Crumb rubber restrictions. Is the fat lady warming up for the end of the show?
ECHA to Recommend Restrictions on Crumb Rubber
Tyre and Rubber Recycling is not usually given to speculation on leaks, but this is a case where we feel a need to highlight an issue.
On 3rd June 2020, The European Chemicals Agency RAC committee met in a series of discussions about recommendations and restrictions. It is believed that the discussion on Crumb Rubber took place under 9.1 Restriction Annex XV dossiers … 3) Microplastics – final draft opinion for discussion and adoption.
Reports leaked from the meeting to the industry suggest that there were two options on the table, the first to accommodate crumb rubber use, the second to recommend an outright ban on crumb rubber use where the particle size was <5mm or a thread length was <15mm. This recommendation to the European Commission was to include a six-year adoption period from 2021.
No hard copy of the minutes, nor a press release have been issued by the ECHA yet.
Dr. Shulman and Dr. Mussacchi at ETRA have both been made aware of the recommendation. Peter Taylor at the TRA anticipates a big response from the tyre industry as it precludes the use of crumb rubber in ANY new products. This could severely hit Michelin’s investment in LeHigh. There is no clarity at this stage but since crumb rubber is a feedstock for reclaim and devulcanisation processes it may well also impact those sectors.
With as much as 45% of recovered material from tyres going into artificial sports surfaces and wet poured play surfaces, this recommended ban would have a massive impact upon recycling across Europe. This is a complete reversal of previous statements by the ECHA.
Recyclers who had diverged into product manufacturing would lose their markets and their investments.
The ban would create a massive oversupply of tyre material for recycling and no country in Europe has the capacity to pyrolise of use the volume for cement kilns.
The other side of the coin is that virgin materials would be used to replace the current crumb rubber markets – there are already virgin materials being offered for sports surfaces. There could be a huge increase in demand for natural rubber (and SBR), placing unprecedented demands on the NR producing countries and the associated damage on the environment.
Of course, it is expected that the ETRMA – acting on behalf of the tyre manufacturers will seek a derogation on the regulations, and probably there would also be pressure from IASLIM representing the sports industry provision.
For the UK, after the 1st January 2021 this , technically has no legal impact under a No Deal termination of the BREXIT deal – but, we can expect the US agencies to follow the EU, and without operating to EU standards no UK processor will be able to sell his products in Europe.