Research and analysis

Implementation plan (January 2026): Environment Agency's regulation of waste pneumatic tyres and their export

Updated 12 January 2026

Applies to England

Background 

The review was prompted by concerns that regulatory gaps were allowing UK waste tyre exports to be diverted from legitimate recycling to illegal pyrolysis operations in India. India banned waste tyre imports for pyrolysis in July 2022.

The review concluded we needed stronger measures to ensure waste tyre exports are managed in an environmentally sound way throughout shipment and recovery. We identified 4 priority actions:

1. Implement enhanced verification checks for waste tyre exports.

2. Train staff on UK Waste Shipment Regulations.

3. Strengthen partnership working.

4. Improve horizon scanning.

This plan summarises our progress (up to 12 January 2026) and outlines next steps for 2026.

Implementation of enhanced verification checks

On 1 October 2025, we introduced enhanced verification checks on exports of waste tyres. These checks confirm export destinations and ensure recovery facilities meet environmentally sound management (ESM) standards. Using our regulatory powers, relevant exporters are to provide details of all shipments to non-UK destinations. For exports to India, they must also demonstrate the recovery facility operates to standards broadly equivalent to the UK by providing documentary evidence under a Notice for Information.

We will update further on the findings and outcomes of the enhanced verification checks in spring 2026, including details on the completed Annex VII forms that should be submitted from 22 December 2025 (8 weeks after the first shipments covered by the information notice). Where these are not provided, we will consider whether further shipments to those destinations should be prohibited.

Between 1 October and 15 December 2025

The Environment Agency:

• served 42 exporters with information notices to provide us with information on their intended shipments
• approved 41 Indian recovery facilities that meet ESM standards based on the information provided to us
• rejected 13 facilities that failed ESM standards – movements to these sites are now prohibited

We received 1,093 Annex VII waste movement forms. Because these forms cover waste tyres sent to all destinations, they give us insight into alternative destinations beyond India.

Train staff on the requirements of the UK Waste Shipment Regulations

Training on how to assess ESM evidence

We have prioritised training for our core staff assessing ESM and Annex VIIs being submitted under the enhanced verification process, and we are sharing our learning with colleagues working on related international waste issues.

Mandatory training for international waste shipments (IWS) staff

We are also reviewing and refreshing all of our mandatory e-learning modules which support all IWS staff to carry out their roles. The updated modules will reflect the findings of the review, and we are developing a new module on ESM which will be mandatory. These modules complement our Technical Development Framework, which tracks staff competency and which must be completed prior to staff being fully operational. We aim to complete this review work by April 2026.

For wider teams involved in IWS, we have launched bite-size interactive sessions on ESM. These sessions give an overview of legislation and waste tyre regulation. We started with teams directly regulating IWS in December 2025 and will roll out wider sessions in 2026 across relevant parts of the business, including making them available ‘on demand’.

Strengthen partnership working

The review highlighted the importance of collaborating with a wide variety of stakeholders to ensure that we understand the risks and threats posed by international movements of waste tyres. We continue to invest in our partnership working with government, UK regulators, industry, and international partners.

Government engagement

We continue to work with government departments including the Department for Environment, Food and Rural Affairs (Defra), the Department for Business and Trade, the Department for Energy Security and Net Zero, and the Foreign and Commonwealth Development Office. We share updates on the effectiveness of our enhanced checks, and any learning, opportunities, risks, or implications arising from changes to our regulatory approach in the UK and overseas. This will help our understanding of any policy changes. We will continue building these relationships in 2026 and plan to engage with the Circular Economy Taskforce Group for Transport.

Engagement with partner organisations and international networks

We have shared our findings, research and best practice with the UK Competent Authorities in Scotland, Wales, and Northern Ireland. We presented at the EU Network for the Implementation and Enforcement of Environmental Law (IMPEL) Waste and Transfrontier Shipments Conference to raise awareness and learn from others tackling illegal waste shipments, including tyres, across Europe. We have kept partners informed through regulator meetings, Basel Convention projects, and bilateral exchanges.

Collaboration with Indian environmental authorities

In September 2025, we visited India to strengthen relationships and explore collaboration to tackle waste crime. Engagement with authorities and industry shaped stronger verification checks and informed evidence requirements. Learning about India’s Extended Producer Responsibility framework directly influenced our approach for the enhanced verification checks. We will build on these links in 2026.

Participation in Basel Convention working groups

We are a key contributor to the Basel Convention Small Intersessional Working Group (SIWG) to update global guidelines for managing used and waste tyres. These guidelines give environmental authorities, industry, and others clear advice on how to manage used and waste tyres in an environmentally sound way. We provided detailed comments on the draft and supported Defra as UK Focal Point. We are preparing for the next SIWG meeting in March 2026.

Industry engagement

We worked closely with the waste tyre sector to make enhanced checks practical and effective. We attended industry events, delivered a webinar for exporters, joined stakeholder meetings, and met operators. Industry engagement helped us refine our approach and develop targeted interventions based on shared intelligence.

Horizon scanning

The review showed we needed to anticipate emerging risks in international waste tyre movements. We are strengthening our horizon scanning by sharing insights across teams, conducting research, and working with external partners.

Our National Environmental Crime Unit updates priority waste streams regularly to ensure we’re focused on the biggest risks. We are also working on a plan to ensure intelligence is more visible to staff by making information more accessible on our internal database. We are commissioning a literature review on existing and emerging waste tyre research and will report initial findings from this in spring 2026.

Next steps

In early 2026, we will publish a further update on our work, including more information relating to the enhanced verification checks.

Whilst our immediate focus has been on waste tyre exports, we are planning wider reforms for international waste shipments. Current Article 18 (green list) rules create opportunities for poor-quality and contaminated waste exports. Through regulatory reforms with the support of Defra, we intend to implement improved compliance activity to stop illegal exports, protect the environment and human health, and support sustainable growth. Reforms will create a fairer market for legitimate exporters and help to stop waste crime.

We are developing a new system for regulating green list waste shipments ahead of Digital Waste Tracking. Plans include more compliance officers, better data, and new digital tools to target high-risk shipments. We intend to introduce a charging scheme for green list waste movements to fund increased compliance and enforcement. We will consult on this in early 2026. If adopted, we will apply lessons from waste tyre checks to other green list waste streams later in 2026.

We remain committed to Digital Waste Tracking as part of our long-term approach. Defra will provide more details in due course. Until then, our interim proposals will strengthen regulation of green list waste.