German Tyre Recycling Standards: Meeting DIN and EU Requirements

By:     Kieran Donnelly

Germany is Europe’s largest generator of end-of-life tyres by volume, reflecting the country’s size, its large vehicle fleet, and its dominant automotive industry. Approximately 600,000 tonnes of waste tyres are generated in Germany annually, managed through the Altgummi GmbH and private processor networks under EU End-of-Life Vehicle Directive requirements and German waste legislation. German tyre recycling operates to standards that combine EU framework requirements with German technical specificity, and businesses in the German tyre processing sector need to understand both levels to operate compliantly.

This article covers the standards framework that governs German tyre recycling, the equipment specifications that meet those standards, and how German tyre processors can position their operations to access the highest-value end markets for processed tyre material.

The EU Regulatory Framework for Tyre Recycling in Germany

EU Directive 1999/31/EC on landfill banned the landfilling of whole tyres from 2003 and shredded tyres from 2006, establishing the baseline that Germany had already surpassed by the time the Directive took effect. EU Directive 2000/53/EC on end-of-life vehicles requires 85% reuse and recovery and 80% reuse and recycling for vehicles, which drives tyre recovery as part of the vehicle dismantling process.

The EU Circular Economy Action Plan and its associated regulations, including the ongoing review of the End-of-Life Vehicles Directive, are tightening requirements further. Germany implements these through the Kreislaufwirtschaftsgesetz (KrWG) and sector-specific regulations including the Altfahrzeugverordnung.

End-of-Life Tyre Management Routes in Germany

German end-of-life tyres flow through four primary management routes. Tyre-derived fuel (TDF) for cement kilns and industrial facilities accounts for a significant share; Germany’s cement industry is a major TDF consumer. Crumb rubber production for sports surfaces, playground fall protection, and rubber-modified asphalt is the fastest-growing recycled tyre material application. Whole tyre export, primarily to markets in Eastern Europe, Africa, and the Middle East, absorbs a portion of the German waste tyre stream. And tyre baling for civil engineering applications, while less developed in Germany than in the UK, is a growing route supported by EU circular economy policy.

The highest-value routes are crumb rubber for premium applications and tyre bales for civil engineering, both of which command a premium over TDF gate fees. German tyre processors investing in equipment that enables access to these premium routes improve their margin per tonne of tyre processed.

“The German tyre recycling market is more sophisticated than many processors realise,” says Conor Murphy, Director of Gradeall International. “The TDF route is accessible and established, but the premium routes require investment in the right processing equipment. A tyre baler producing bales to PAS 108 specification opens export markets and civil engineering applications that pay significantly better than domestic TDF. That’s a meaningful difference in economics per tonne.”

Tyre Baling Equipment for the German Market

The Gradeall MKII Tyre Baler produces PAS 108-compliant bales at up to 6 bales per hour, with bale dimensions and wire tie specifications that meet the requirements of European civil engineering and export markets. German tyre processors using the MKII can access UK civil engineering buyers, Middle Eastern construction markets, and Eastern European TDF consumers simultaneously with consistent bale output.

For German processors handling truck tyres alongside car tyres, the Gradeall Truck Tyre Sidewall Cutter provides the pre-processing capability to produce consistent bales from the 22.5-inch formats common in European commercial vehicle fleets. The German commercial vehicle fleet is one of the largest in Europe, creating a substantial truck tyre recycling volume that rewards investment in truck tyre processing capability.

DIN Standards for Rubber Products and Crumb Rubber

German and European DIN EN ISO standards govern the quality of rubber products derived from tyre recycling. Crumb rubber used in sports surface infill and playground safety surfaces is subject to quality specifications covering particle size distribution, metal contamination limits, and in the context of PFAS regulation, chemical content. German environmental regulators have been active in scrutinising crumb rubber from recycled tyres, particularly for applications involving children on sports and play surfaces.

For German processors, the quality chain begins at the baling stage. Clean, whole-tyre bales from the Gradeall tyre recycling equipment range provide a consistent, uncontaminated feedstock for downstream crumb rubber and TDF processors. The quality of the processed tyre output is directly linked to the quality of the baling and pre-processing stage.

Frequently Asked Questions

Is there a German equivalent to PAS 108 for tyre bales?

Germany does not have a direct national equivalent to PAS 108. German tyre bale quality for civil engineering applications is assessed against project-specific engineering specifications rather than a single national standard. In practice, tyre bales meeting PAS 108 specifications are accepted by German civil engineering specifiers who reference the British standard as a proxy specification, since it is the most widely recognised whole tyre bale standard in European markets. German processors exporting tyre bales to UK or international buyers need to produce bales to PAS 108 specification.

How are tyre recycling facilities permitted in Germany?

Tyre recycling facilities in Germany require an Immissionsschutzrechtliche Genehmigung (immission control permit) under the Bundes-Immissionsschutzgesetz (BImSchG) for larger operations, or a Baugenehmigung (building permit) and notification to the relevant Landesbehörde (state authority) for smaller operations. The permit conditions cover air emissions, noise, fire safety, and waste management requirements. Requirements vary by German federal state (Bundesland), and the relevant state environmental authority (Landesumweltamt) is the correct contact for specific permit requirements.

What is the PFAS issue for crumb rubber in Germany?

PFAS (per- and polyfluoroalkyl substances) in crumb rubber from recycled tyres have come under regulatory scrutiny in Germany and across the EU. The EU PFAS restriction proposal under REACH addresses multiple application areas including crumb rubber infill on sports surfaces. German environmental authorities have conducted testing programmes on sports surface crumb rubber. The regulatory situation is developing; German tyre processors selling crumb rubber for sports surface applications should monitor the EU PFAS restriction process and obtain current regulatory guidance from the Umweltbundesamt (Federal Environment Agency).

Can German tyre processors export tyre bales under EU waste shipment regulations?

Export of waste tyre bales from Germany to non-OECD countries requires prior informed consent notification under EU Waste Shipment Regulation 1013/2006. Export to OECD countries follows a simplified notification procedure. Tyre bales that qualify as recycled materials rather than waste (through beneficial use classification under German KrWG provisions) may be exportable under commercial goods rules rather than waste shipment regulations. Legal advice from a German waste and environmental law specialist is recommended before establishing tyre bale export programmes.

How do German tyre processors access the TDF market?

German cement kilns and industrial boilers that accept TDF operate under licensing conditions that specify tyre material acceptance criteria. Processors wishing to supply TDF must establish a supply agreement with a licensed TDF user, confirm that their tyre material meets the user’s acceptance criteria, and manage the waste transfer documentation (Begleitschein) required for waste tyre transport in Germany. The German cement industry association (VDZ) can provide information on member cement plants that accept TDF.

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