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Key departmental publications, e.g. annual reports, budget papers and program guidelines are available in our online archive.

Much of the material listed on these archived web pages has been superseded, or served a particular purpose at a particular time. It may contain references to activities or policies that have no current application. Many archived documents may link to web pages that have moved or no longer exist, or may refer to other documents that are no longer available.

A National Approach to Waste Tyres

Commonwealth Department of Environment, 2001

3 Waste Avoidance

3.1 The opportunity

At the top of the waste management hierarchy is waste avoidance. In regard to tyres, waste avoidance means achieving a reduction in the rate at which waste tyres are generated within Australia.

Waste avoidance, in the case of tyres, is the responsibility of both the tyre producer (manufacturer or importer) and the consumer. The role of producers is firstly to develop tyres that have longer lives, and this can be considered to refer to both the life of the tread and the potential for the casing to be used as a retread. It must be pointed out that the Australian market for tyres is small in comparison with the world market, and that tyre producers in Australia are generally offshoots from large international enterprises. Under these circumstances, it is unrealistic to expect major advances in tyre technology to occur in Australia, though certain manufacturers claim their tyres are ‘designed for Australian conditions’.

A more promising area for tyre producers to contribute to waste tyre avoidance is through the provision of information to consumers, and this leads naturally to considerations of decisions made by vehicle owners. The major opportunities to reduce the rate at which waste tyres are generated relate to changes in consumer behaviour. A narrow definition of the term consumer behaviour would be restricted to the purchase of tyres. However, for the purpose of this study the definition of the consumer will be taken to include the role as vehicle owner/operator, and to extend the use of the term behaviour to actions during the life of the tyre, such as tyre maintenance and driving behaviour.

Decisions by consumers that influence the waste tyre generation rate at the point of purchase include:

Decisions by consumers that influence the waste tyre generation rate during the life of the tyre include:

Clearly, not all of the above decisions are subject to influence by programs and policies that aim to reduce the rate of waste tyre generation. In particular, the last two bullet points will not be addressed in this report, since these matters are the subject of other, broader programs (targeted at road congestion, safety and environmental impacts mainly air emissions) that are likely to be more successful in achieving change in driver behaviour. However, it must be acknowledged that programs to reduce vehicle usage have not been very effective in the past and there do not seem strong prospects for improvements in the future55. In fact, vehicle-kilometres has outstripped the growth in population. For the purpose of projecting vehicle usage trends into the future, no significant reduction in distance travelled has been assumed in the analysis conducted for this study.

Of the other decisions listed above, information provided by tyre producers (in concert with tyre dealers) can certainly be expected to provide a sounder basis for the choice of tyre purchased in terms of expected life. Producers and dealers could also contribute (possibly in cash but certainly in kind) to programs to promote better tyre maintenance.

Also, increased use of retreads can reduce the rate of generation of waste tyres. The retreading process is much less resource intensive than is the production of new tyres. While retreading does not keep a tyre out of landfill in the long term, by deferring the time of disposal retreading slows the waste generation rate and reduces the need for new tyres to be manufactured.

3.2 Impediments

3.2.1 Purchase decisions

It would be expected that a rational consumer would choose the tyre that offered the best bundle of attributes: roadholding performance, noise and comfort against cost. Cost in this case is the expected cost of the tyre over its life. However, it has been frequently observed that consumers have a high effective discount rate when assessing purchases of long-lived products (such as energy efficient lighting), and commonly demand a ‘payback period’ of the order of one to two years for the additional cost. In the case of tyres, this problem is exacerbated since, if the vehicle is disposed within the life of the tyre, the increase in the residual value from a superior tyre is largely lost. In particular, owners of older vehicles are often loath to fit expensive tyres, regardless of the projected cost per kilometre.

Also, there is little hard factual information provided by tyre manufacturers or tyre dealers to assist consumers. For fleet operators it is worthwhile to spend resources on careful evaluation of available tyres that best suit their needs, because the costs (and resulting benefits) for obtaining the required information are spread over a large number of tyres. Again, fleet owners will have considerable experience (based on detailed records) of past tyre performance. For individuals, who may only buy tyres once every few years, such information is not available, and they have to rely on a mixture of advice from friends and advertising by the tyre industry.

The consequence of this is that purchase decisions by many (perhaps the majority of) private buyers are dominated by the purchase price of tyres and appear to pay little or no attention to the expected tyre life. Yet tyre industry members indicate that choosing better quality tyres generally provides better value notwithstanding the higher purchase price.

The value-for-money problem is reversed for retreads. Tyre retailers tell us that many customers reject retreads as poor value-for-money or as unsafe, even though the price of the retread might be significantly less than the price of the cheapest new tyre and the customer is otherwise keen to buy cheaply. A survey undertaken by the National Roads and Motorists Association56 found that only 4 per cent of motorists said that they would choose retreads when replacing tyres.

While official data are lacking, the limited evidence suggests that the market for passenger vehicle retreads is in steady and significant decline. The NSW Environment Protection Authority57 estimated that market share of passenger vehicle retreads was about 40 per cent in the 1970s (based on a retreading rate of 65 per cent), 27 per cent in the early 1990s, and around 20 per cent in the mid 1990s. It may now be as low as 10%. The pressure on the retread industry is also reflected in reports of severe competition between suppliers of passenger vehicle retreads at the present time. This contrasts with the increasing market share of truck retreads. Why the difference?

Tyre dealers and retreaders have largely blamed the falling supply of retreadable casings for the loss of business:

However, if this last-named situation were the case, then the price of retreadable casings would have risen to reflect the scarcity, but there is no strong evidence that this has occurred. A greater problem facing retreaders may be that they produce a largely undifferentiated product. Although the Standard for retreads requires the name of the retreader to be placed on the sidewall there is no ‘brand’ awareness amongst the general public.

3.2.2 Tyre maintenance

Members of the tyre industry have consistently nominated tyre maintenance as the key determinant of the durability of tyres. Further, poor maintenance can damage tyres to the point where they cannot be retreaded.

In the case of tyre maintenance, it is clearly in the interests of the vehicle owner to strive to maximise the life of tyres fitted to the vehicle. The costs, in time and money, of proper tyre maintenance are very modest, involving only regular tyre pressure checks and visual inspection. Maintenance of vehicle components is more expensive but has safety and comfort benefits. Yet there is abundant evidence that tyre maintenance receives inadequate attention on the part of many vehicle owners.

One problem is that tyres constitute only a small component (perhaps 3-4%) of the total cost of a vehicle. Unlike fuel, tyres only need to be purchased at infrequent intervals (on average a tyre has a life of three years). The vehicle owner is not confronted on an ongoing basis with the increased costs resulting from poor tyre maintenance practices. There is no strong feedback loop from changes in behaviour to effects of longer tyre life.

The quality of tyre maintenance is reported to have declined steadily over the last 10 to 15 years and some of the blame has been placed on the growth of self-service petrol stations. Many stations have only one air hose and it is not always handy to the refuelling aisles. The quality of the air hoses is also variable: the gauges may be inaccurate or unreadable; motorists are often frustrated by a leaky seal between tyre valve and air nozzle. One option to consider is for tyre dealers to include pocket air pressure gauges with the purchase of new tyres (or discounts for vehicle owners that have a gauge in their car).

3.2.3 Importation of used tyres

Under the heading of waste avoidance is an additional ‘impediment’ that is not concerned with consumer behaviour, but relates to the importation of used tyres. Truck tyre casings are imported to augment the local supply for retreading. On the other hand, surveys have found repeatedly that a large proportion of used passenger tyre imports do not meet Australian safety requirements and are unsuitable for retreading. These tyres are disposed immediately on landing in Australia; they add to the waste management burden without providing economic benefits from use.

3.3 Options for waste avoidance

3.3.1 Option 1: Purchase decisions

In respect of tyre purchase decisions, it is true that vehicle owners can only make choices from the range of tyre models available and based on information that they can access. To derive significant waste avoidance from changes in purchase decisions, it is necessary that consumers have the right type of information. But it is likely that the tyre industry will only provide this information if there is a strong demand for it by consumers or the provision of information is mandated by law.

To confront the image problem for retreads requires, in the first place, some program to promote the value for money of retreads. The Tire Retreading Information Bureau (TRIB) funded by members of the retread industry in the US provides a model. TRIB provides point of sale materials - posters, videos, brochures, fact sheets explaining that retreads are commonly used by transport professionals, such as on taxis, aircraft, racing cars, trucks and school buses. The TRIB also reports on studies on tyre debris alongside highways, which is commonly interpreted as the result of retread failure58.

The other type of program is to provide for product differentiation for retreads. Concurrent with this program, if there are enterprises that are known to be producing defective or seriously inferior retreads, then pressure should be brought to bear on them to improve quality or leave the industry.

Options to improve the management of the supply of casings for retreading will be dealt with in section Part II.5.4.3.

3.3.2 Option 2: Tyre maintenance

Programs to improve the awareness of vehicle owners in regard to the importance and benefits of proper tyre maintenance can take one of two forms. The first form is direct contact with vehicle owners in car parks or public places. The form of such activities could be modelled on a survey undertaken by the NRMA in 1993 on tyre maintenance or free inspections of emissions equipment under the NRMA's Clean Air 2000 activities that commenced in 1997. The second form is a more conventional mass media appeal to the public promoting the direct financial, safety and wider community benefits from correct tyre maintenance.

3.3.3 Option 3: Importation of used tyres

Two direct options can be considered to address problems associated with the import of used tyres:

A third option is to impose a levy on imports of used (and new) tyres, as discussed in Part II.7, which by raising the effective landed costs would discourage imports of tyres which are in fact waste tyres with little or no further use as tyres.

3.4 Assessment

3.4.1 Option 1: Purchase decisions

The discussion will use as a model the Uniform Tire Quality Grading Scheme (UTQGS) developed by the National Highway Traffic Safety Administration (NHTSA) in the US Department of Transport.

Once tyre life information is available to consumers, it can be expected that this will have an influence on the characteristics of tyres that are placed on the market, by giving a competitive advantage to tyres with long life. The expected tread life of tyres will become a selling point.

Tyre manufacturers and importers will react in the short term perhaps by adjusting their price structures in response to any differential in demand across tyres. In the longer term, there will be incentives that encourage the development of tyres with longer tread life (better quality tyres including those with longer tread life are already available in the Australian market). However, realistically, Australia is such a small market in an international industry that local consumer demand cannot be expected to have a major impact on tyre design and manufacture.

The provision of the information could be made mandatory by government passing the appropriate regulations. Alternatively the tyre industry could agree to a code of practice that required this information. In the case of an industry-based scheme, tyres for which tread life information was not provided under a voluntary scheme would be less attractive to aware consumers, and so market forces (along with appropriate public awareness programs) might be effective in generating full compliance. However, experience in the US with the UTQGS is that tyre manufacturers as a group are less than supportive of the tread life rating given to tyres. Thus a tyre industry rating scheme may have difficulty getting off the ground.

Various regulatory schemes could be considered, such as requiring new tyres to have some minimum tread life, or imposing some form of tax on tyres which is inversely proportional to the tread wear rating. However, it seems premature to consider strong interventionist measures that over-ride consumer choice until measures to educate and inform the consumer have been tried and shown to have failed.

Some estimates of costs can be provided for a tyre grading scheme. For the UTQGS, the contract fee to conduct a tread wear test is approximately $37,000 (when converted to year 2000 Australian dollars)59. Obviously, each tyre model only needs to be tested once and the test costs can be defrayed over the production run for the tyre. Many tyres for sale now in Australia have already got UTQGS ratings (the UTQGS currently lists 2,265 tyres). Costs for labelling (including moulding the information on the sidewall) for the rating are estimated at $0.20 to $0.30 per tyre.

If 10 new tyre models required testing each year the total cost would be around $400,000, a fairly small fraction of turnover in the new tyre industry which is of the order of a billion dollars per year.

It might be argued that there are increased costs to the buyer associated with higher price tyres. But if the buyer has the necessary tread life and price information to make comparisons, he or she will only purchase a more expensive tyre if this is of greater value. Consumers should never be made worse off when they are offered a greater (or more informed) choice.

How effective might such a scheme be? In the US, 79% of the public have heard of the UTQGS tread wear rating and 29% take it into account in tyre purchase decisions60. Tread wear information is reportedly given prominent treatment in tyre advertising.

It is true that durability can often be purchased at the expense of other tyre qualities - like traction, comfort and road noise. If the value-for-money equation is sufficiently complex, it might be difficult and misleading to present simple messages about the relative merits of different tyres. But our view is that there is a lot of information and opinions that are swapped by vehicle owners about some of the other characteristics of tyres (such as road holding performance) but comparatively little on tread wear.

Retreads

One possibility is to include retreads in a system of independent advice along the lines outlined above. However, the information provided by the UTQGS - on tread wear, traction and the dissipation of heat - does not directly address concerns about safety. And there is some potential for the characteristics of the retread to be attributed to the original tyre. Not only would that undermine the UTQGS itself; it might also be a real or imagined reason for new tyre manufacturers to resist the introduction of the UTQGS. Retreads are not included in the US version of the UTQGS.

The development and distribution of promotional material extolling the value of retreads is relatively straightforward and need not be overly expensive. However, it would remain of limited value unless implemented in parallel with a scheme that provides consumers with guidance on individual retread products. Otherwise, private buyers would have little confidence in the quality of their purchase.

Governments could play a valuable role by adopting retreads for their fleets, and could specify certain minimum requirements for retreads to be fitted to their vehicles. This could give guidance and added confidence to private vehicle owners to purchase retreads and establish confidence in the market.

3.4.2 Option 2: Tyre maintenance

The pay-off from better tyre maintenance is multi-dimensional. As well as more durable tyres, the benefits include better fuel economy, safety, comfort and control, and less damage to shock absorbers.

The extent of the problem is indicated by the NRMA survey of the condition of tyres in Sydney, Newcastle and Wollongong61. It comprised:

The key findings are set out in Table 3.1. In summary:

Table 3.1 Findings from the NRMA survey of tyre conditions

Actual minus recommended pressure (%) Incidence of uneven wear (%)
Less than 99 kPa (under) 2 Left front tyre 35
99 to 50 kPa 7 Right front tyre 31
19 to 50 kPa 16 Left rear tyre 24
19 to +19 kPa (correct pressure) 33 Spare tyre 23
+20 to 49 kPa 25 Right rear tyre 22
+50 to 99 kPa 10
More than +99 kPa (over) 2
Total 100 Cause of uneven wear (%)


Wheel alignment 64
Average tread depth 3mm or less (%)
Tyre pressure 29
Right front tyre 17 Suspension 1
Spare tyre 17 Not established 6
Left front tyre 18

Right rear tyre 19

Left rear tyre 22

Source: NRMA (1993).

About a quarter of tyres show evidence of uneven wear, a prime cause of reduced durability. Misalignment and incorrect pressures are the main contributors.

The potential benefits of programs to improve tyre maintenance are the avoided damage to tyres, and the extent of the damage can be gauged from the findings of the NRMA survey.

The question is: how effective a package of information and educational initiatives might be, and what would be the costs? There are some indications that it might be difficult to educate motorists about the importance of tyre maintenance. The market for advice on tyre economy is probably much thinner than that for advice on fuel economy. Whereas petrol accounts for 20-25 per cent of motoring costs and is purchased regularly, tyres account for only 3-4 per cent of costs and are purchased irregularly.

The experience of one Sydney company with an innovative product for tyre maintenance is instructive. J C Ludowice & Son Ltd. developed its Green Ring Valve in 1993. The Green Ring Valve replaces the standard valve, is fitted and adjusted when the tyre is fitted, and replaced when the tyre is replaced. The green ring is visible whenever the tyre is under-inflated and disappears when the tyre is restored to its correct pressure, that is, without further reference to an air gauge. The tyres can be checked simply by walking round the car. However, when the valve was offered free to the company's 300 plus employees and members of the board, only 21 per cent took up the offer. At a price of $6.00 each from tyre retailers, its impact on the general public was quite small.

And even a short session of individual instruction about car maintenance can be expensive. On rough estimates provided informally by the NRMA, its inspection day in Newcastle seems to have cost about $100 per participant, mostly advertising costs. Given that the average passenger vehicle consumes about $100 to $150 of tyres per year62, it would be difficult to justify spending anything like $100 per participant in a tyre education campaign.

Notwithstanding these difficulties and costs, efforts in this area have great potential: members of the tyre industry have claimed that poor tyre maintenance can reduce the life of a tyre by up to 50 per cent. Using the results of the NRMA survey on the distribution of under and over inflated tyres in conjunction with the estimates in Section Part I.8.3.2, over the entire passenger fleet, proper maintenance could reduce tyre generation in aggregate by approximately 6%.

Further, the NRMA inspection day might not be a good guide to the costs of such programs. It was staffed by NRMA inspectors and the advertising had to succeed to the point where participants would go to the bother of booking a time at a specific inspection station. An alternative and less expensive approach might be to use non-professionals as ‘inspectors’, give them one or two hours training, and set them to work in the parking lots of supermarkets on weekends. They might do no more than offer to check tyre pressures; tell people where the tyre pressure placard is located; hand out a fact sheet on tyres, safety and the environment; nominate one or two service stations where the air hoses are accessible, easy to use, and accurate; and suggest some polite ways to rebuke service station operators when air hoses and gauges are found in poor condition. The inspectors should quickly learn to identify the better targets, for example, by age or sex. Motorists might be more interested if told that they pay a few cents towards the cost of the inspection day when they buy tyres.

Also, education programs have multiplier effects. That is, information is generally shared or swapped with other family members and friends; it is applied to second and subsequent cars. Hence, if it is possible to design a simple program that costs $5 per direct participant, and each participant shares that information with four others, the real cost is reduced to $1 each.

These types of direct contact programs would appear to offer greater promise of changing behaviour than public awareness programs in the mass media, but the latter would reach a wider audience. Of course, there is no reason why the two types of programs could not be run concurrently.

3.4.3 Option 3: Importation of used tyres

The two direct options could be designed to achieve the aim of keeping out unusable waste tyres in an effective manner. All options would need to be supported with well-designed monitoring and enforcement activities, and this would impose additional costs.

A total ban on imported tyres has the drawback that it would stop genuine imports of used tyres and result in foregone economic opportunities. The consequences in the case of passenger tyres would be felt most keenly by those who depend on used tyres, and these may belong to sectors in society who are least able to meet the resulting higher costs.

The more flexible approach of allowing used tyres into Australia subject to conditions is likely to be associated with operational difficulties, not the least of which is the complexities of determining compliance with the conditions.

The Australian Customs Service believes that a ban based on end use would not be feasible as the Customs Tariff and rules of classification focus on the characteristics of the goods at importation rather than end use.

The application of a levy on imports has the advantage that it confronts the importer with price signals that more closely approximate the real costs of eventual management of waste tyres. For used tyres with genuine value, the impact should not be dramatic, since these tyres would compete with used tyres generated within Australia which would also attract the levy (possibly at the point of manufacture). Thus the levy could be seen as functioning like a filter, allowing in used tyres with genuine value, but imposing significant additional costs on tyres that can be regarded as waste. It is not known how effective these costs might be in discouraging imports of used tyres with no beneficial use.

Any actions which apply to imports immediately raise international trade issues. In the framework of international trade, requirements on recycling or reuse are interpreted as product standards. Under GATT rules, product standards:

These requirements do not seem to throw up insurmountable hurdles to a levy on used tyres provided the levy is also applied to other tyres that compete with the imported used tyres.

3.5 A national approach?

Clearly a tyre rating scheme (whether government or industry) is national (in reality international) in scope.

The rationale for a national approach in market development programs for retreads and public awareness programs in relation to tyre maintenance is more problematic. Certainly a national based program would save costs in the development of promotional or educational materials, but an inspection activity, for example, would need to be tailored to local conditions.

It should also be remarked that programs targeted at product differentiation in the case of retreads will assist only the retreaders within the tyre industry, and it seems only fair that this should be funded by the retreaders. The retreading association represents the larger (and presumably more quality conscious) retreaders who would benefit from the product differentiation. Many retreaders operate locally, and a national scheme would have limited benefits.

Actions in regard to the importation of used tyres would need to be national in scale, and indeed be implemented by the Australian Customs Service with the requirement that the taxation treatment of imported tyres is mirrored in the domestic market. The Australian Taxation Office would need to be part of such an arrangement. Changes to legislation may be required.

 


55 The problem that needs to be addressed is that the convenience and comparatively low cost of private motor vehicle use has resulted in private road travel becoming an integral part of the lifestyle of many people, and this role cannot be substituted for by other forms of transport.

56NRMA (1993), page 34.

57NSW EPA (1996b), pages. 6-7.

58See for example Commonwealth of Virginia (2000).

59NHTSA (1995). The UTQGS test for tread wear is an on-road test using 4 vehicles over a standard 6,400 mile course plus 800 miles for pre-test break-in.

60NHTSA (1995).

61NRMA (1993).

62Taking new and retread tyres together, passenger tyres are consumed at the rate of 1.67 tyres per registered vehicle per year. Assuming an average price of $80 per tyre, the cost is $133 per year.