The UK Environment Agency has published a resource framework for tire pyrolysis oil produced from the pyrolysis of waste tires in England. The framework explains when tire pyrolysis oil, also known as TPO, can meet the end-of-waste test and no longer be considered waste. It sets conditions for approved input materials, refinery use, product specifications, evidence requirements, storage, imports, exports and mixing with other materials. The framework is intended to give tire pyrolysis operators, refiners and other market participants clearer guidance on when TPO can move outside waste management controls while still protecting human health and the environment.

Framework applies to TPO from approved waste tires

The resource framework applies only to TPO produced from approved tire-derived waste inputs. These include end-of-life tires under waste code 16 01 03 and shredded tires or tire crumb under waste code 19 12 04. The Environment Agency said the term “use” refers to the pyrolysis of these materials, meaning producers must ensure that only compliant inputs are used in the tire recycling and pyrolysis process if they want the resulting TPO to qualify under the framework.

End-of-waste status depends on refinery use

TPO will be considered to have met the end-of-waste test only if several conditions are met. It must be produced exclusively from the approved waste materials listed in the framework and, after pyrolysis, must be sent only to a refinery for use as a feedstock in the production of marketable products. The TPO must meet the minimum specification set by the framework, along with any further specifications agreed with the receiving refinery. The refinery must also hold the appropriate environmental permits to accept and use the TPO in the quantities supplied, and there must be certainty that the material will be used as refinery feedstock.

Intermediate storage without an end user remains waste

The framework states that TPO stored in intermediate storage, either on the production site or elsewhere, will still be considered waste if there is no identified end user. In such cases, the material remains subject to waste management controls. This condition is important for tire pyrolysis operators and traders because non-waste status depends not only on production quality but also on a clear and permitted route to final refinery use.

Producers must keep records on incoming waste and outgoing product

Producers following the framework must keep records of incoming waste, including the waste code and description, volume or weight, source, delivery date, supplier, carrier, acceptance method, reasons for rejecting input material and the handling of rejected waste. For outgoing TPO, producers must keep customer supply documentation declaring that the final product meets the framework’s minimum specification, all other framework requirements and any additional specifications agreed with the receiving refinery. These records must be made available to the Environment Agency on request.

Compliance with refinery permits is required

Producers must ensure that TPO is sent only to refineries with environmental permits allowing the acceptance and intended use of the material in the quantities supplied. The framework makes clear that compliance with its conditions does not remove the need to comply with other applicable legislation, including UK REACH requirements for chemicals. Failure to meet these obligations, or failure to follow waste management controls where framework compliance cannot be demonstrated, may constitute an offence.

TPO can lose non-waste status

TPO that qualifies under the framework can become waste again if it is discarded, intended to be discarded, required to be discarded, sent to a refinery without appropriate environmental permissions, or stored indefinitely with little prospect of being used. The Environment Agency said this applies to anyone holding stores of TPO, not only producers. The rule is intended to prevent tire-derived oil from being treated as a non-waste product when there is no realistic or compliant route to market.

Import and export status must be checked

The framework notes that TPO may no longer be classified as waste in England if it complies with the resource framework, but other countries may still treat it as waste. Exporters and importers must therefore check the status of the material with the relevant competent authority and follow waste export and import guidance where required. Imported TPO must also be supported by proof that it meets the requirements of the framework, including testing documentation. Without this evidence, imported material will be treated as waste in England and will remain subject to waste controls.

Mixing rules depend on the material combined with TPO

If compliant TPO is mixed with other waste oils, the whole mixed volume becomes waste and must follow waste management controls. If compliant TPO is mixed with other non-waste material, such as crude oil, the whole mixed volume is not considered waste, provided the requirements of other relevant legislation continue to be met. The framework says such mixing is not considered further treatment where neither material is waste.

Minimum specification set for refinery-bound TPO

The framework requires producers to agree the final TPO specification with the receiving refinery. However, any final specification must meet minimum limits set by the Environment Agency for properties including kinematic viscosity, sulphur content, total acid number, total halogens and several metals. The listed metals include aluminium, arsenic, cadmium, chromium, cobalt, copper, iron, lead, manganese, mercury, nickel, phosphorus, titanium, vanadium and zinc. Producers must carry out representative analysis of TPO before dispatch from the tire pyrolysis plant to prove compliance with these limits.

Framework scheduled for review in 2029

The Environment Agency said it will review the tire pyrolysis oil resource framework in April 2029 with support from industry. The framework may be updated or withdrawn before then in response to pollution incidents, incorrect use of the framework, changes in scientific understanding, market developments, legislative or case law changes, or changes to agreed industry standards and input materials. The publication provides a clearer regulatory route for tire-derived oil used as refinery feedstock, while maintaining controls around quality, traceability, permitted use and environmental protection.

Read more at The UK Government.