Western Europe generates some four million tonnes of used rubber annually – and that is just from used tyres. Add to that, belting and other industrial rubbers and the figure is a whole lot more. No-one knows exactly how much.

Old tyres are a useful source of energy with a high calcific value, so they make for a popular fuel. A sizeable proportion of used tyre arisings managed in Europe actually go into kilns and furnaces, particularly in cement production, and almost all exported tonnages are similarly used. In Britain, we annually export more than 200,000 tonnes of old tyres to be used in this way.

The export of old tyres is not an ideal way of exploiting their value. It undermines our own need for domestic resilience in tyre recycling and also puts us at the mercy of price variations in export markets, which have a knock-on effect here at home by often destabilising our home marketplace for locally managed recovery and recycling. It can be damaging in another way too as such market instability deters investment in the new products and technologies we strive for.

The export of old tyres also gives rise to other concerns especially relative to standards of environmental compliance beyond our control. In the Tyre Recovery Association (TRA), we are trying to do something about this but the Government remains resolutely unhelpful. Nevertheless, despite often poor levels of enforcement in our own country, we have made progress as an industry.

Tyre recycling in the UK has long been a tale of two cultures. Since 2006 the tyre industry here has been required to recover or reuse virtually 100% of its used tyre arisings, but that recognised achievement has not been without its issues.

Firstly, there is still too much poor practice and rogue activity where the enforcement record of our regulations has at best been patchy as too many incidences of illegal dumping and fly tipping testify. Secondly, bad practices are like viruses. They spread and mutate and have badly infected some disposal routes, especially the export of some of our waste tyres.

Exporting our old tyres has become all too easy and has been increasing when we should be striving for greater domestic resilience. We should be developing more pyrolysis projects, where the carbon black and steel in tyres is recovered and converted to a partially renewable oil. Instead, we rely too much on fickle export markets. This is not to argue against exports per se, but we will need less of them in years to come if these new pyrolysis and other market opportunities are to thrive here in Britain.

Some things are moving in the right direction. This year we expect the Government to announce the end of T8 Exemptions; Defra’s so-called ‘light touch’ approach to the regulation of small-scale operators which, though well-intentioned, has been all too frequently abused. This move is expected to be accompanied by strict compliance monitoring of suspect exempt operators across England and Wales in the transition period which will follow. The result should be the further raising of standards all-round.

There is one other factor that is affecting us all: rising operating costs. TRA members are facing exponential rises in operating costs, which will have to be passed on to the consumer. We will aim to mitigate these as best we can but they are ultimately unavoidable.

What of the future? Legislative changes to the way we operate are in the air and if all of these are implemented, they will change the business of waste management generally and of tyre recycling in particular. Consultations announced earlier this year envisage much stricter permitting rules for waste collectors, brokers and all those who handle waste, including tyres. If implemented, they will require mandatory registration for all those handling even their own businesses to meet new standards of technical competence.

Defra and the Environment Agency have also recently launched consultations on the reform of waste carrier, broker, dealer registration in England, and mandatory digital waste tracking across the whole of the UK. The implications of both documents are far-reaching. These new legislative ambitions will form the backbone of the regulatory requirements we will need to work to in the near future, so we need to ready ourselves for this further professionalisation of tyre recycling in Britain.