ETRMA Comments on the “Draft revised technical guidelines on the environmentally sound
management of used tyres” – Version 28-2-2011

Table of Contents: Title III.E. Environmentally sound disposal  Title III.E. Environmentally
sound management

Definitions of Terms: “Artificial turf”: replace “Tyre crumbs” by “Tyre granulates” (see also
comment on “crumb rubber”)

Definitions of Terms: “Civil engineering applications”: Replace current definition by: “Use of
whole, baled, cut, shredded, chipped end-of-life tyres for backfilling in construction projects.”

Definitions of Terms: “Crumb rubber”: definition to be deleted as the concepts “chips, cuts,
granulate, powder & shred” as described in TS 14243 already cover the main tyre derived
products. In addition, this concept is not defined at all with regard to the particle size range,
hence is not useful. To ETRMA understanding, “Crumb rubber” is a synonym of “granulates”.

Para. 44 – Table 5 – Foradehyde  Formaldehyde

Para 66 – “close loop recycling”  “closed loop recycling”

Para 84 – clumsy – change into “All other existing processes for disposing of used and waste
pneumatic tyres must be evaluated since they could generate environmental impacts and
therefore not be considered environmentally sound.”

Para 92 – to be deleted – as it is in duplicate with Para. 93

Para 93 – “Typically a recovery target for the waste tyres is specified …”  “Typically a
collection target for the waste tyres is specified in the regulation…”. Rationale: In most national
regulations, a collection target is being assigned, not a specific recovery target (energy recovery,
material recovery, …).

Para 94 – Change into “The State is then responsible for organizing a system to collect and
dispose of waste tyres …”
ETRMA Aisbl
European Tyre and Rubber Manufacturers’ Association
VAT number: BE0881 606 175
EC Register : ID 6025320863-10
2/12 Avenue des Arts
1210 Brussels Belgium
www.etrma.org
Tel +32 2 218 49 40 - Fax +32 2 218 61 62

Para 100: “The use of alternative modes of transport e.g. railways, water-ways, especially in
countries where such networks are developed is a contribution to minimize the amount of waste
pneumatic tyres. Those actions can be considered a non-generation or reduction measures in
the used and waste tyre management hierarchy.”
This cannot be stated as a general truth: the shift to other modes of transportation is not always
more favorable in terms of environmental impacts and cannot be generally considered as a nongeneration or reduction measures in the used and waste tyre management hierarchy. Only a
case by case approach based on LCAs would be acceptable with the use of the same
assumptions and functional unit and looking at different environmental compartments to
avoid shifts of environmental burdens between impact categories.
Hence we insist to reintroduce the paragraph as it was proposed in the previous version :
“The use of alternative modes of transport e.g. railways, water-ways, especially in countries
where such networks are developed should be analyzed on the basis of case specific Life Cycle
Assessment comparing the overall pro and cons of the different solutions.”

Para 161: Delete “Modern techniques can produce a char that is comparable to virgin
carbon black”. This quite general allegation is not substantiated at all by any kind of scientific
studies in the bibliography proving the performance equivalence of pyrolysis char with carbon
black used for tyre production, characterized by quite severe specifications in terms of
properties. In addition, there are tens of different carbon black grades each with specific
granulometry and properties, hence this statement is unfounded. Which “modern techniques” are
we talking about? Which pyrolysis char properties are equivalent? As it is stated, it seems to be
purely a “marketing” statement.

Para 167: “Civil engineering applications of waste tyres are addressed in standard ASTM … and
also in CEN TS14243. Works by Hyland & Schulman Table 16 show examples of these
applications”. [Add a full stop after CEN TS14243 and delete the full stop between Hyland &
Schulman and Table 16].

Para 180: crumbed rubber  rubber powder

Para 185: “The use of rubber in asphalt is highly regional based costly … “  clumsy (to be
corrected).

Para 200: 18/6  18.6

P. 56 Table 20 – Prevention & control column  check spelling & grammar