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ELTs play their part

Legislative decree on management of end-of-life tyres

The Ministry of the Environment decree on the management of end-of-life tyres proposed in 2006 will come into force on 7 September 2011. The prevention of end-of-life tyre build up, optimization of recovery, and traceability are the main objectives of the regulation

Roberta Papadia

By 7 September 2011, the manufacturers and importers of tyres are required to collect and manage an annual quantity of end-of-life tyres, by any brand, that is equivalent (in weight) to the number of replacement tyres that they placed on the domestic market during the previous year.


After years of waiting, Ministerial Decree 82/2011 on end-of-life tyres (ELTs) is here at last. It all began with article 228 of Leg.Dec.152/2006 (the environmental code), which aimed at organizing the management of ELTs to optimize their recovery, prevent build up (also by retreading) and protect the environment. Decree 228 states that it is obligatory for the manufacturers and importers of tyres (the so-called producer responsibility) to individually or jointly ensure the management of the same quantity of end-of-life tyres as the replacement tyres sold on the domestic market the previous year. A contribution will be paid by the end-user to cover the costs of managing ELTs. System start up was dependent on the actuation decree, which came into force on 9 June with implementation 90 days later (7 September 2011).
Just like any important change in legislation, it will take time for the system to become fully operative and for harmonizing legislative theory - which sometimes leaves too much room for interpretation - and practice. The aim is praiseworthy, but it will certainly need everyone's commitment if is to be achieved.


Management criteria
By 7 September 2011, the manufacturers and importers of tyres are required to collect and manage an annual quantity of end-of-life tyres, by any brand, that is equivalent (in weight) to the number of replacement tyres that they placed on the domestic market during the previous year.
To give the system a slight breathing space, the following partial quantities have been established:
By 31 December 2011, the management of at least 25% of the quantity placed on the domestic market in 2010;
By 31 December 2012, the management of at least 80% of the quantity placed on the domestic market in 2011;
By 31 December 2013 and for subsequent years, the management of 100% of the quantity placed on the domestic market during the previous solar year.
Excluded from the regulation are end-of-life bicycle tyres, inner tubes, the relevant flaps and rubber seals, and airplane and aircraft tyres in general. ELTs that have been removed from demolished vehicles (Leg. Dec. 209 of 24 June 2003) are subject to the specific procedure indicated in the Decree (art.7).
The law also envisages fines. These will be calculated in proportion to the contribution percentage and refer, very briefly, to failure to meet the minimum quantities provided for by law, omitted reporting, or the non-fulfilment of obligations for managing end-of-life tyres. For other indirect fines, the Decree refers to Law 689 of 24 November 1981 (Amendment of the Penal System).

The start of environmental contributions

Also in force from 7 September is the environmental contribution established by the Ministry for the Environment. The contribution varies depending on the type of tyre and it is clearly indicated on all invoices (or receipts) for the sale of tyres on the domestic replacement market.


The Decree establishes that manufacturers and importers must prioritize the collection of ELTs generated on the replacement market subsequent to the date the Decree came into effect. And this leads us to stocks: ELTs, and products deriving from their destruction, which are part of historical stocks generated by tyre replacement operations, or by removal from demolished vehicles, before the Decree came into effect, may be used to make up for any shortfall in quantities. The Law also requires that joint operating structures must allocate, if applicable, no less than 30% of ascertained surplus to the management of historical stocks.


End-of-life tyres from demolished vehicles
As mentioned, end-of-life tyres from demolished vehicles are governed separately. On request, the manufacturers and importers of tyres, either directly or through their associates, collect and manage ELTs removed from demolished vehicles against payment of a sum from a fund set up by the Italian Automobile Association (ACI). There will also be a special management committee at ACI offices. In this case, the contribution is collected by the dealer (from 7 October) and paid into the fund when a new vehicle is sold on the domestic market.


The role of Ecopneus
Without doubt, a leading role in the new system for the management of end-of-life tyres is played by Ecopneus, the non-profit joint-stock association set up at the beginning of 2009 by the main tyre manufacturing or importing companies in Italy: Bridgestone, Continental, Goodyear-Dunlop, Marangoni, Michelin and Pirelli. Representing over 80% of the domestic market, Ecopneus is the main interface and is responsible for the development of a system that must guarantee collection, recovery and monitoring throughout Italy.
The association will have to manage a large part of the over 380,000 tonnes of ELTs produced in Italy by giving them a new life and by promoting the sectors of use. Currently, according to Ecopneus, 100,000 tonnes of ELTs "disappear" every year. They are abandoned in illegal landfills, streams, rivers, quarries and the countryside, to the detriment of the landscape and the environment. Also not to be underestimated is the figure that emerged from the Legambiente 2005-2010 census: there are 1,049 illegal landfills in an area of over 6 million square metres (6,170,537 to be exact).


• The nature of tyres  


A tyre is a sophisticated product with a complex structure that also contains metal and fabric reinforcements. Its main components are:
elastomers from 45 to 47%;
carbon black from 20 to 22%;
metal reinforcements from 16 to 25%;
textile reinforcements up to 6%;
other ingredients and sulphur from 1% to 3%. 


• The road to recovery  


Every year about 30 million tyres are changed on cars, 2 million on trucks, 3 million on two-wheeled vehicles, and 200,000 on industrial and agricultural vehicles: an important source of materials for recycling and energy recovery. End-of-life tyres can be used in numerous applications, either whole or in the form of granules of various sizes. As far as energy recovery is concerned, they have the same calorific value as coal and crumbled, shredded or whole tyres are used in sectors such as the cement industry and in energy/steam generating plants.
The material is recovered by a granulation process that reduces it to increasingly smaller sizes and powder. Many uses have been identified at international level, for example as modified asphalt (0-0.8mm powder and 0.8-2mm granulate). Rubber added to bitumen conglomerate increases the durability of road surfaces, reduces noise emissions, increases grip when braking, and drainage.
In Italy, it has been used in various applications in Tuscany, Emilia Romagna and Piedmont. Another interesting application is in sports facilities (0.8-20 mm deferrized granulate) as drainage for fields of artificial grass and athletics tracks, impact-absorbing surfaces and equestrian surfaces. Another use is as insulating material (0-20 mm granulate and deferrized powder). Rubber granules bonded with polyurethane resins are used to make soundproofing panels, sound-deadening mats, waterproof membranes, anti-vibration and anti-seismic materials with good elastic properties, and for the prevention of injuries. Other uses are urban furnishings, surfacing and products (0-15 mm granulate and deferrized powder). Here, rubber granules bonded with polyurethane resins or combined with other thermoplastic polymers, are used for make speed bumps, traffic delimiters, kerbs, mattresses for animal breeding, rubber bricks, etc.. In civil engineering, whole end-of-life tyres or 10-400 mm shredded and crumbled tyres are used for sound barriers, erosion barriers, slope stabilization, coastal protection, road drainage and insulating embankments, and drainage for new landfills.
Rubber powders are recycled to make new compounds (0-0.4 mm powder) for technical articles and a minimum amount is used in tyre compounds. In addition to the second-fusion recovery of steel from broken up ELTs, at international level steel works are increasingly interested in the partial substitution of anthracite and coke (used to reduce metal oxides) with ELTs of various sizes depending on the type of plant (25-400 crumbled). Chipped tyres coated with polyurethane resins (10-50 mm deferrized chips) in a variety of colours are used instead of conifer bark as mulch in public gardens, traffic division islands, roundabouts, etc.. This application is not yet widespread in Italy. When subjected to mechanical or heat processes or ultrasound irradiation, rubber powders and granules (regeneration, 0-20 mm powder and granulate) can be de-vulcanized with variable results depending on the start material and the technology used. The end product is particularly suitable for reuse in new rubber compounds, even in high percentages. 

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