Mr. Tony Keohane:

I thank the Chairman, Deputies and Senators for the opportunity to address this committee.

Repak End of Life Tyres, ELT, a company limited by guarantee, was incorporated on 24 July 2015 under Part 18 of the Companies Act 2014. Repak ELT applied with a detailed submission to the Department of Communications, Climate Action and Environment to be the approved waste management scheme, and was granted an approval by the Minister from 1 October 2017 to 31 December 2022, subject to an interim review in 2020. Repak ELT is a not-for-profit company. It was set up to manage a compliance scheme for producers and retailers to ensure that their waste tyres were managed in an environmentally sound manner. Twenty countries in Europe have end of life tyres producer responsibility initiatives. Repak ELT's mission is to provide legal compliance for its members under the Waste Management (Tyres and Waste Tyres) Regulations 2017, and in doing so to focus on providing a cost-effective solution and responsible, environmentally sound recovery methods for waste tyres.

Repak ELT is a separate legal entity to Repak Limited, the compliance scheme for packaging waste. There is a service level agreement between the two entities, which enables synergies to be created and Repak ELT to draw on the considerable experience and lessons learned by Repak Limited throughout its successful 20 years of operation. Such experience covers the full range of compliance activities, including data capture and storage, membership recruitment and management, auditing, target achievement, communications, awareness raising and behavioural change.

On behalf of its members, Repak ELT will be responsible for all tyres sold to the consumer with a visible environmental charge, and for the waste tyres coming off the market to be collected by authorised waste collectors. So far, since the introduction of the Waste Management (Tyres and Waste Tyre) Regulations 2017, we have 1,695 members, representing retailers, wholesalers and producers, while over 2,013 outlets have been signed up to the scheme. These include 1,375 retailers and 114 producers, with the balance being authorised treatment facilities. The industry has responded positively to the introduction of the regulations. A total of 21 collectors have been approved, based on having up-to-date tax clearance certificates, national waste collection permits on all vehicles and verified outlets for the recycling and recovery of waste tyres.

The visible Environmental Management Cost, vEMC, introduced as part of the regulations, is formalising an existing charge that was applied by most retailers. The Minister has set this cost to be €2.80 for car tyres and €1.50 for motorbike tyres. The vEMC for truck tyres will be introduced in January 2018. The visible charge will pay for the following; the collection and transportation of tyres for recycling and recovery; the recycling and recovery cost; contribution to the historic stockpile fund; the funding of Producer Register Limited; education and awareness for the public and producers; administration costs of the scheme, including auditing; and the build-up of a contingency reserve fund which is a standard requirement for all full producer repsonsibility initiative, PRI, schemes.

Repak ELT has put in place a comprehensive communication and awareness programme for consumers and for all potential obligated businesses in the past 12 months, including but not limited to a road show at five venues across the island of Ireland. This was attended by theDepartment, the Enivronmental Protection Agency, EPA, the Waste Enforcement Regional Lead Authorities, WERLAs, the Producer Register Limited, PRL and Repak ELT, as well as producers, retailers, car manufacturers and collectors. A campaign of direct letters, emails, direct calling, radio advertising and a website with all the necessary information to comply are all in place. A consumer radio awareness programme will commence in January 2018.

As with any new compliance scheme, behavioural change is required and will take time. The initial response from the tyre industry has been positive. Repak ELT will support the enforcement process as required with the statutory authorities. Repak ELT’s long-term strategic objectives are; to maximise complce levels and grow the membership base of Repak ELT; to meet agreed ELT recovery and recycling targets in a cost-effective and environmentally sound manner; to continually benchmark with other EU member states to pursue excellence in recycling and recovery and promote best practice aligned to the waste hierarchy; to build up a sufficient contingency reserve over time; to contribute to abatement programmes for historic stockpiles; and to deliver a sustainable financial plan.

I can assure the committee that Repak ELT would use its best endeavours in delivering a compliance scheme that protects our environment with the help of all the stakeholders.