All tyre operators are free to import tyres directly for their business. However if you import tyres directly from outside the state, including Northern Ireland, you are the Producer for these tyres when you sell them and place them on the market.
As a Producer your legal obligations are to:
- Register with the Producer Register Ltd (01 5522 606) and report these tyres on a monthly basis.
- Charge your customers the vEMC on these tyres.
There are instances where tyre suppliers from Northern Ireland are advertising their tyres with no vEMC applied. The inference being that there are savings to be gained and that you can sell these tyres to your customers without the vEMC. That is misleading, there are no savings in this situation. If you purchase tyres from abroad you are the Producer for those tyres and must pay the relevant vEMC’s to the scheme.
They may also offer to ‘arrange for a fully licensed, certified waste tyre collector based in ROI to collect your tyre waste’ for a set cost, outside of the Repak ELT collection system. Under the 2017 Waste Tyre Regulations, only registered Repak ELT collectors can collect waste tyres and all waste tyres must be disposed of in an environmentally sound manner and be reported to Repak ELT. Compliant Repak ELT members will have their car and motorcycle waste tyres collected without charge.
If you import tyres directly you must protect your business!
It is illegal to:
- Import tyres and not report them to the PRL when sold. Regardless of your business model, whether you Retail the tyres yourself or wholesale to another business, you must cover your Producer obligations for all imported tyres.
- Sell a tyre without the vEMC. Regardless of whether you import a tyre directly or buy from a scheme supplier you must charge on the appropriate vEMC.
- Use a collector who is not a Repak ELT registered Collector. Only Collectors on the Repak ELT collectors list are permitted to collect tyre waste in the ROI. Do not take anyone else’s word, always check the list. If you have any concerns about a collector contact Repak ELT.
Whether a tyre has a vEMC or not you may only give tyre waste to a Repak ELT Registered Collector.
Repak ELT action
On behalf of our members, Repak ELT are following up potential incidences of illegal activity which have been reported to us. We will alert the Producer Register Ltd in the case of any Producer issues. If appropriate we will also notify the enforcement authorities, including the EPA, WERLA and Local Authorities. In addition, we will highlight the issue with industry bodies and our members directly, to make sure that they do not inadvertently expose their business to illegal practices.