Ms Verona Murphy:

The Irish Road Haulage Association, IRHA, is the recognised national representative body of the licensed road haulage industry in the Republic of Ireland. The association seeks to promote professionalism, excellence and safety in the operation of road transport businesses. There are approximately 3,700 licensed haulage operators at present in Ireland. The sector supports 50,000 jobs accounting for approximately 2.5% of total employment in the Irish economy. Most of our members are based in rural areas throughout the country providing local jobs. In addition to its strong employment contribution, the sector is also central to getting essential goods for consumers and businesses in and out of Ireland. As such, the sector provides the life blood for Irish commercial and consumer life.

The IRHA fully understands the reasoning behind this new scheme. The illegal dumping or storing of waste tyres, particularly car tyres, is a problem that must be tackled. However, the scheme must be well planned, properly executed and above all amount to a fair and proportionate response. The imposition of a charge of €11 on truck tyres will in no way deal with a problem that is manifestly a problem with car tyres, which account for 94% of the total tyres sold in the State annually and which have little or no end-of-life value. It is not truck tyres that are fly tipped or strewn in the ditches of Ireland. Truck tyres account for a tiny percentage of total tyres sold in the State and are fully recycled through reuse within the State and then by exporting. However, the proposed charge is almost four times the charge for a car tyre when it is generally accepted that end-of-life car tyres retain little or no value and so form a considerable source of waste.

No case has been made to justify the imposition of such a high charge on truck tyres and the IRHA is deeply concerned at the arbitrary manner in which the €11 charge plus VAT was decided. This level is almost four times the level set for car tyres - to date we have not been told why. The IRHA requested a cost breakdown analysis for the charge from the Department but none has been forthcoming. We were told that the charge will go towards collection fee, transport fee, recycling-recovery fee, scheme management costs, auditing, marketing costs, education awareness costs and contingency reserve. However, no information has been given on the breakdown of the charge, that is, how much of the charge goes toward each element listed. The very same list of costs is given for car tyres and yet the rate set for a car tyre is €2.80 plus VAT, which is €3.44.

The system as it exists at the moment operates on the simple assumption that a tyre will have a single use life at the end of which it must be disposed of as waste. Therefore, when a new car tyre is purchased, the consumer pays for its inevitable disposal. This assumption simply does not apply to truck tyres as the same tyre will be retreaded several times after its first use yet it is the purchaser of the new tyre who must stump up the €11 plus VAT. The regulations came into force on 1 October and it is alarming how little preparation has been put into deciding a fair system to deal with the fact that truck tyres are recycled and reused many times before eventually being exported for further uses elsewhere or disposed of. A further meeting is being held at the offices of Repak later this month to discuss this further. The IRHA believes that proper scrutiny and oversight of the activities of Repak would have ensured that this issue was decided upon long before now.

It is very important I set the context for the IRHA's approach to this issue. Our members are facing a considerable threat to their viability arising from uncertainty associated with Brexit.

This has already manifested itself by creating huge issues of financial insecurity and challenge for members, particularly in circumstances where they are having real challenges in providing assurance to their lenders about the future stability of the market. This is a direct, immediate and current impact of Brexit on our members' businesses. The road haulage industry is at the forefront of the economic relationship between the UK and Ireland. Policy makers in Ireland need to ensure that this vital component of Irish economic life is protected to the greatest extent possible.

In the context of such uncertainty the IRHA, at our members' direct instruction, has been directed to engage with the Government to ensure that no new additional costs are imposed on our members. Specifically, we have been instructed to vigorously oppose any costs which are either unnecessary or not properly grounded. We believe that the proposed visible environmental management cost, vEMC, on truck tyres is one such measure which is misplaced and misdirected as it applies to our members. We believe that the imposition of a charge of €11 plus VAT per tyre on our members is unjustifiable and ignores the commercial reality facing our members. It represents a significant additional cost in circumstances where hauliers have absorbed numerous recent cost increases and simply cannot continue to do so in an unprecedentedly challenging operating environment. The proposed charge comes at a time when the IRHA is already seeking emergency measures to avoid a real risk to the viability of its members and the thousands of jobs that they support.

The IRHA has made it clear to the Department that the charge will force members to purchase tyres outside of the State as hauliers are already absorbing numerous cost increases and cannot countenance a new charge, especially one which is totally unjustifiable. Many of our members are already sourcing their fuel outside the State where there is a more effective fuel rebate system in place due to greater recognition of the essential user status of the haulage industry as a lifeblood of the economy. Now it appears our members are being forced to source another support service outside the State, a State which is failing its indigenous haulage industry and the 50,000, mainly rural, jobs it supports.

In conclusion, the IRHA believes that the charge for large truck tyres should be set at 0%, as it is at present for agricultural tyres, for an initial period of at least 36 months to allow the industry cope with this hugely challenging period and thereafter the charge should be set at a special rate but no higher than the rate set for the car tyre.