WORLD TRADE  
ORGANIZATION  WT/CTE/W/241 
12 July 2005 
 
 (05-3090) 
Committee on Trade and Environment Original:   English 
  
 
TRADE IN USED AND RETREADED TYRES 
 
Submission by Brazil
 
  
 The following communication, dated 7 July 2005,  is being circulated at the request of the 
Delegation of Brazil
. 
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1. Tyres are not ordinary products.  They are ir replaceable goods in the automobile industry and 
perform an essential role in transport activities all over the world.  Designed to be both durable and 
robust, tyres contain highly combustible and pollu tant materials and generate large quantities of 
wastes at the end of their life cycle.  Due to th e volumes and special characteristics of waste tyres, 
their management is an extremely difficult task to carry out.  Waste tyres disposed in landfills last 
hundreds of years before disappearing in the environmen t.  Tyre fires or their incineration in cement 
kilns release toxic gases and contaminate soil, water and the air.  The treatment of this sort of wastes 
is expensive, involves environmental risks a nd does not guarantee their total elimination.  
2. The waste tyres stream also represents a majo r concern regarding public health.  Trade of 
tyres, especially of used tyres, is responsible for the spreading of viral diseases around the world.  
Moreover, tyres discarded in the environment ar e ideal breeding places for mosquitoes transmitting 
diseases such as dengue and yellow fever.  Other ri sks to human health derive from air and soil 
contamination resulting from the huge fires that  frequently occur where tyres are stockpiled. 
3. Waste tyres are considered a most problematic w aste stream:  they are difficult to collect, for 
economic, geographic and cultural reasons;  they are risky to transport, due to the possibility of 
occurrence of environmental accidents;  they are cos tly to deposit, due to their huge volumes;  they 
are arduous to recycle, due to technical peculiaritie s related to the process of devulcanization;  and 
they are hard to dispose of.  Estimates show that al most 1 billion tyres reach the end of their life cycle 
every year in the world.  The corresponding figur es for the European Union and the United States are 
around 300 million tyres each.  These impressive numbers are in themselves an indication that the waste tyres stream is an environmental problem of worldwide scale.  
4. Given that tyres are irreplaceable goods, however , rational and efficient waste management 
schemes are required to diminish the harmful effects of the ever-growing generation of waste tyres on 
the environment and human health.  In light of the difficulties relating to the disposal of waste tyres, 
the priority in the context of any waste management programme shall be given to measures aiming at avoiding the generation of extra amounts of wastes.   In this context, many WTO Members have 
adopted restrictive measures as a way to prevent im ports of used and retreaded tyres so as to avoid 
premature generation of wastes in their territories. 
5. Brazil has adopted a series of measures to a ddress the problems resulting from the increasing 
generation of waste tyres in its territory.  Some  of these measures were adopted (a) to prohibit 
landfilling and burning of used tyres;  (b) to attach  responsibility to producers and importers of tyres WT/CTE/W/241 
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 for the collection and disposal of these products when they reach the end of their life cycle;  (c) to 
define and monitor the environmentally sound options  for disposal of waste tyres;  (d) to require 
compulsory environmental licensing for companies dedicated to the disposal of waste tyres;  (e) to discipline the use of waste tyres co-processing t echnologies in cement production;  (f) to control 
emissions in industrial plants co-processing waste tyr es;  (g) to establish as administrative infractions 
the importation itself and the trade, transport, storag e, guard or deposit of imported used or retreaded 
tyres;  (h) to create pecuniary sanctions to punish environmental administrative infractions.  
Moreover, in accordance with the widely accepted pr inciple of sustainable development, and taking 
into consideration that used tyres are de prompto  waste and that retreaded tyres are shorter lifespan 
products, Brazil banned imports of  used and retreaded tyres. 
6. Brazil is aware that policies and regulations adopted by some countries as part of their waste 
management schemes may impact negatively on the efforts made by other countries to implement 
sound management practices regarding waste tyres.  Several developed countries, for instance, seem 
to stimulate exports of used and retreaded tyres as a manner of reducing the volumes of scrap tyres 
generated in their territories.  It is common to find  in statistics, together with alternatives such as 
recycling, energy recovery or la ndfilling, references to exports of used and retreaded tyres as valid 
options for disposal of waste tyres. 
7. In Brazil’s view, the international trade of  used and retreaded tyres introduces a new 
perspective to the problem of waste tyre manageme nt.  While imported used tyres are in many cases 
discarded immediately after entrance in the territo ry of the importing country, retreaded tyres are 
discarded shortly after that.  It is evident, thus, th at used and retreaded tyres generate wastes sooner 
than new tyres do and, therefore, imports of su ch products clearly aggravate the environmental 
problems in the importing countries. 
8. The efforts made by the European Communities to address its waste tyre stream problems 
illustrates what Brazil is concerned about.  From  1999 on, three different Directives adopted by the 
European Communities deserve mention for their imp lication in the management of the waste tyre 
stream:  (a) the Landfill Directive;  (b) the End of Life Vehicle Directive;  and (c) the Waste 
Incineration Directive. 
9. While they are not the exclusive focus of the Landfill Directive (Council Directive 
1999/31/EC), tyres are the only product specifically me ntioned in that rule and is the one that has 
been most severely impacted upon by the cited re gulation.  The many disadvantages of landfilling do 
not really recommend it as a sound option for disposal of waste tyres.  Therefore, as of 2006, whole, 
cut or shredded tyres will be totally banned from landfills within the European Communities.  The 
immediate consequence of the implementation of the Landfill Directive is crystal clear:  the member States will have to find another destina tion for around 30% of the tyres discarded every year 
in the European Communities. 
10. According to the End of Life Vehicle Direc tive (European Parliament and Council Directive 
2000/53/EC), all European Union member States will be required to ensure that the reuse or recovery 
rate for this waste stream be raised to 85% by Ja nuary 2006 and up to 95% by January 2015.  Experts 
calculate that the implementation of the End of Li fe Directive will cause to return to the market 
around 300,000 tonnes of waste tyres which are current ly send to landfills by vehicle dismantlers and 
shredders. 
11. The Waste Incineration Directive (European Pa rliament and Council Directive 2000/76/EC), 
in turn, establishes emission limit standards for plants incinerating wastes within the 
European Communities.  The intent of the Direct ive is to prevent or limit as far as practicable 
emissions into air, soil, surface and ground water resulting from incineration activities.  There are  WT/CTE/W/241 
 Page 3 
 
 
 estimates pointing out that slightly more than 100,000 tonnes of waste tyres will be affected by the 
implementation of the Waste Incineration Directive, returning to the market. 
12. Brazil understands the efforts made by the Eu ropean Communities to address the extremely 
serious problems posed by the accumulation of waste ty res in the territories of its member States.  
Nevertheless, Brazil considers that each country sh all bear the burden of disposing of the wastes 
generated in its territory.  The implementation of  the referred Community Directives will certainly 
cause the return to the market of large quantities of waste tyres that are currently sent to landfills or 
incinerated in cement kilns.  This situation is  likely to increase pressures for new markets for the 
European Communities locally generated or produced  used and retreaded tyres.  Consumers all over 
the world tend to see used tyres an d retreaded tyres as low quality products.  European consumers, in 
particular, clearly prefer new tyres to the used and retreaded tyres.  Therefore, the 
European Communities will need to search for consumers of its shor ter lifespan products outside its 
territory.  In Brazil's view, exports of used and retr eaded tyres correspond, in practice, to a transfer to 
other countries – mainly developing countries – of the social, economic and environmental burden of 
disposing of the wastes generated by these products. 
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