ITWRA issues statement
The Irish Tyre Wholesalers & Retailers Association (ITWRA) has released a statement to members on the back of communications between the Association’s solicitors and the Department of Environment, Community and Local Government. (DECLG).
The statement is published here in its entirety:
The Department has replied to William Fry Solicitors. It is fair to say the financial support received from the industry has been put to good use by the above solicitors.
Currently, there is NOT a requirement for a full Producer Initiative under EU legislation, no matter who is promoting this message.
As stated in the reply back from the Department to William Fry solicitors, Repak ELT is formally approved by the Minister to operate the current regulations only, but they do not have the required systems of security to our knowledge for anyone to give them information. The real news is the following;
The impact study has to be carried out in 2016; this should have been done prior to any approvals or suggestions of a full PRI. The Department have not listened to the concerns of the industry and overlooked this impact study, which was rightly pointed out by William Fry Solicitors.
The new regulations have to be written in 2016 and approved or signed off, but subject to public consultation. Self-compliance is currently a legal option, It will be 2017 before any new scheme can be in place. The ITWRA will continue to raise issue with any scheme that creates distortion and damages to to Irish trader and will oppose anyone who promotes the same.
Both Repak and WEEE have to submit an application to operate any new scheme.
Therefore, why should anyone join Repak ELT now when we do not know the implications of the new regulations? They do not have approval yet to operate any proposed new scheme.
Repak ELT do not have any security for information, therefore they cannot seek information from any dealer.
The option to self-comply exists for 2016, so continue to deal with your local authority. It’s the law so you are entitled to join the local authority.
The Department has also stated that the visible Environmental Management Charge (vEMC) will be set under the new Regulations at €2.80 per car tyre (€3.44 including VAT). It is proposed that the vEMC will cover the following:-
– Collection fee,
– Transport fee,
– Recycling/recovery fee,
– Scheme management costs,
– Auditing,
– Retail handling fee,
– Marketing costs,
– Education/awareness costs (information for public and the industry), and
– A Contingency Reserve.
If you examine these cost, it raises the question is the Collection Fee not similar to Transport cost and what is a Retail handling fee?
It raises a major question as waste collectors licensed under the current regulation have been collecting and recycling tyres for as little as €1.00 and Repak ELT require €3.44 to do the same job. Currently, recycling exists in Ireland.
We know that tyres will become valuable as fuel for cement plants in the near future. Therefore, it makes it difficult for Repak ELT to justify their proposed levies.
According to expert authorities in Europe waste tyres cannot have a fixed charge as it is subject to demand, currency and shipping costs.
Currently, Irish traders are supporting each other and have not swayed to join Repak ELT. There is a great feeling of solidarity in the tyre industry which has never been felt before. We also have to consider our waste collectors who will lose their business to Repak ELT.
The ITWRA are requesting all traders to stand up for our industry and protect their business. It’s time to face up to what is happening and the full implications of a Full PRI. A small effort at this stage can make a big impact.
Do not register with Repak ELT. By registering you are handing them control of the waste industry and a monopoly to charge exorbitant prices. Wait until we see new regulations and a full detail of any new scheme.
Repak ELT cannot comment on future charges as the new regulations are not written. We want full details of costs from Repak and WEEE prior to any support. We want full details of any new scheme and how it works. We want all the concerns raised dealt with by satisfactory solutions. Otherwise, this is like asking a builder to build a house without a quote, don’t forget this is our livelihood which is at stake.
Use our votes in the General Election as one organisation. Support the party that supports our industry and does not take the food from our table. We will advise you early next week which party intends to support the Irish tyre trade.
This is the one time for solidarity in the tyre industry where we all need to support each other. To date this is happening.