Mr. Thom Fox:

I thank the Chairman for the invitation to appear here today. I am unaccustomed to this type of audience. I would prefer to be doing a tractor puncture at 5.55 p.m. than be here today. I am joined by Kevin Farrell and Brendan Byrne. We are all former Irish Tyre Industry Association, ITIA, council members. We established ATRS along with Darren Darker, Sean McCullough and Cormac Farrell to give retailers a voice and a platform to build and promote best practice among compliant tyre operators. We have engaged with the Department of Communications, Climate Action and Environment, the tyre working group, the Road Safety Authority, RSA, and Repak ELT. We have a mailing list of 500 retailers who receive our newsletters and our website iswww.atrs.ie. We are tyre operators with outlets across the country with many years in business. We strive to have consistently high standards for safety and service. We are all automotive technician accreditation, ATA, accredited tyre fitters.

The founding retailers who formed ATRS felt that as both of the other tyre representative organisations represented more than one sector, each sector could not be effectively represented and set up ATRS as a retail-only organisation to fully represent the retail sector. Retailers have long been looking for regulation in our industry as the compliant operators must battle daily against the black economy traders who have popped up in our industry without any requirement for them to be trained or competent to fit and repair the most important and often overlooked safety component of a vehicle. This, along with the dumping of tyres nationwide, means that regulation in our industry has long been needed and is something retailers have been calling for.

We see the introduction of the Waste Management (Tyres and Waste Tyres) Regulations 2017 as a good foundation for the establishment of new standards for our industry which we would like to see established as a trade with enforceable standards for fitting, repairs and the safety of the products going onto the national fleet. We welcome the fact that some tyre categories have not had a vEMC imposed on them just yet and we will continue to engage in the further examination of how best to manage these tyres. We are sure that an agreement can be reached with a fit-for-purpose outcome through the tyre working group's next meeting.

The number of tyre operators in Ireland is estimated at just over 3,000. A culture of compliance is building in the tyre industry and more than 2,000 members joined the Repak ELT tyre scheme in the first two weeks of the new regulations. As the first piece of regulation to specifically deal with the tyre industry, the swift uptake of compliance shows how needed and welcome the regulations are to tyre operators. The compliant operators now need to be supported with targeted enforcement to deal with the non-compliant free riders as a priority.

The stipulation that all operators must join the compliance scheme has been a catalyst to have a new culture of compliance building in our industry. The fact that it will be public knowledge who is signed up to the scheme and who has remained non-compliant, should make identifying free riders in the system very simple. Enforcement is weak. Enforcement is something that the entire industry has always agreed on yet it has only a brief paragraph in the regulations. This urgently needs to be expanded. There simply must be consequences to non-compliance. Enforcement checks must start with non-compliant operators.

The definition of producer in the regulation has resulted in some of the main manufacturers who sell directly into Ireland not joining the scheme. Retailers do not want to be producers especially not for tyres from suppliers who have been producers under previous regulations. The onus, especially on small owner-operator retailers to join Repak ELT and the Producer Register Limited, PRL, is unnecessary.

ATRS recommends the following actions to ensure the successful implementation of the new regulations: reduce the vEMC on compliance as previously agreed. Retailers should be able to do all their reporting through Repak and an opt-in to the PRL for any for any producer of tyres would reduce the administrative burden on retailers. It makes sense that the reporting takes place with the option to opt in from where the bulk of their submissions are made. Targeted and visible enforcement has been promised and fixed-penalty notices must be brought in to support the new regulations.

Cross-Border co-operation would help to allay concerns in the industry.

Part worn tyres pose both a safety and environmental risk. Part worn tyres shipped in from Europe do not follow established sales chains which could leave them open to under and non-reporting and containers of part worn tyres can have up to 30% of unusable tyres in a consignment. They place a heavy burden on environment and should be subject to a vEMC that reflects this imbalance.

The Association for Retail Tyre Standards would like the committee's support and encourage all public representatives to support the fixed penalty notices when they are before the Dáil. ATRS works with all stakeholders in the tyre industry and will continue to engage with the local authority enforcement officers, the EPA, Waste Enforcement Regional Lead Authorities, the Road Safety Authority and the Department to make sure that in carrying out our business activities we continue to protect the environment.

The new regulations for tyres are most welcomed by ATRS and we will do all we can to ensure they are implemented successfully. With robust enforcement the regulations could be positive for all compliant operators and could be a starting point for other standards to be introduced in our industry.