Simple Steps for joining Repak ELT

Regulation

Tyre Regulations

Minister Denis Naughten has introduced new regulations for tyres to underpin the operation of a tyre compliance scheme which come into effect on October 1st 2017. 

The Minister says that the new scheme will ‘reassure consumers that their old tyres will be disposed of responsibly by the retailer when they buy new tyres.  There is a lack of information in relation to the tyre market in Ireland. These regulations will place a reporting obligation on tyre operators to provide data on the numbers of tyres coming on and off the market. This will be the first time that there will be clarity,”  

“A report published by the Department of the Environment, Community and Local Government found that a significant proportion of waste tyres were not being accounted for (with many being illegally dumped) and a lack of consistent and accurate data on tyres. Capturing data from all tyre operators will be an important step in addressing this,” stated Minister Naughten.

”I fully recognise the concerns expressed to me in relation to enforcement. Tyres are one of the five priority areas as agreed by the National Waste Enforcement Steering Committee (http://www.dccae.gov.ie/en-ie/environment/topics/waste/enforcement/enforcement-structures/Pages/Waste-Enforcement-Regional-Lead-Authorities.aspx) and I have made €9 million available this year in relation to waste enforcement. Now that these regulations are in place I will be asking the EPA and Local Authorities to begin a visible enforcement campaign on tyres”.

Minister Denis Naughten, Minister for Communication, Climate Action and Environment.

How will the compliance scheme operate?

Repak ELT (the approved body) will run the compliance scheme, which all tyre operators are obliged to join.  All operators will report to Repak ELT except for the producers who must also register and report to the Producer Register Limited.

How will the scheme be enforced?

 

WERLA

Waste Enforcement Regional Local Authorities (WERLA) have been set up in the Eastern Midlands, Connaught Ulster and Southern divisions to assist the local authorities in their region to enforce the waste regulations. 

They provide a coordinated national approach to compliance with new Regulations including:

    • awareness
    • inspections
    • Multi-local authority operations
    • Multi-agency operations

Local authorities will be responsible for retail enforcement. Tyres are on the list of priority waste streams for 2018 for all local Authorities.

WERLAs 

  • Eastern Midlands
  • Connaught Ulster
  • Southern

Environmental Protection Agency (EPA) 

The Environment Protection Agency (EPA) is responsible for enforcement of the Regulations which relates to functions and powers of the Registration Body and the obligations of tyre producers.

Enforcement activities include PRI enforcement, research, provision of guidance and awareness raising. The EPA will work with local authorities and other bodies to increase compliance overall with the Regulations including joining the approved body.

The EPA will rely on intelligence provided by the Registration Body, the Approved Body and others to identify suspected free riding producers. It is critical to the success of the Repak ELT tyre compliance scheme that free rider producers are identified and challenged by the EPA.

Link to EPA

Repak ELT

Repak ELT commit to follow up on any non compliant operators reported to us with the relevant enforcement authorities. All reports relating to non-compliance are treated in the strictest of confidence.

Report a free rider

Who needs to join?

 

Any business who handles tyres has an obligation to join the Repak ELT compliance scheme and report the tyres through their business. 

How do I know my obligations?

 

FAQ

 

General

  • If an operator is late to join the scheme will they be at a competitive advantage?

    No. Regardless of when a member joins, they are legally liable for all fees from the start of the scheme on October 1st 2017. Putting off joining is only deferring this cost and causing it to build up.

  • What happens those who don’t comply?

    The Repak ELT member list has all compliant operators listed. IF an operator is not a member, they are not listed and are trading illegally. The Enforcement agencies are updated with the members list and an economic operator list of all business who trade in tyres, which is updated daily.

  • Could late reporting affect my waste collection?

    Yes. Your business must keep up to date with your reporting requirements. If you are late submitting your data the scheme will not have the details required to process your collections.

  • Who enforces the retail sector?

    The Waste Enforcement Regional Lead Authorities (WERLA ) coordinate the enforcement of the retail sector supported by the local authorities.

  • Who enforces the Producer sector?

    The Environmental Protection Agency (EPA) enforces producer compliance.

  • What would cause an audit to be carried out?

    Repak ELT will audit collectors on a routine basis. We will also audit a sample of members on an ongoing basis. If we have cause for concern such as If you fail to report or a mistake is found with your reporting you will be contacted by Repak ELT. Persistent late and or mis reporting could cause an audit process to be undertaken.

  • Can I choose my waste collector?

    Yes. A list of Authorised Waste Collectors is available and you may choose your collector here

  • Will only scheme members be inspected?

    No. The Enforcement agencies have asked for the compliant industry to join the scheme as soon as possible as high levels of compliance will allow them to effectively target the free riders in the system.

  • Are waste collectors permitted to sell retail waste as PWT?

    No. End of life tyres discarded are prohibited from being resold back onto the market for fitting onto vehicles.

  • How do I manage tyres with zero vEMC?

    For tyres with a zero rated vEMC you will continue to pay the disposal charge to your authorised collected. Even though they are zero rated these tyres must be reported and may only be collected by an Authorised Collector.

  • Can I only report online?

    Yes. All reporting is online. If you have any queries about reporting email info@repakelt.ie

  • What if you are a Retailer and a Producer?

    If you purchase tyres and or vehicles from a producer within the state and also import directly from outside the state you are both a retailer and a Producer and must join Repak ELT and register with the PRL

  • What kind of files can be uploaded for reporting?

    There are a number of options to make your reporting easier and to eliminate the need for manual input of data. Contact info@repakelt.ie to discuss your reporting options

  • What is selling to self?

    When a Retailer imports tyres directly for sale in their retail outlet – they effectively sell to self and will report the tyres both through the PRL and Repak ELT.

  • How will retreads be managed?

    Retreads have a unique life cycle which will be reflected in the compliance scheme. If you have queries about retreads email info@repakelt.ie

  • How do I report a non compliant tyre trader?

    You can report non compliant operators through our confidential reporting (link) and also through your local authority or the EPA.

  • When will the vEMC for Agri and construction tyres come in?

    The Minister has deferred the vEMC for Agri and Construction tyres until the scheme has been established.

  • How will tyres going to Farms for silage pits be managed?

    All farmers who have a requirement for tyres for silage pits must register with Repak ELT. Tyres may only be given to farmers from Authorised Collectors. Retailers are prohibited from supplying framers directly with End of life tyres for silage pits.

  • How will tyres going to and from Authorised Treatment Facilities (ATF) and vehicle dismantles be managed?

    All Authorised Treatment Facilities (ATF) must join and report in to Repak ELT. They are not permitted to resell end of life tyres for the fitment to vehicles. Under the new regulations end of life tyres(part worn tyres) are discarded and prohibited from being refitted to a vehicle.

  • When does the vEMC need to be paid?

    The Producer (first person to put the tyre on the market)pays the vEMC at point of sale. The vEMC is then charged through the sales chain.

  • Is there help available to get the vEMC onto software systems?

    Yes Repak ELT can help you streamline your reporting. Email info@repakelt.ie to request further details.

  • When will Authorised collectors begin collection?

    From Monday 2nd October Authorised Collectors will be only collecting from member outlets. They will be prohibited from collecting from non members.

  • What rate of VAT is charged on vEMC?

    23%

  • If a consumer takes their waste away do you charge the vEMC and do you need to take their details?

    Yes. The vEMC relates to the new tyre being fitted and must be charged. You should take the customers details and inform them that they may take the end of life tyre back for disposal.

  • Will Producers be registered ahead of the scheme start date?

    Yes. Once the regulations are signed the PRL will open registration for producers

  • Will the vEMC rates come down?

    The quicker compliance builds in the industry the quicker the vEMC will come down. There are many established tyre PRI’s in Europe and the vEMC has been shown to consistently come down as high rates of compliance are achieved.

  • How does the collector know how many tyres to collect from a retailer?

    Timely reporting from retailers is key to facilitating an efficient collection system.

  • How will PWT being imported be managed?

    All second hand, part worn tyres must be reported to the PRL on import. They are covered with the same regualtions as new tyres and must be reported at each step in the distribution chain.

  • How can the scheme be sure that the compliant operators are not paying for the non compliant?

    Repak ELT operate the Tyre Compliance scheme on our members behalf and manage only our members obligations. Only Repak ELT member tyres will be collected by Authorised scheme collectors. Authorised scheme collectors are prohibited from collecting from non member outlets.

  • Will the scheme be advertised to consumers?

    Yes. A comprehesive consumer campaign will be run through national press and digital channels.

Collectors

  • Can collectors collect from non scheme members?

    No. Authorised scheme collectors may only collect from Repak ELT members.

  • How do I become an Authorised scheme collector?

    Go to (link to collector application) and complete your application online

  • What do collectors do with Agri and Construction tyres(zero rated vEMC)?

    You must report all tyres including those at zero rate vEMC. You will continue to charge you customers directly for these tyres.

  • Am I automatially signed up for start of scheme?

    No. Even if you have been a member of Repak ELT during phase one you must apply to become an authorised collector for phase 2. Link to collector registration

  • Is there training available for reporting?

    Yes. Repak ELT will give you help with your reporting and documentation requirements. Email info@repakelt.ie

  • What should I do if I have a concern about the volume of tyres for collection?

    If you are picking up waste tyres from a Repak ELT member and are concerned that some of the waste may not be scheme tyres, you should contact Repak ELT immediately.

  • Are waste collectors permitted to sell retail waste as PWT?

    No. End of life tyres discarded within the state are prohibited from being resold back onto the market for fitting onto vehicles.

  • When will Authorised collectors begin collection?

    From Monday 2nd October Authorised Collectors will be only collecting from member outlets. They will be prohibited from collecting from non members.

  • Will late reporting affect my free collection?

    Yes. Your business must keep up to date with your reporting requirements. If you are late submitting your data the scheme will not have the details required to process your collections.

  • Can I report by weight?

    No. All reporting is by unit

  • What if some of my customers are not members of Repak ELT?

    From the start of the scheme you are only permitted to collect scheme tyres from scheme members. Collecting non scheme tyres from non members could cause your contract to be compromised and could result in termination of your contract.

Retailers

  • Who is a Tyre Retailer?

    A tyre retailer is outlined in the new tyre regulations as a person who for the purpose of trade or otherwise, in the course of business sells or otherwise supplies tyres to other persons

  • How will waste at retail outlets be managed at the start of the scheme?

    Retailers are advised to reduced all stocks of waste tyres in the lead up to the start of the scheme, as they will have to pay the relevant vEMC on all waste tyres after October 1st.

  • How will the vEMC be managed?

    The vEMC is charged by the producer who is the first person to put the tyre on the market.  They pay the scheme the vEMC.  Each operator in the distribution chain charges the vEMC at point of sale, concluding in the retail outlet.  Waste generate through the scheme is picked up by authorised collectors at no charge to the outlet.

  • When is the vEMC due on opening stock?

    The vEMC due on opening stock is due as you sell these tyres.

  • When will Authorised collectors begin collection?

    From Monday 2nd October Authorised Collectors will be only collecting from member outlets. They will be prohibited from collecting from non members.

  • How will opening stock be dealt with?

    Retailers must declare opening retail stock.  The vEMC on opening stock is paid as the tyres are sold.  The declaration is important to indicate the volume of waste that will be arising from the REatail outlet during the opening months of the scheme.

  • Are you prohibited from buying from producer within state if they are not registered?

    Yes the regulations state that you may only purchase from a registered Producer

  • How do I know if I am an accidental producer?

    If you are the first person to put a tyre or vehicle onto the market – you are the producer for these tyres.

  • Will late reporting affect my free collection?

    Yes. You business must keep up to date with your reporting requirements. If you are late submitting your data the scheme will not have the details required to process your collections.

  • Can I report by weight?

    No. All reporting is by unit

  • What does a retailer who is also a producer do with opening stock which they are the producer for?

    Retailers must declare opening retail stock. If they have tyres for distribution to other retailers they do not have to declare these. The vEMC on opening stock is paid as the tyres are sold. The declaration is important to indicate the volume of waste that will be arising from the REatail outlet during the opening months of the scheme.

  • When will Authorised collectors begin collection?

    From Monday 2nd October Authorised Collectors will be only collecting from member outlets. They will be prohibited from collecting from non members.

  • Can I have more than one collector?

    You may have more than one collector if your business requires.

  • How do I mange the vEMC on tyres a consumer brings in to be fitted?

    The vEMC is related to the new tyre being fitted. If you are fitting a new tyre a customer has brought into your outlet, you must still charge the vEMC for this tyre at the relevant rate.

  • Will Producers be registered ahead of the scheme start date?

    Yes. Once the regulations are signed the PRL will open registration for producers

  • Do you have to report tyres sold to small garages even if you take their waste

    Yes. All tyre movements must be reported to ensure a clear picture of where potential waste tyres are. While you may have their waste, Repak ELT still needds to know where the tyres you fitted have gone.

  • What happens with contract tyres that are sold – but the waste must be held for one month – reporting?

    Contact Repak ELT if you feel that the numbers of contract tyres going through your business could make your reporting look incomplete.

  • What would cause an audit to be carried out?

    Random routine audits will be carried out on an ongoing basis by Repak ELT. If you fail to report or a mistake is found with your reporting you will be contacted by Repak ELT. Persistent late and or mis reporting could cause an audit process to be undertaken.

  • Who enforces the retail sector?

    The Waste Enforcement Regional Lead Authorities (WERLA ) coordinate the enforcement of the retail sector supported by the local authorities.

Producers

  • Who is a tyre Producer?

    A Producer is the first person to put the tyre on the market. They can be a manufacturer, wholesaler, tyre importer, vehicle importer, retreader or retailer importing directly.

  • How will the vEMC be managed?

    The vEMC is charged by the producer who is the first person to put the tyre on the market. They pay the scheme the vEMC. Each operator in the distribution chain charges the vEMC at point of sale, concluding in the retail outlet. Waste generate through the scheme is picked up by authorised collectors at no charge to the outlet.

  • How will opening stock be dealt with?

    Producers do not have to declare their opening stock

  • If you export tyres to the North do you have to charge the vEMC?

    No. Tyre exported outside the state are not subject to the vEMC.

  • What is the opt in option and what is its purpose?

    Repak ELT’s security system for data reporting is both confidential and secure. If as a producer you wish to share you data from your PRL reporting you can click on the opt in button and your details will be securely uploaded to the Repak ELT reporting portal.

  • Can I report by weight?

    No. All reporting is by unit

  • Will Producers be registered ahead of the scheme start date?

    Yes. Once the regualtions are signed the PRL will open registration for producers

  • How will PWT being imported be managed?

    All second hand, part worn tyres must be reported to the PRL on import. They are covered with the same regualtions as new tyres and must be reported at each step in the distribution chain.

  • How do I manage tyres with zero vEMC?

    For tyres with a zero rated vEMC you will continue to pay the disposal charge to your authorised collected. Even though they are zero rated these tyres must be reported and may only be collected by an Authorised Collector.

  • What kind of files can be uploaded for reporting?

    There are a number of options to make your reporting easier and to eliminate the need for manual input of data. Contact info@repakelt.ie to discuss your reporting options

  • When does the vEMC need to be paid?

    The Producer (first person to put the tyre on the market)pays the vEMC at point of sale. The vEMC is then charged through the sales chain.

  • Is there help available to get the vEMC onto software systems?

    Yes Repak ELT can help you streamline your reporting. Email info@repakelt.ie to request further details.

  • What rate of VAT is charged on vEMC?

    23%

  • Who enforces the Producer sector?

    The Environmental Protection Agency (EPA) enforces producer compliance.

EPA

  • How do I report a non compliant tyre trader?
  • What happens those who don’t comply?

    The Repak ELT member list has all compliant operators listed. If an operator is not a member, they are not listed and non- compliant. The Enforcement agencies are updated with our members list and an economic operator list of all business who trade in tyres, which is updated daily.

  • Will only scheme members be inspected?

    No. The Enforcement agencies has asked for the compliant industry to join the scheme as soon as possible as high levels of compliance will allow them to effectively target the free riders in the system.

Motor Industry

  • When an importer sells a car to a dealership do they need to show the vEMC?

    You may wish to itemise the vEMC – but you are only obliged to do so when the price of the tyre is shown. So for car sales you do not need to show the vEMC.

  • When a dealership sells a car do they need to show the vEMC?

    You may wish to itemise the vEMC – but you are only obliged to do so when the price of the tyre is shown. So for car sales you do not need to show the vEMC.

  • How will the vEMC be managed?

    The vEMC is charged by the producer who is the first person to put the tyre on the market. They pay the scheme the vEMC. Each operator in the distribution chain charges the vEMC at point of sale, concluding in the retail outlet. Waste generate through the scheme is picked up by authorised collectors at no charge to the outlet.

  • How will the vEMC be managed?

    The vEMC is charged by the producer who is the first person to put the tyre on the market. They pay the scheme the vEMC. Each operator in the distribution chain charges the vEMC at point of sale, concluding in the retail outlet. Waste generate through the scheme is picked up by authorised collectors at no charge to the outlet.

  • Should my tyre supplier show the vEMC?

    Yes. Under the new tyre regulations you are prohibited from purchasing tyres from non compliant producers. The regulations stipulate that each time the price of the tyre is shown, on invoice, website, price list etc it must be accompanied by the wording – this price includes a statutory contribution to the recycling cost.

  • How will second hand car sales track tyres?

    All sales in the distribution chain must be reported and the vEMC charged

  • Do vehicle dealerships have to show vEMC on sales receipts?

    When selling a vehicle, as the tyre cost is not itemised you do not need to show the vEMC . However you may wish to show the vEMC and need to follow the prescribed wording if you do list it as a line item

  • Do vehicle importers have to show vEMC on sales invoices?

    When selling a vehicle, as the tyre cost is not itemised you do not need to show the vEMC . However you may wish to show the vEMC and need to follow the prescribed wording if you do list it as a line item

  • What liability for vEMC do cars on forecourts at the start of the scheme?

    You are required to make an opening stock declaration for all tyres on vehicles at the start of the scheme.

  • How do I know if I am a Producer?

    If you import vehicles directly you are the producer and must pay the vEMC for the tyres on this vehicle, as the first person to put them on the market. You then charge you customer the vEMC in full when you sell the vehicle.

ERLA and LA

  • How do I report a non compliant tyre trader?

    Follow the link to your local authority:

  • What happens those who don’t comply?

    The Repak ELT member list has all compliant operators listed. If an operator is not a member, they are not listed and non- compliant. The Enforcement agencies are updated with our members list and an economic operator list of all business who trade in tyres, which is updated daily.

  • Will only scheme members be inspected?

    No. The Enforcement agencies has asked for the compliant industry to join the scheme as soon as possible as high levels of compliance will allow them to effectively target the free riders in the system.

  • How do I contact my local authority?

    Links to local authorities: 

The Waste Management (Tyres and Waste tyres) Regulations 2017 come into effect on October 1st. Are you ready to join?

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