Research and analysis

Progress update (March 2026): Environment Agency's regulation of waste pneumatic tyres and their export

Updated 31 March 2026

Applies to England

Since we published our waste pneumatic tyres review in August 2025, the Environment Agency has strengthened traceability across the waste export chain. We are more confident that waste pneumatic tyres reach legitimate overseas recovery facilities for treatment, particularly to India.

Alongside our implementation plan published on 12 January 2026, this update:

• explains the progress made to date
• reports on the performance of the enhanced compliance checks we introduced in October 2025
• outlines further reforms planned for Article 18 waste exports

Executive summary

We have made strong and measurable progress since publishing the waste tyres review in August 2025. The enhanced compliance checks introduced in October 2025 are delivering results. They give us clearer oversight over the waste export chain and support our regulation to ensure tyres are treated in an environmentally sound way in India. We have stopped shipments to recovery facilities in India that cannot show they operate to equivalent environmental standards to those in the UK. Operators are responding to information requests, and where responsibilities have not been met, we have taken proportionate and timely action including considering further formal enforcement.

Based on our learning from this work, we are now progressing wider changes to enhance controls for shipments of all Article 18 (Green List) wastes and introduce charges to fund our compliance activity. This will take place in a phased approach with interim changes due to be implemented from July 2026. Further changes for Article 18 waste are planned for delivery through digital waste tracking from 2027 onwards through legislative reform lead by the Department for Environment, Food and Rural Affairs (Defra).

We are investing in our people. Staff now receive consistent, targeted training on the Waste Shipment Regulations. New training modules from April 2026 will give teams the skills they need to monitor and enforce waste movements effectively. We are also recruiting more staff to support enhanced compliance checks and compliance monitoring.

Our international work has advanced significantly. Engagement with the Indian authorities, including a visit in September 2025, has strengthened relationships and improved our understanding of local controls. This insight has shaped the evidence we now require from exporters. This collaboration helps us prevent exports to facilities that cannot show environmentally sound operations.

Our national inspection campaign of T8 facilities is strengthening our confidence in site compliance. Overall, compliance is high and where issues have been found, this has been minor and is being resolved. We have found no widespread or serious non-compliance.

We remain committed to transparency. Our actions since the review, and the results they have produced, give stakeholders and the public greater confidence in how we regulate waste tyre exports. This progress shows that stronger oversight, better data and closer partnership working can deliver real improvements. Together, these steps help tackle waste crime, create a fairer market, and support legitimate businesses.

Review actions

The review identified the need for stronger measures to make sure waste tyre exports are managed in an environmentally sound way throughout the period of shipment and their final recovery.

We set 4 priority actions:

• introduce enhanced compliance checks for exports of waste tyres
• improve staff training on the Waste Shipment Regulations and their application to tyres
• strengthen research and horizon scanning on global waste controls
• build stronger partnerships with key stakeholders to support compliance and oversight

Headline statistics

These statistics cover the period from 1 October 2025 to 23 February 2026. The figures will change as work continues.

We have served:

• 48 information notices on waste tyre exporters
• 21 prohibition notices on operators where they have not responded to those information notices, or the information we have received is inadequate

Assessment of environmentally sound operations in India

We have received 85 applications for destination recovery facilities in India:

• 50 applications were assessed and acknowledged as demonstrating they were operating to environmentally sound standards broadly equivalent to those in the UK
• 35 applications were rejected due to a lack of evidence provided by the exporter

Tracking of waste pneumatic tyres

We now have a clearer picture of waste tyre exports. We have:

• received details of 4,189 Annex VII forms at least 3 days before shipment
• assessed 1,839 shipments were within the 8-week deadline to provide post-shipment information
• assessed 2,350 shipments had exceeded the 8-week deadline to provide post- shipment information
• received 667 post-shipment Annex VII forms
• received 54 complete post-shipment Annex VII forms with geotagged evidence demonstrating the shipment arrived at the intended recovery facility in India
• received 613 non-compliant post-shipment Annex VII forms because of missing, incomplete or incorrect information – we have followed up on each of these with further compliance and enforcement activity
• have followed up all 1,172 shipments that still have information pending after the 8-week deadline

Enforcement

We have issued 6 warnings to 5 companies covering 14 recovery facilities, addressing issues such as missing evidence or incorrect Annex VII information.

We have started the fixed penalty notice process for one exporter relating to non-compliance with Annex VII requirements.

We are considering further enforcement on 2 non-compliances:

• 1 relates to not submitting an Annex VII and exporting to a destination recovery facility which had not been assessed
• 1 relates to not submitting an Annex VII outside of the required 3-day pre-shipment period

T8 exempt and permitted facility inspections

As of 13 March 2026, we have inspected 90 facilities. Our inspections identified:

• 63 were fully compliant (62 T8 facilities and 1 permitted facility)
• 25 were non-compliant (20 T8 facilities and 5 permitted facilities)
• 2 reports were pending

Action 1: Enhanced compliance checks

From 1 October 2025, enhanced compliance checks were introduced to ensure that English sourced waste tyres reach their intended destinations and are not diverted to illegal waste sites. We also needed assurance that tyres exported to India are recycled at facilities operating in an environmentally sound manner broadly equivalent to the UK.

Information required

We served information notices on exporters of waste tyres to require them to provide information about their operations. We used existing records, intelligence, public registers, and industry reports to identify operators. Further notices were issued as more operators became known to us. The information notices required that:

Before shipment, exporters must:

• provide details of their shipments at least 3 days before they begin
• provide evidence that the destination recovery facility meets environmentally sound management standards (required from 28 October 2025)

After shipment, exporters must provide the completed Annex VII forms and a geotagged photograph within 8 weeks of the movement.

48 operators were served an information notice. However, 21 operators did not respond within the deadline, resulting in prohibition notices being served to prevent further exports. 3 operators subsequently confirmed they do not export waste tyres, and their prohibition notices were withdrawn. Data analysis suggests none of the 18 exporters who failed to respond have attempted to export waste tyres since prohibition notices were served. We will intervene if we have information that they attempt to export waste tyres.

Environmentally sound destination recovery facility assessment

Exporters sending waste tyres to India must demonstrate that each destination recovery facility operates to environmentally sound standards broadly equivalent to those in the UK. Each exporter must provide evidence for the facilities they plan to use, and several exporters may apply for the same site. Because commercial relationships between exporters and the destination recovery facilities are confidential, we assess each application separately and acknowledge the facilities on an exporter specific basis where there is adequate evidence supplied. This means a facility can be acknowledged for one exporter but rejected for another if the evidence they provide is not satisfactory.

Post-shipment information

To 23 February 2026, we have identified 1,172 post shipment Annex VII forms that had not been returned within the 8-week deadline (35 from October, 570 from November and 567 from December).

In response, we have:

• followed up with operators within 7 days of the deadline
• requested the missing information and confirmation of expected arrival dates
• given exporters 7 days to provide the required evidence
• made clear that failure to respond may result in prohibition notices being served

We have now received all post-shipment Annex VII forms for October shipments. We are reviewing the pending information for November and December and engaging with operators to understand the reasons for delays. We assess each case through our enforcement and governance procedures, also considering current uncertainties in global shipping, before escalating to formal action.

Extension of deadline

Exporters have told us that the 8-week deadline does not reflect the realities of deep-sea transport, operational logistics, and customs clearance. This may be one reason why initial figures we provided appeared to infer low compliance, when waste had not yet reached its destination. We have extended post-shipment deadline from 8 weeks to 16 weeks to reflect this feedback. We will issue prohibition notices at 16 weeks unless there are clear mitigating circumstances.

Quality of evidence

We have received:

• 667 post-shipment Annex VII forms
• 54 compliant post-shipment Annex VII forms with geotagged photographs
• 613 non-compliant forms due to missing geotagged photographs, missing location metadata, or incorrect or incomplete information

Some operators have reported they cannot provide geotagged photos because:

• the container was unpacked (devanned or destuffed) before the final facility, breaking the ability to match the specific container to the destination recovery facility named on the Annex VII form
• the destination recovery facility did not supply a photograph, or the photo did not contain the digital location data

Where containers are unpacked, exporters must provide other evidence to show traceability. We are working with operators to agree how they will do this. If we are not satisfied that waste reached the intended recovery facility, we will issue prohibition notices to prevent further exports to that destination.

Lessons learnt from implementing enhanced compliance checks

We are using the lessons from this work to:

• inform the development of an interim, strengthened compliance approach for all Article 18 wastes to be introduced from July 2026 – these changes will require data reporting and the payment of charges to allow for enhanced compliance activity, and further controls will be delivered through digital waste tracking from 2027
• require operators to update us if they change the intended destination recovery facility during the movement or decide not to export in the reporting period, improving the accuracy of data we hold
• extend the use of information notices beyond 1 April 2026 until our planned reporting and charges for all Article 18 wastes are introduced from July 2026

We recognise that issuing information notices at scale is burdensome for both industry and the Environment Agency. This reinforces the need for this data to be collected through mandatory digital waste tracking in the longer term.

T8 and permitted facility inspections

A T8 exemption from environmental permitting allows small scale treatment of end-of-life tyres, such as baling, shredding or granulating. The review raised concerns that some operators were exceeding the 40-tonne limit for waste car tyres over a 7-day period.

In November 2025 we launched a national inspection campaign to identify whether the concerns were justified. As of 4 February 2026, 711 T8 facilities are registered. Our analysis shows that, of these, 412 facilities are farm-based and 299 are non-farm based. We prioritised inspecting non-farm sites as they are more likely to be linked to tyre exports.

As of 13 March 2026, officers have inspected 90 facilities (82 T8, 8 permitted):

• 63 facilities were compliant
• 25 were not compliant (20 T8, 5 permitted)
• 2 reports were pending

Of the 20 non‑compliant T8 facilities:

• 2 facilities lacked fire breaks
• 1 facility had no fire breaks, exceeded the 10‑tonne pile limit, and operated outside their exempt area
• 1 facility exceeded the 10-tonne pile limit
• 5 facilities exceeded tonnage limits
• 5 facilities exceeded tonnage and lacked fire breaks
• 1 facility had been vacated
• 1 operator used another operator’s exemption and was advised to register their own
• 1 facility had a lack of sealed drainage
• 3 registered exemptions were being operated within permitted facilities and were advised to deregister the exemptions

We assess compliance using our Waste operations and installations: assessing and scoring environmental permit compliance guidance. Officers assessed all the non-compliances as minor. These issues are being addressed through advice and guidance. For example, some facilities held slightly more tyres than allowed, typically around 70-80 tonnes.

Among the 5 non-compliant permitted facilities, issues related to:

• storage
• record‑keeping
• drainage
• infrastructure

One facility is being considered for enforcement action. The others were minor breaches that are being resolved through advice and guidance.

Our inspections show no evidence of widespread or serious noncompliance by either permitted operators or those using the T8 exemption. We will continue intelligence led inspections as part of our routine work.

We support government plans to reform waste exemptions, including removal of the T8 exemption (subject to parliamentary time).

Action 2: Training

We have delivered targeted training to strengthen staff understanding of the Waste Shipment Regulations. New modules on tracking requirements and environmentally sound management will launch from April 2026. These resources will support a more joined up approach to compliance monitoring and enforcing waste movements.

Action 3: Horizon scanning

We now scan more widely for changes in global waste controls and emerging risks. We have committed to 2 areas of work:

• reviewing our research into waste pneumatic tyres, including their materials and the impact they have on the environment and human health
• improving how we scan for future risks, so we stay alert to changes in international rules that affect waste tyre exports

Research and evidence

Research into waste tyre constituents

We have commissioned an internal research project to assess whether waste pneumatic tyres meet the criteria to be classed as hazardous. The project will summarise our existing research and gather relevant information from industry stakeholders on studies they have completed or plan to commission.

We will engage across the tyre industry, including producers and recyclers, to build a full picture of the evidence available. Engaging with producers gives us important insight into tyre design and constituents, which may influence how tyres should be classified when they become waste.

The commission also includes a literature review of academic research, with commentary on the statistical relevance and limitations of those studies.

Article 18 controls

Defra wrote to India’s Ministry of Environment, Forestry and Climate Change in March 2026 to confirm if Annex VII controls remain appropriate for UK to India waste tyre movements. Any amendments to the current controls would require legislative change led by Defra.

Basel Convention technical guidelines

We have contributed to the Basel Convention Small Intersessional Working Group updating the technical guidelines on the environmentally sound management of used and waste pneumatic tyres. The guidelines aim to ensure strengthened and more consistent international requirements. The guidelines will be further discussed at the Basel Convention Open Ended Working Group in June 2026.

Scanning for future risks

Strengthening horizon scanning

We have strengthened our horizon scanning and how teams share intelligence. We:

• are creating a waste export working group to monitor global, political, economic and social developments that could impact international regulatory controls and market trends
• record information from inspections, port visits and research in a consistent way – this helps us share intelligence across teams and spot risks earlier
• have improved how we share intelligence across teams – feedback from industry, government and international partners has helped us make this information easier for staff to use
• identify emerging risks and opportunities and adapt our regulatory strategy in response – our waste prioritisation work helps us focus on priority waste streams, routes, sources and destination countries

Intelligence development

We assess risks linked to international waste exports using the MoRiLE (Management of Risk in Law Enforcement) method. We completed assessments for waste tyre exports in February 2025 and updated them in August 2025. We regularly review our MoRiLE assessments to ensure they represent current and future risks accurately.

A Market Analysis Report has helped us focus on the bulk brokers that dominate the export market. The report also highlighted limitations in using the customs code for waste rubber to understand market trends which is not specific to waste pneumatic tyres. The Basel Convention Secretariat is working with the World Customs Organisation to address this.

Our Strategic Intelligence Team carries out routine horizon scanning and produces quarterly threat assessments on emerging risks.

Action 4: Partnership working

Government and UK partners

We work closely with government departments, including the Department for Business and Trade and the Foreign, Commonwealth and Development Office. We also stay in close contact with the other UK competent authorities which helps us compare regulatory approaches and share intelligence to improve the traceability of waste tyre exports. We meet Defra regularly to update them on progress, risks and emerging opportunities and will contribute to the Circular Economy Taskforce on Transport once established.

Collaboration with Indian stakeholders

A visit to India in September 2025 strengthened relationships with environmental authorities and the tyre recycling sector. The visit:

• improved our understanding of India’s regulatory controls
• provided insight into legitimate recycling operations
• informed the information we require to demonstrate environmentally sound operations
• supported shared assurance on the legitimacy of destination recovery facilities

We continue to maintain close dialogue with the Indian authorities.

Industry engagement

Engagement has included meetings, events, direct communications, and one-to-one discussions. A webinar for exporters in October 2025 set out evidence requirements and gave operators a chance to ask questions and clarify expectations. We are planning another stakeholder event in June 2026.

International engagement

The Environment Agency is committed to international collaboration where it improves regulatory outcomes and efficiency. Through the European Union (EU) Network for the Implementation and Enforcement of Environmental Law (IMPEL), we presented our work on tyres at events in October and November 2025, supporting greater regulatory consistency across Europe.

Next steps

We will:

• continue to work with stakeholders to strengthen our approach, including wider data reporting requirements and charges for all Article 18 (Green List) waste shipments
• monitor the impact of enhanced compliance checks and our compliance monitoring activities to ensure we prevent illegal exports and support legitimate business
• provide quarterly reports on tyre export statistics (first report covering April to June 2026 by 31 July 2026)