ELT Management: Regulatory Mis-steps, Mistakes, Makeovers
Presented to the Tyre Industry Summit 2015 by Glenn Maidment, President of the Tire and Rubber Association of Canada
Top 10 Elements Which Should Not be in a End-of-Life Tyre Regulation:
- Tyre Eco Fee Amount
- Probhibition of Eco Fee Visibility
- A restricted definition of “Producer”
- A listing of tyre categories captured by Regs
- A requirement for “Design for Environment”
- Gov’t. appointment to an industry board
- Arbitrary restrictions on viable market opportunities
- A requirement for Producers to pay tyre retailers a handling allowance
- A requirement for a detailed Stewardship Plan
- Creation of a Gov’t Oversight Body
Top 10 Elements Which Should be in a End-of-Life Tyre Regulation
- Demand Outcomes i.e. diversion & accessibility targets
- Allow Producers to Discharge Obligations via Contract with Service Providers
- Allow Producers to Join a Collective
- Require Annual 3rd Party Audited Reports
- Encourage Gov’t to support green procurement
- Gov’t. must provide enforcement provisions
- Demand clean-up of existing scrap tyre piles
- Prohibit tyre retailer charging consumer a fee to dispose of their old tyres
- Require a responsibility for public education
- A generic definition of tyre types captured under Regulation
