ANALYSIS OF ELT 1

Summarized Analysis of Diverse Aspects of ELT

Name

University
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1. Analysis of ELT Markets

There are three categories used to explain the diverse ways ELT can be recovered; these are

Material recovery; energy recovery and civil engineering and backfilling. For the latter tires can

be used as water retention basins in civil engineering, as tire-derived aggregates for road

construction and also as backfilling. China, US, India and Europe are the countries that recover

ELT volumes in large amounts worldwide (figure below) For Europe, data collected in this

study indicated the cumulative quantity of ELT recovered in the 13 countries (figure below). For

the European region, it amounted to approximately 25.7 and 26.1 million tons per year, with the

latter accounting for civil engineering and backfilling as the recovery root. 29.1 million tons was

the overall amount of ELT estimated to be generated amongst these countries. It is however of

vital importance that the ELT recovered per year in terms of numbers be put into an outlook

which accounts for the amount of generated ELT, this is because the recovery rate till date is

seen as the best indicator in the analysis of the performance of region-based ELT markets. This

particular study focused on two different recovery rates that were calculated based on the

consideration of civil engineering and backfilling as a recovery route or amount non-equivalent

to landfill disposal( in recovery rates not considered as the former). The distinction was

imperative as considering two ELT end- markets as a material recovery means remains

debatable.

India, China and Brazil have the highest recovery rates amongst countries accounted for in this

study. The latter, having an EPR system, has seen a continual increase in recovery rates that have

been seen to approach targets by means cement kilns delivery and granulators. Two-thirds of

recovery occurs in informal markets for India (artisanal products, fishing boats, rooftop swings)

and China, with the latter outweighing all other countries from reclaimed rubber technologies.
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With increasing numbers of the growing middle class, the recovery rates are postulated to see a

declination possibly. For Europe, materials, energy and civil engineering in 2017 were 1.9, 1.2

and 0.1 million tons respectively at 92%. Governmental regulations per country are vital for ELT

recycling worldwide as they are their driving force. Such regulations when enacted address

illegal dumping and ELT importation; historical stockpiles that affect the public health sector

and ELT collection related and non-functioning processing systems to address sanitization; all

for environmental and human protection.

Figure 1 and 2, page 12 and 13.

2. Recovery methods

Recovery products’ demand at a given time has for long been directly related to the rate of

growth and viability amongst diverse recovery markets. For instance, Tire Derived Fuel is

considered to be the most volatile, and when traditional fuels prices are low, the demand for TDF

will alternatively be weaker. Recovery requires limited processing and treatment; which embody

how energy recovery is . .In examining ELTs in the market amongst different nations, diverse

findings have been reiterated. For instance, Brazil has been seen to have high rates, this being

dependent on consumption by the cement industry; in South Korea, there is a limit of ELT

portions sent for the purpose of energy recovery they are set up to 70% and the material recovery

is less than a quarter of ELT recovered. For USA energy recovery makes up half of the ELT

market For instance, Brazil has been seen to have high rates, this being dependent on

consumption by the cement industry; in South Korea, there is a limit of ELT portions sent for the

purpose of energy recovery they are set up to 70% and the material recovery is less than a quarter

of ELT recovered. For USA energy recovery makes up half of the ELT market (especially in
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cement kilns and pulp and paper industries), moreover a quarter of ELT generated therein

becomes rubber granulate (usually costly e.g. in initial capital expenditure) that has diverse

application e.g. in sports facilities, asphalt amongst others; material recovery in particular is

prioritized in the state of California. Indeed the development of secondary and end use industries

for absorption of ELT products is imperative. In Europe material recovered takes precedence

over energy recovery, hence it is at 40%, making up close to half of the recovered ELT; policies

set up in Russia directs ELT to material recovery over energy recovery as the latter is not eligible

to meet management targets’ ELT. Japan is unique as their policies encourage the use of TDF as

elucidated in the country’s energy policy (exempting reduction and objectives), ELT thus mostly

becomes TDF in paper manufacturing boiler industries. Reclaim rubber production is

predominant in the Asian continent. Whereas recovery methods in pyrolysis and gasification are

consequential in Indonesia, Japan and Thailand, US has just developed pilot plant, contrastingly

US has seen significant growth of application of ELT in civil engineering and backfilling (10%

of ELT marker over the past decade). Even with the success of these two types of recovery

methods, challenges in the area of commercialization of products and operational risk exist and

indeed must be addressed.

3. Regulations

Government intervention can be limited to formation of an ELT stakeholder’s organization or

can be interventionist in its financial and technological capacity development within the sector,

either way it is of crucial importance to properly develop the ELT recycling industry. Financial

support plays a vital role in ELT management systems as it is a factor that enables an increased

competitiveness of an industry for it to achieve high recovery rates. Three major systems have

been identified within the scope of this study, these are: the EPR system (common in European
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countries); the free market system (Denmark, Croatia and Slovakia) and government

responsibility financed by means of tax (adopted by many countries spread out globally). The

unique factors in these three types of system are accounted in the differences that arise on: the

responsible actors, governors, findings and key features (table 2, pg 15). Organizations within

the ELT are formed by tire manufacturers and the common feature that exists between an EPR

and free marker system is that legal regulations are present and they are the basis through which

their activities are guided. Whereas the fees usage may vary through the different systems in

place, the eco-fees and fees charged on the consumers and manufactures is used in ensuring CSR

and further advancing the development of the system in place, through its divided sectors. A

long term vision of this industry is to discover new or existing markets for recycling ELT in

order to prioritize high-value products and encourage industrial sufficient through revenue

returns. Stockpiling is common due to low environmental awareness, burning of ELT and its

commercialization in the black market has also been seen as an emerging problem; this can be

addressed by policy makers who should make the general public aware and implement favorable

policy based on the same. Developing country(lack technology, expertise, recycling

capabilities), they should emulate the more experience actors from developed countries to gain

success status in the ELT market.

4. Best practices

There is no one specific way or approach that can be taken up to properly fit a ELT management

system that is well functioning. Each country or even continents have unique management

systems. Take for instance, Europe their systems include: free market, tax based and EPR

systems, as such recovery rates therein are high. The main indicator on how successful a system

performs is always the recovery rate, this related to the total ELT produced. Hence to identify
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best practices a focus on countries having high recovery rates is necessary, some of the

contributing elements to best practices include: Trade associations which ensure the success of

ELT, evidence has shown that large associations mandated to manage ELT as cooperative

organizations (E.g. Reciclanip in Brazil and EcoTyresUnion in Russia) has shown continual

success. Another best practice involves the use of government and non-government agencies

which will take up responsibilities of managing solid waste or possibly ELT. This EPR system

has been adopted in Brazil and South Korea, where government agencies namely IBAMA and

Ministry of Environment, respectively; whereas their guidelines, rules and frameworks may

differ and have independent uniqueness, their main goals remains to increase both the amount

and degree in terms of product recovery and minimize to the very least the impact of waste to the

environment by coming up with legislative policies. Of importance to note is that, different

countries that have adopted EPR systems have their own unique ways of mandatory recovery

quantities. Tax based systems are also prevalent in countries like South Korea, Brazil, and South

Africa through charging fees based on a particular criteria(e.g importation) or employing

punitive fines amongst other ways. This is advantageous as the cumulative funds are used for

R&D, used as start-ups to fund and promote recovery and assist in developing secondary

industry (South Africa). Free markets are present in countries like US, UK and Japan and with

unique policies in place waste regulations and provision of high recovery rates are given priority.

Government intervention is allowed in free market systems as seen in countries like US where

grants and funds are provided to aid in recovery; EPR systems also have funding schemes

(Brazil). Informal markets of India and Indonesia have shown high recovery rates owing to the

many number of treatment facilities and independent collectors.

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With the advantage of EPR system, countries like Thailand, Nigeria, Mexico and Nigeria that

have low recovery rates have expressed interest in shifting to this system from the free market

system they had adopted. Ireland recently adopted this change in 2017 and South Korea, is well

on its way to this once its markets become established. To have a successful ELT management

system hubs will need to be established between collection, processing and the organization of

delivery in direct relation to processing if distance is proximal; this will ensure success to free

market countries in the management systems.

5.) Environmental impact

Numerous studies done in the past regarding ELT granulate has aimed to shed light mostly on

how human health are at risk from the exposure on article sports fields, specifically for those in

USA and in European countries. Other individual studies have however researched different

methods of recovery in other parts of the world. Additionally, innumerable studies related to use

of granulate in turf fields have been done. Due to the multiple variables in play and narrow

scope, there has been uncertainty with regard to the potential impacts , no consensus has been

decided upon regarding this.

Some of these studies include those done by ECHA, in February 2017 and that conducted by the

French research institution (ANSES) in September 2018 on risk of exposure to granulate in

synthetic turf sport fields and rubber infill which both concluded that the levels of exposure to

granulate separately was low thus inherently negligible to human health. However, the latter

found that an environmental risk was present through zinc and phenol transfer and advised for

additional measures to be done in evaluating methodologies and risk assessment. To reduce the

risk of impacting human health, ECHAs’ risk assessment and socio-economic analyses
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committee adopted and drafted opinions which were in support of a restriction proposal of not

placing granules and mulches in Netherland markets, if the sum if the sum of polycyclic aromatic

hydrocarbons were calculated and gotten to be greater than 20mg/K.

ETRMA in 2016 released a statement on the safety of rubber infill material that is recycled.

Rubber components that would possibly come to contact with the general public were regulated

under EU restrictions. From the 70 scientific articles published at the time the association

conclusively stated that there was scientific or other significant risk that was associated with

using rubber granules derived from end of life tires. Additional studies by IRCC found that

restrictions covered by REACH regulations were at lower limit levels than that for the general

public. ETRMA with the involvement of ERASSTRI that has 28 partners from 14 European

countries came together under REACH to conduct studies on use ELT derived materials and

applications therein possible health effects and concerns to human health, this findings are yet to

be published halfway through 2020.

6.) Technologies

Diverse trends in this field of research have been observed and some are specific to different

countries, especially in the area of advanced ELT technologies and innovation. Material recovery

based research project are the main ones identified in this. Many research institutes and projects

have put a major focus on pyrolysis development (USA, Russia, China, South Africa) as a

recovery method and the products they generate. Regulation wise a significant content of

pyrolysis derived products are classified as TDF, hence waste management policies apply here;

there is no regulation in informal sectors where recovery routes are common; grants are also

provided to further R&D of innovative substances. The IP protection limits also competition in
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innovation done in this field. In terms of technical feasibility, more trials and plant projects have

been set up in different parts of the globe with the aim of eventually going commercial, R&D on

high quality carbon and output products significant in both pre and post processing procedures

are required. Whereas efficient technology of producing high output is not far-reaching, the

aforementioned steps will help it be more widespread, e.g in oil production as TDF in parts of

Asia. Products of pyrolysis (low added value, high production cost) have potential for

applications in a variety of applications but their economic viability is relatively low due to

competition in relation to traditional materials already in the market. Unsatisfactory standards of

widespread informal operations and large scale use of technology that is less advanced, its

sustainable performance is low. As such using advanced technology such as high quality oil;

accelerated pyrolysis forms; low emission pyrolysis and carbon black will ensure its

sustainability. The capacity of ELT granulate to absorb substance in wastewater and oil from

spills is another technology researched upon in countries like Nigeria, USA, Thailand, Brazil

amongst others; at different ways and capacities. A number of policy measures (though few)

consider priority recovery rate over energy recovery and general guidelines have been set up to

promote application deemed to be high in potential. The granulation process is well set up but

some of its application is a challenge in terms of technical difficulties due to advanced

technology. Barriers such as insufficient funds to invest in high volumes and quality technology

in ELT systems, prevents small companies from thriving in some countries. Advanced treatment

and processing stages means that granulation and applications therein need more investment;

whereas markets of granulation application had fallen in the recent years, innovative

technologies has enabled opening up of new markets for the products in this line. Regarding

sustainability considerations, it is considered as material recovery and thus its hierarchical

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placement is high in waste management systems; its predominantly well perceived by the public

domain, save from Artificial tuff which was thought to have health and environment ; effects, but

this notion was dispelled after through scientific research studies. For cement production and

other energy recovery technologies, indirect policies have been set up to promote TDF use,

however policy that promotes material recovery is the norm, hence regulation policies may not

be favored in this context. Large corporations require permit procedures, but once this hurdle is

tackled it is easy for long term feasibility to be in place. This technology is technically feasible as

power plants and cement kilns have the capacity to treat ELT stockpiles in the long term; power

plants however prefer shredded tires to whole tires due to enhanced facility dosage. ELT

materials are considered to have relative stability although more improvements are needed.

Economically, there are factors that influence the use of ELT in cement kilns, these include: gate

fees ( gives a positive overall outlook) and high pricing of traditional fuels. Even with the

competition they face from alternative fuels, their high calorific value gives them a competitive

edge in the market. Improved infrastructure through investment and adaptation is however

required. With regards to sustainability, industries have shown the capability of being able to

switch from fossil fuel to ELT, to aid in reduction of GHG and other emitted pollutants; use of

TDF has also aided in reduction of harmful emissions and enabled compliance with

environmental regulations. Crucial to note is the negative perception people have heard

especially in regions having well established ELT management systems. Cement kiln shows

exception over other recovery route however had aided in reduction of CO 2, which beneficial to

the environment.

7.) Comparison in ELT management between China, Europe, and USA summary

ELT MNGT CHINA EUROPE USA

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DETAILS

Legal system No structured Various systems ELT are regulated per

management system, present based on states, state through federal
possibly policy EPR systems, free program, Subsidies
development from markets & government and potential grants
environmental responsibility financed available for ELT
considerations through taxation

Legislation/Policy None save from Ireland shifting from a No policy change, no

change(from 2016) environmental free market to EPR shift expected at a
restrictions by the national level
government to curb
non-compliance

Main ELT mngt org. CTRA &CRIA ETRMA at EU level, USTMA, representing
physical systems per tire manufactures
state

Main ELT recovery Material recovery Rubber, granulates and 39% ELT for energy
methods, products majorly, with powder at 43% recovery, 33.2 to
&application(% of granulation and material recovery;
total ELT) reclaimed rubber as with granulation as
main recovery routes; main route of
ELT considered a Cement Kiln at 38% recovery, 8% towards
resource civil engineering

Health& Env.Impact Pyrolysis air pollution Research by ANSES, Inconclusive results

awareness; Perceived ECHA & EU chemical on the impact of
potential risk of rubber agencies gave an synthetic turf
powder discussions overview on impact especially to human
health & environmental health over the past
from exposure 15 years).

Tech Innovations Low emission Project on efficient A focus on material

pyrolysis used in pyrolysis, ELT usage in and energy e.g
construction asphalt, low noise micronized rubber
surface, incorporation powder &pyrolysis
of ELT granulates in
plastics
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Opportunities Govt policies focusing Cost reduction, image ELT management

&Drivers on environmental branding, reputation, methods state wise,
issues, legislative circular economic Regulations’
change pushed by strategy influence on smooth
organizations , ELT market development.
considered a resource

Barriers & Tire manufacturers are Innovation constrains, Well established and
challenges small scale and family alleged risks in health, efficient ELT system,
owned, ELT as rubber raw material pricing Active research on
resource limits use in new technologies
some recovery routes

8. Conclusion of the SOK Phase

The older a system is the better the performance it will have on this spectrum, hence ELT

management systems are directly related to existence or absence of a system or the level of

maturity therein. The data on ELT management practices in diverse countries, in terms of:

production rates and recovery rates in metric tons; market analysis; impact of governmental

support in provision of a legal framework, technological advancement and its application, in this

report is able to further elucidate the distribution of ELT across recovery methods, applications

and products thus showing its unique impact on a global level.

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