Tyre pyrolysis oil: proposed resource framework: consultation response
Published 6 June 2025
© Crown copyright 2025
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This publication is available at https://www.gov.uk/government/consultations/tyre-pyrolysis-oil-proposed-resource-framework/outcome/tyre-pyrolysis-oil-proposed-resource-framework-consultation-response
Foreword
There were originally 13 published quality protocols setting out end-of-waste positions for a number of different materials. These are currently under review. Progress is given in the waste quality protocols review page which is published on GOV.UK.
During the review process, some industry bodies approached us to ask about the potential for new end-of-waste frameworks to cover new waste streams. This resulted in us offering the industry the ability to apply for new frameworks. The way we do this is explained in our guidance on how to request a resource framework to show when a material has ceased to be waste.
The first submission from industry came from the Renewable Transport Fuel Association for a new framework to produce tyre pyrolysis oil as a feedstock to fuel production. This consultation was done to gather views from industry and the wider public on the content of the new framework.
We would like to thank all respondents for taking the time to contribute to the consultation process. We will use this information to help shape the development of the new resource framework.
Consultation summary
A resource framework sets out end of waste criteria for the production and use of a product from a specific waste type. Compliance with these criteria is considered sufficient to ensure that the fully recovered product may be used without undermining the effectiveness of the Waste Framework Directive. And as such, without the need for waste management controls.
In addition, a resource framework indicates how compliance may be demonstrated and points to good practice for the use of the fully recovered product. A resource framework further aims to:
- provide increased market confidence in the quality of products made from waste
- reduce waste
- support the circular economy
In this consultation we were interested to hear from industry and the wider public on:
- the proposed new resource framework for tyre pyrolysis oil
- the approach that has been taken to help inform our decision
- confirmation (or otherwise) of the specific requirements of the framework
This consultation was available on our Citizen Space consultation website and we made copies available on request.
We encouraged staff and partners to raise awareness of the consultation with their networks.
We received 16 responses to the consultation from a range of stakeholders including:
- fuel producers
- consultants
- trade associations
- waste management companies
You responded broadly under 3 themes:
- positive view of the direction being taken by the Environment Agency with regard to feedstock materials and end-of-waste
- issues with the status of import and export of tyre pyrolysis oil
- requests to broaden the scope of the framework to include other waste inputs, end products or end markets
Responses received to this consultation informed the process of producing this resource framework.
Responses to consultation questions
Question 1: Is it clear within the resource framework document what requirements need to be met in order to achieve end of waste for tyre pyrolysis oil?
| Number of responses | |
|---|---|
| Strongly agree | 5 |
| Agree | 9 |
| Neither agree nor disagree | 0 |
| Disagree | 0 |
| Strongly disagree | 2 |
| Total | 16 |
Most responses were positive about the requirements detailed within the new resource framework.
There were 2 respondents who disagreed with the content. They requested further definition of pyrolysis and to expand the scope of the framework to include:
- different waste inputs, such as plastics
- further outputs from pyrolysis, such as carbon black
At this stage it is worth outlining that provision of end-of-waste guidance is not statutory requirement of the Environment Agency. We see the benefit and would like to promote this work to enable a circular economy, and we do this by charging for our time.
As part of this process, we ask industry to work with us through task and finish groups. The scope of any new framework is defined at the start of the process by the party who brought the submission to us and are funding the process.
The guidance on how to request a resource framework to show when a material has ceased to be waste explains how you can work with us and fund our time to:
- add further waste inputs to a framework
- produce new frameworks
In this case, the Renewable Transport Fuel Association wanted to look specifically at tyre pyrolysis oil with a view to it being used as a feedstock to refineries in the production of fuels.
There was also a request to add in detail on import and export requirements of tyre pyrolysis oil product material. This will be added to the final document.
Question 2: Is it clear tyre pyrolysis oil produced under this framework is suitable for use in the identified end market, i.e. refineries?
| Number of responses | |
|---|---|
| Strongly agree | 3 |
| Agree | 8 |
| Neither agree nor disagree | 2 |
| Disagree | 1 |
| Strongly disagree | 2 |
| Total | 16 |
As with question 1, most respondents agreed that the framework was clear on the issue of suitability of the oil for the end market.
There were 3 respondents who either disagreed or strongly disagreed. The issues they raised related to a desire for the framework to be widened in scope to:
- accommodate further waste inputs
- allow different products or end markets
Check the guidance on how to request a resource framework to show when a material has ceased to be waste if you’re interested in working with us and funding our time to:
- add further waste inputs to a framework
- produce new frameworks
Question 3: Do you foresee any potential adverse human health impacts from the use of the material in the manner described in the resource framework?
| Number of responses | |
|---|---|
| Strongly agree | 0 |
| Agree | 2 |
| Neither agree nor disagree | 6 |
| Disagree | 1 |
| Strongly disagree | 4 |
| Prefer not to answer | 3 |
| Total | 16 |
We note that this question should have been a yes or no question, rather than variations on agree or disagree.
The split in responses is not consistent with the comments received. Most said they could not foresee any potential human health impacts.
One respondent requested addition of requirements for the refineries accepting the material. This will be covered by the permit, so is not included within the resource framework.
Another respondent said they would agree if scope of the resource framework was widened.
Check the guidance on how to request a resource framework to show when a material has ceased to be waste if you’re interested in working with us and funding our time to:
- add further waste inputs to a framework
- produce new frameworks
Question 4: Do you foresee any potential adverse environmental impacts (over and above other refinery feedstocks) from the use of the material in the manner described in the resource framework?
| Number of responses | |
|---|---|
| Strongly agree | 0 |
| Agree | 2 |
| Neither agree nor disagree | 6 |
| Disagree | 1 |
| Strongly disagree | 4 |
| Prefer not to answer | 3 |
| Total | 16 |
We note that this question should also have been a yes or no question, rather than variations on agree or disagree.
The split in responses is not consistent with the comments received. Most said they could not foresee any potential environmental impacts.
One respondent requested:
- addition of requirements for handling and storage requirements for transportation (which is outside the remit of resource framework)
- clarification on status of other pyrolysis products, such as carbon black
One respondent said they would agree if scope of the resource framework was widened.
Check the guidance on how to request a resource framework to show when a material has ceased to be waste if you’re interested in working with us and funding our time to:
- add further waste inputs to a framework
- produce new frameworks
Question 5: Does the specification detailed in section 8.4 of the framework for tyre pyrolysis oil identify all potential contaminants of concern?
| Number of responses | |
|---|---|
| Strongly agree | 2 |
| Agree | 6 |
| Neither agree nor disagree | 4 |
| Disagree | 2 |
| Strongly disagree | 0 |
| Prefer not to answer | 2 |
| Total | 16 |
We note that this question should also have been a yes or no question, rather than variations on agree disagree.
The split in responses is not consistent with the comments received. Most said the specifications included contaminants of concern.
One respondent listed further contaminants for consideration.
One noted that the specification may not be appropriate if the scope was widened to include further waste inputs, such as plastics.
Question 6: Does the specification detailed in section 8.4 of the framework for tyre pyrolysis oil adequately limit all potential contaminants of concern?
| Number of responses | |
|---|---|
| Strongly agree | 2 |
| Agree | 6 |
| Neither agree nor disagree | 4 |
| Disagree | 2 |
| Strongly disagree | 0 |
| Prefer not to answer | 2 |
| Total | 16 |
We note that this question should also have been a yes or no question, rather than variations on agree disagree.
The split in responses is not consistent with the comments received, with the comments replicating those above in question 5.
Question 7: Is the text of the resource framework clear?
| Number of responses | |
|---|---|
| Strongly agree | 3 |
| Agree | 11 |
| Neither agree nor disagree | 1 |
| Disagree | 1 |
| Strongly disagree | 0 |
| Prefer not to answer | 0 |
| Total | 16 |
We note that this question should also have been a yes or no question, rather than variations on agree disagree.
The split in responses is not consistent with the comments received, with the comments replicating those above in question 5.
Next steps
The responses we received to this consultation informed the process of updating the draft document. Following this, we shared the draft with the task and finish group.
We have now finalised and published the Tyre pyrolysis oil: resource framework.