End-of-Life Tyres: What You Need Before Applying for a Permit (Expert Guide for Waste Operators)
Hart's Waste Consultancy
End-of-Life Tyre Environmental Permit Requirements for Waste Sites
Managing end-of-life tyres (ELTs) is one of the more tightly controlled activities in the waste sector. The risks are well-known: fire, stockpile collapse, arson, environmental harm, and commercial operators entering the market without suitable controls. As a result, the Environment Agency (EA) places a heavy emphasis on robust management systems, site design, fire prevention controls and technical competence long before a permit can be issued.
With 24 years in the waste industry and extensive experience preparing permit applications, this guide sets out exactly what operators need to know before applying — and what the EA expects to see before they will even consider granting permission.
This article is purposely written in a practical, straight-talking way for operators, recyclers, hauliers, and new entrants to the tyre sector.
1. Understanding the Regulatory Scope for End-of-Life Tyres
End-of-life tyres are regulated as non-hazardous waste, but the regime surrounding them is far more restrictive than most non-hazardous streams due to two primary risks:
Fire
Stockpile instability and abandonment
The EA regulates tyres through:
Environmental Permitting Regulations (EPR) 2016
Fire Prevention Plans (FPP) Guidance
Specific waste codes related to tyres
16 01 03 – End-of-life tyres
Control of major accident hazards (COMAH) thresholds, where applicable
Duty of care and storage limits
Most tyre operations will require a bespoke environmental permit rather than a Standard Rules Permit because ELTs typically breach SRP limits or require treatment not covered under standard rules.
If you intend to:
Store tyres
Shred tyres
Treat tyres mechanically
Bale tyres
Export tyres
Produce shred, chips, or crumb rubber
…then a permit will be required.
Operators who underestimate the regulatory load associated with tyres are very unlikely to progress through permitting smoothly.
2. Common Activities Involving End-of-Life Tyres
Most tyre businesses fall into one or more of the following categories:
2.1. Storage Only
Tyres are stored before onward transport to recovery or recycling.
Permits limit:
Maximum tonnage stored
Stack height
Stack footprint
Separation distances
Fire compartments
Even a “storage only” operation requires a full Fire Prevention Plan.
2.2. Mechanical Shredding
Includes shredding whole tyres into:
150mm shred
50mm shred
PAS 107 specification products
Mechanical treatment increases fire risks and therefore requires detailed engineering controls, ATEX consideration and strict maintenance systems.
2.3. Baling or Processing
Required for export or commercial resale.
Baling has caused some of the most serious tyre site fires in the UK due to inadequate separation and overstocking.
2.4. Mobile Plant Tyre Shredding
Requires a mobile plant permit registered by an operator with a fixed base, including waste acceptance and tracking systems.
If your site does any combination of storage and treatment, the EA expects a high level of management sophistication.
3. What the EA Looks for Before They Approve Tyre Sites
End-of-life tyre permits attract heavy scrutiny. Inspectors will typically assess:
3.1. Technical Competence (TCM Requirements)
Operators must demonstrate:
A suitable TCM with relevant WAMITAB units
Continuous cover (not a TCM “on paper”)
A CPD plan
The EA views tyre sites as higher risk, so they expect technical leadership to be robust and demonstrable.
3.2. Fit and Proper Person Test
The EA will consider:
Past compliance history
Financial competence
Criminal convictions
Previous site abandonment
Insolvency events
Tyre operations have historically been associated with rogue operators, so the EA’s tolerance for risk is extremely low.
3.3. Fire Prevention Plan (FPP)
No tyre permit will be granted without an FPP fully accepted by the EA.
Your FPP must demonstrate:
Maximum storage tonnage
Stack dimensions
6m separation distances
Site layout
Ignition source control
Quarantine areas
Firewater containment
Access for emergency services
Stock rotation strategy
Maximum dwell time
Tyre-related fires are notoriously difficult to extinguish, and many have burned for days or weeks, causing millions in damages. This is why the EA scrutinises the FPP more aggressively than any other part of the application.
3.4. Waste Acceptance Procedures
Before tyres arrive on site, operators must have:
Inspection procedures
Load rejection criteria
Controls against contamination
Acceptance documentation
Tracking and storage location systems
Tyres often arrive mixed with:
Rims
Rubber strip
Metal wire
Plastics
General waste
Contamination causes fires, sparks, and equipment hazards.
3.5. Firewater and Pollution Risk
Your application must include:
Pollution inventory
Secondary containment
Surface water protection
Drainage plan
Accident management procedures
The EA will reject applications that cannot demonstrate secure control of firewater run-off.
4. Site Design: The Foundation of a Successful Permit Application
Tyre sites must be designed with:
4.1. Clear traffic flow
Separate pedestrian and vehicle routes, turning areas for HGVs, and clear signage.
4.2. Adequate surface infrastructure
Concrete surfaces free from cracks and potholes are essential for fire control and drainage integrity.
4.3. Sufficient space for stack separation
Operators regularly underestimate how much space 500 tonnes of tyres requires.
4.4. Security
High fencing, anti-arson measures, and CCTV. Tyre sites are frequent targets of arson.
4.5. Power supply
Mechanical shredders have high load demands.
A common reason applications fail is that the operator tries to make the site fit the permit, instead of designing a permit that fits the site.
5. Management System Requirements
Your management system (MS) should demonstrate:
Training and competency
Daily inspections
Tyre rotation and stock tracking
Housekeeping checks
Maintenance records
At least one named senior manager responsible for environmental performance
TCM involvement and oversight
The EA expects management systems to be site-specific, not generic templates.
6. Demonstrating Financial Competence
Operators must prove they can:
Manage site operations
Fund fire prevention measures
Maintain shredding machinery
Cover clean-up costs if stockpiles must be removed
Abandoned tyre sites are one of the largest financial liabilities in the waste sector.
Expect the EA to scrutinise your financial modelling and contingency costs.
7. Maximum Storage Capacity and Throughput
You must define:
Maximum storage on site
Maximum operational stock
Annual throughput
Retention and dwell time
The EA will assess whether your stated throughput is realistic when compared to:
Shredder capacity
Staffing
Operating hours
Export markets
Site size
If you cannot demonstrate that tyres will not accumulate, your application will be refused.
8. Common Reasons Tyre Permit Applications Are Rejected
After supporting operators through many tyre permit applications, these are the most frequent reasons for regulator refusal:
❌ FPP not acceptable
❌ Stockpiles too large
❌ Inadequate site drainage
❌ Lack of genuine TCM involvement
❌ Unrealistic throughput claims
❌ History of poor compliance
❌ Inadequate financial evidence
❌ No demonstrable storage rotation strategy
❌ Sub-standard infrastructure (gravel yards, broken concrete)
Tyre permits are awarded only to operators who can clearly demonstrate control and stability.
9. Preparing a Successful Application: What Operators Should Do
Step 1 – Commission a Feasibility Assessment
Identify:
Whether the site is suitable
What infrastructure is missing
Compliance gaps
Step 2 – Prepare detailed site drawings
Including stack layout, drainage, fire access, quarantine area.
Step 3 – Develop a robust Fire Prevention Plan
Expect several rounds of EA feedback.
Step 4 – Create a site-specific EMS
Housekeeping, acceptance, training, maintenance, and contingency controls.
Step 5 – Outline your TCM structure
Demonstrate continuous and effective management.
Step 6 – Engage with the local Fire & Rescue Service
Their comments can strengthen your FPP.
Step 7 – Submit a high-quality permit application
Include everything the EA expects up front.
Step 8 – Maintain compliance from day one
Permit conditions are legally binding the moment the permit is issued.
10. What a Good Tyre Site Looks Like (From a Compliance Perspective)
A compliant facility has:
Hardstanding
Clearly marked stacks
6m separation
Good drainage
No vegetation
Daily inspection logs
A high level of housekeeping
Competent staff
Controlled access
CCTV and security measures
Shredder maintenance logs
A safe loading/unloading system
Good sites look organised.
Bad tyre sites look cluttered, chaotic, and unstable — and the EA can spot the difference instantly.
11. Final Thoughts: Should You Enter the Tyre Sector?
Tyre recycling is a growing industry with strong demand for:
Shred
Crumb
Reuse
Export
Civil engineering applications
However, it is also a sector with:
High regulatory scrutiny
Serious fire risks
High equipment costs
Strict compliance expectations
If you cannot demonstrate operational discipline, this is not the area to cut your teeth in.
But for operators who invest properly, demonstrate competence, and maintain control, tyre recycling can be a profitable and future-proof waste stream.
Need Support With a Tyre Permit?
I support operators with:
Feasibility assessments
Environmental permit applications
Fire Prevention Plans
Site layout design
EMS development
TCM oversight
Pre-application EA engagement
If you want your tyre permit to progress smoothly, professional preparation is essential.
What Documents Should Be On-Site During an Environment Agency Visit?
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