Weibold Academy: England’s new Resource Framework: Implications for international TPO trade
Weibold Academy article series discusses periodically the practical developments and scientific research findings in the end-of-life tire (ELT) recycling and pyrolysis industry.
These articles are reviews by Claus Lamer – the senior pyrolysis consultant at Weibold. The reviews aim to give industry entrepreneurs, project initiators, investors, and the public a better insight into a rapidly growing circular economy. At the same time, this article series should stimulate discussion.
For completeness, we would like to emphasize that these articles are no legal advice from Weibold or the author. Please refer to the responsible authorities and specialist lawyers for legally binding statements.
England’s new „Tyre Pyrolysis Oil Resource Framework“ establishes a defined pathway for determining when TPO produced from waste tires may cease to be classified as waste. Although formally applicable only in England, the framework has significant implications for overseas TPO producers, traders and English importers. Imported TPO will not automatically be recognized as a product merely because it has obtained end-of-waste or equivalent status in the country of dispatch. Instead, the English importer must demonstrate compliance with the framework’s requirements, including eligibility of tire-derived feedstocks, representative pre-dispatch testing, conformity with minimum and refinery-specific specifications, certainty of refinery use, and delivery to an appropriately permitted facility. The framework therefore shifts market access towards transparent, contractually defined and evidence-based supply chains. While it may strengthen confidence in TPO as a refinery feedstock, it also increases the compliance, documentation, and due diligence burden for both exporters and importers.
Abstract
England’s new „Tyre Pyrolysis Oil Resource Framework“ establishes a defined pathway for determining when TPO produced from waste tires may cease to be classified as waste. Although formally applicable only in England, the framework has significant implications for overseas TPO producers, traders and English importers. Imported TPO will not automatically be recognized as a product merely because it has obtained end-of-waste or equivalent status in the country of dispatch. Instead, the English importer must demonstrate compliance with the framework’s requirements, including eligibility of tire-derived feedstocks, representative pre-dispatch testing, conformity with minimum and refinery-specific specifications, certainty of refinery use, and delivery to an appropriately permitted facility. The framework therefore shifts market access towards transparent, contractually defined and evidence-based supply chains. While it may strengthen confidence in TPO as a refinery feedstock, it also increases the compliance, documentation, and due diligence burden for both exporters and importers.
Introduction
On 30 June 2026, the Environment Agency published a dedicated resource framework for tire pyrolysis oil. For the first time, producers and market participants have a specific, publicly available route for demonstrations when TPO produced from waste tires (ELT) can cease to be waste in England. The framework is a significant development for the British TPO market. It provides greater regulatory structure for English pyrolysis operators, refiners and investors. Its implications, however, are not limited to domestic producers. The framework also establishes a new evidentiary threshold for TPO imported into England from the European Union, India, the United States and other producing regions.
The central message for overseas suppliers is straightforward: a product classification in the country of production will not automatically be accepted in England. Imported TPO must be supported by evidence demonstrating that it meets the requirements of the English resource framework. Without adequate proof, the Environment Agency states that the imported material will be treated as waste in England, even where the country of dispatch takes a different view. (GOV.UK)
This does not close the English market to international TPO. On the contrary, the framework may make that market more accessible to qualified suppliers. It does, however, change the basis on which access will be assessed.
A defined route out of waste status
The resource framework applies only to England. It does not establish a uniform UK-wide classification and should not be assumed to determine the position in Scotland, Wales or Northern Ireland. Northern Ireland also remains subject to EU REACH rather than UK REACH for chemicals placed on the market there.
Under the framework, TPO can cease to be waste where all specified conditions are met. The permitted feedstocks are limited to end-of-life tires under waste code 16 01 03 and shredded tires or tire crumb under waste code 19 12 04. The oil must subsequently be sent only to a refinery, where it is used as feedstock in the manufacture of marketable products.
The receiving refinery must hold the environmental permits required to accept and use the TPO in the quantities supplied. There must also be certainty that the material will be used for the specified refinery purpose. In addition, the TPO must meet the framework’s minimum specification and any further quality requirements agreed with the refinery.
This is an important limitation. The framework does not establish a general non-waste status for every possible application of TPO. It is not a route for placing untreated TPO directly on the market for unrestricted combustion or other industrial uses. Its scope is tied to a defined refinery-feedstock pathway.
The commercial value of the framework is therefore strongest where a supplier, importer and receiving refinery are connected through a clearly identified supply chain.
English recognition does not travel automatically
End-of-waste status is territorial. A material accepted as a product in one jurisdiction may still be classified as waste in another.
The Environment Agency’s waste shipment guidance requires the classification position to be considered in the country of origin, the destination country and any transit country. Where the relevant competent authorities disagree on whether the material is waste, the shipment must be handled as waste. Waste shipment controls then apply across the entire journey.
This principle creates a two-sided issue for TPO imports.
An overseas producer may have an end-of-waste decision, product approval or established commercial classification in its home jurisdiction. That decision may support exports from the country of production, but it does not bind the Environment Agency. Conversely, England’s new framework cannot compel the authority in the exporting country to classify the material as a product.
The decisive question is consequently not whether one authority has accepted the TPO as non-waste. It is whether all relevant jurisdictions consistently accept the intended cross-border movement.
For exporters, this makes the regulatory status of the shipment a supply-chain issue rather than a plant-level issue.
What changes for exporters outside Great Britain?
The English framework does not directly regulate a pyrolysis plant located outside England. Nevertheless, its requirements will reach back to the foreign producer through the English importer, refinery, and commercial contract.
The importer must hold appropriate proof that the imported TPO satisfies the framework. The Environment Agency expressly identifies testing documentation as part of that proof. In practice, however, evidence is unlikely to be confined to a certificate of analysis. The framework also addresses eligible tire inputs, certainty of refinery use, the receiving refinery permit, customer specifications and production and supply records.
An overseas supplier seeking product treatment in England should therefore expect its English counterparty to request significantly more information than a conventional commodity buyer might require. The supplier may need to demonstrate that the oil originates exclusively from the approved tire waste categories and that representative analysis was carried out before dispatch from the pyrolysis plant.
The framework sets maximum limits and specifies test methods for viscosity, Sulfur, total acid number (TAN), total halogens, and a range of metals. These are minimum requirements, not necessarily the full commercial specification. The producer must also agree the final specification with the receiving refinery, which may impose stricter or additional parameters.
A foreign producer’s existing specification may consequently be commercially acceptable to a trader but insufficient for reliance on the English framework. Similarly, an analysis performed using different methods may not provide the evidence expected within the framework, even when the reported numerical result appears comparable.
The new framework therefore favors suppliers capable of linking feedstock records, production batches, tank inventories, laboratory results and refinery deliveries. Producers that cannot provide this continuity may still be able to ship TPO, but the material may have to move under waste shipment control rather than as a product.
The English importer becomes the regulatory gatekeeper
For the English importer, the framework creates an opportunity and a considerable responsibility. The importer cannot rely solely on the exporter’s invoice, customs description, safety data sheet or domestic product classification. It must be able to show that the imported TPO meets the English end-of-waste criteria. If the evidence is incomplete, the Environment Agency’s stated default is that the material will be treated as waste.
This makes supplier due diligence central to the import decision. The importer must be able to reconcile the status of the material at dispatch with its intended status upon arrival. It must also consider whether waste shipment rules apply in the exporting or transit countries, irrespective of the position ultimately taken in England.
The identified refinery outlet is equally important. The resource framework requires certainty of use and a refinery with the appropriate environmental permit. An importer purchasing TPO speculatively, without a nominated refinery end user, may find it considerably more difficult to rely on the framework.
The Environment Agency specifically states that TPO held in intermediate storage without an identified end user will be considered waste. The rule applies whether storage occurs at the production site or elsewhere. It is also relevant to traders, terminal operators and other parties holding TPO stocks, not only to the original producer.
Commercially, the framework is therefore better aligned with contracted refinery supply than with open-ended storage and opportunistic resale.
Storage and blending require particular attention
TPO trading frequently involves storage terminals, consolidated cargoes and blending operations. The framework addresses these activities directly.
Where compliant TPO is mixed with waste oil, the entire mixed volume becomes waste. By contrast, mixing compliant TPO with another non-waste material, such as crude oil, does not in itself make the combined volume waste. Other products, chemical and environmental requirements nevertheless continue to apply.
This distinction may have substantial consequences for shared tanks, terminal procedures and cargo aggregation. A consignment’s status could be affected not only by its original production route but also by how it is stored and handled after import.
For importers and refiners, physical segregation and documentary consistency are therefore part of the same regulatory question. Subsequent handling arrangements in England may undermine a defensible product claim at the loading port.
End of waste is not the end of regulation
The framework removes waste controls only where its conditions are fulfilled. It does not remove obligations under other legislation.
This is particularly important for UK REACH. Waste is excluded from the scope of UK REACH, but TPO that has achieved non-waste status may become subject to chemicals legislation when it is imported or placed on the market in Great Britain. The result is not deregulation, but a transition from one regulatory regime to another.
A Great Britain-based entity importing one ton or more per year of a substance generally has UK REACH registration responsibilities unless an exemption or another valid arrangement applies. A manufacturer outside Great Britain may appoint a Great Britain-based Only Representative to assume certain importer obligations. Still, an EU REACH registration does not by itself constitute a UK REACH registration. The two systems operate independently.
The precise substance identity of TPO, the relevant registration scope and the role of each participant must therefore be considered separately from the end-of-waste assessment. The resource framework does not answer those questions.
GB classification, labeling and packaging requirements may also apply. Great Britain-based importers are responsible for ensuring that imported substances or mixtures are correctly classified, labeled and packaged before being placed on the market. Safety data sheet obligations may arise under UK REACH, particularly where the product is hazardous or contains hazardous constituents.
For exporters, this means that a technically compliant TPO analysis is only one part of market access. Product identity, hazard information and chemical compliance remain separate workstreams.
A higher evidence threshold — and a more credible market
The framework is likely to more clearly divide the international supplier market.
Established producers with controlled tire sourcing, reliable laboratory systems, stable oil quality and transparent operating records should find it easier to engage with English importers and refiners. Their documentation can support not only regulatory classification but also customer due diligence, insurance, logistics planning and financing.
Less prepared suppliers may face a more difficult position. A single laboratory report cannot necessarily compensate for uncertainty over feedstock origin, representative sampling, refinery destination or shipment status. Where the evidence package is weak, importers may price the regulatory risk into the transaction, require waste shipment procedures or decline the cargo altogether.
This is not necessarily a disadvantage for the TPO sector. A more disciplined import market may improve confidence in TPO as a refinery feedstock and reduce the risk created by inconsistent material being traded under a generic product description.
The key change is that documentation is no longer supplementary to the commercial product. Access to the English non-waste pathway becomes part of the product itself.
What the framework does not provide
The new framework should not be interpreted as a general approval of TPO imports.
It does not:
- create automatic mutual recognition between England and exporting countries;
- determine the classification of a shipment in the country of dispatch or transit;
- cover every TPO production feedstock or end use; guarantee that a refinery is permitted to receive a particular consignment;
- replace UK REACH, GB CLP, transport, customs or other product requirements;
- protect a consignment that is subsequently discarded, indefinitely stored or directed to an unsuitable facility.
Resource frameworks are voluntary, standardized routes for demonstrating end-of-waste status. Where an operator does not follow an applicable framework, it may seek to demonstrate end-of-waste on another basis. Still, the Environment Agency may review and disagree with that assessment. For cross-border transactions, such alternative positions are likely to require careful, case-specific examination.
The TPO framework is scheduled for formal review in April 2029. The Environment Agency may amend or withdraw earlier in response to pollution incidents, misuse, market changes, scientific developments, or changes in legislation and case law.
Conclusion
England’s tire pyrolysis oil resource framework is a constructive development for the international TPO market. It gives overseas producers and English importers a clearer basis for understanding when imported TPO may be handled as a product rather than as waste.
At the same time, it raises the standard for market entry.
A foreign end-of-waste decision is not enough. A compliant analysis alone may not be enough. The English importer must be able to demonstrate that the imported TPO satisfies the framework, including eligible inputs, representative testing, an agreed refinery specification, certainty of use and delivery to an appropriately permitted refinery.
The framework is therefore likely to reward direct, transparent and well-documented supply chains. It may also place pressure on trading models based on uncertain product status, speculative storage or limited access to production records.
For qualified exporters, the result could be stronger access to English refinery customers and a more credible product proposition. For importers, it provides a clearer pathway but also transfers substantial responsibility to the English side of the transaction.
The market opportunity is real. So is the burden of proof.
Weibold is an international consulting company specializing exclusively in end-of-life tire recycling and pyrolysis. Since 1999, we have helped companies grow and build profitable businesses.
Weibold is an international consulting company specializing exclusively in end-of-life tire recycling and pyrolysis. Since 1999, we have helped companies grow and build profitable businesses.
