Regulatory Compliance Checklist for Tyre Recyclers: Permits and Licences

Updated on: 4th March 2026 By:

Tyre recycling in the UK operates within a substantial regulatory framework that covers environmental permitting, waste carrier registration, fire safety, planning permission, and health and safety. For new operators, the compliance requirements can appear overwhelming at first sight. For established operators, the risk is complacency: assuming that the permits and registrations obtained at startup remain appropriate as the business evolves.

This compliance checklist covers the key regulatory requirements for UK tyre recycling operations, what each requirement involves, who is responsible for it, and how to maintain compliance over time. It is a practical reference tool, not a substitute for site-specific legal and regulatory advice.

Environmental Permitting

An environmental permit from the Environment Agency (EA) is required for any tyre recycling site that stores or processes tyres above the thresholds covered by the waste management exemptions framework. The permit sets out the conditions under which you are authorised to operate, including what activities you can carry out, what materials you can accept, storage limits, fire safety measures, and reporting requirements.

Waste management exemptions (T8 for tyre storage) cover storage of up to 1,000 tyres in the open air or up to 5,000 tyres indoors below specified quantities, for sites that store but do not process tyres and that operate below the thresholds. Most tyre recycling operations exceed these thresholds or involve processing activities that take them outside the exemption framework.

Requirement	Responsible Body	Renewal / Review	Common Non-Compliance
Environmental permit	Environment Agency / SEPA / NRW	Annual compliance reporting; no automatic renewal	Exceeding storage limits; record-keeping failures
Waste carrier registration (upper tier)	Environment Agency	Renew every 3 years	Allowing unregistered sub-contractors to collect
Planning permission	Local Planning Authority	Check conditions periodically	Unauthentic change of use; breach of conditions
Health and safety risk assessment	Employer (you)	Review annually or on material change	Out-of-date assessment post site changes
Fire risk assessment	Responsible person (employer)	Review annually	Not updated after storage layout changes
Waste Transfer Notes	Both parties to transfer	Retain 2 years	Missing records for transfers; unsigned notes

Waste Carrier Registration

Any business that transports controlled waste (including end-of-life tyres) in the course of a business must be registered as a waste carrier with the Environment Agency. Upper-tier waste carrier registration is required for businesses whose primary activity includes waste transport. Lower-tier registration covers businesses that transport only their own waste as a minor part of their main business.

For tyre recycling operators collecting tyres from customers, upper-tier waste carrier registration is required. This must be renewed every three years. Allowing tyres to be collected or transported by an unregistered carrier is a waste duty of care offence, even if you are not the one doing the collecting.

Operations using Gradeall’s portable tyre baling system for on-site processing at customer locations need to assess whether their operating model requires waste carrier registration for the movement of bales from the processing location to their main site.

Duty of Care: Waste Transfer Notes

The waste duty of care under section 34 of the Environmental Protection Act 1990 requires that waste is only transferred to authorised persons (registered waste carriers and licensed receiving facilities) and that each transfer is documented with a Waste Transfer Note (WTN). Both the transferring party and the receiving party must complete and sign the WTN, and both must retain their copy for two years.

For a tyre recycling operation, WTNs are required for tyres received from customers, bales transferred to downstream buyers, and any residual waste transferred from the site. A bale transfer to a civil engineering project, a TDF buyer, or an export agent all require WTNs. Missing, incomplete, or unsigned WTNs are among the most common compliance failures identified in Environment Agency inspections.

“Waste transfer documentation is the most visible compliance indicator during an EA inspection,” says Conor Murphy, Director of Gradeall International. “Operators who maintain clean, complete records for every movement demonstrate operational competence. Those with gaps in their records create regulatory risk regardless of how well they manage everything else.”

Health and Safety Requirements

Tyre recycling operations are subject to the Health and Safety at Work Act 1974 and associated regulations including the Management of Health and Safety at Work Regulations 1999, Provision and Use of Work Equipment Regulations (PUWER), and the Manual Handling Operations Regulations. Risk assessments, safe working procedures, and equipment maintenance records are all mandatory elements of a compliant health and safety management system.

Gradeall equipment is CE marked and designed to UK and EU machinery safety standards. Equipment documentation provided with every machine includes safety information that supports your PUWER compliance obligations. The Gradeall homepage provides contact details for obtaining equipment safety documentation and compliance support.

Ongoing Compliance: Maintaining Your Position

Regulatory compliance is not a one-off exercise completed at startup. It requires ongoing attention as the business evolves. Changes to site layout, storage volumes, or processing activities may require permit variations. New staff require training on waste duty of care, fire safety, and equipment operation. Equipment changes may require PUWER risk assessment updates.

For operators who have grown their operations and added equipment such as truck tyre sidewall cutters or OTR tyre processing equipment to their processing line, a permit variation review is advisable to confirm the existing permit covers the expanded activities.

Frequently Asked Questions

How often does the Environment Agency inspect tyre recycling sites?

Inspection frequency depends on the site’s risk rating under the EA’s compliance assessment scheme. Higher-risk sites and sites with previous compliance issues are inspected more frequently. Most compliant sites operating within permit conditions are inspected one to three times per year. Sites that have had compliance issues may face more frequent inspections until the EA is satisfied that the issues are resolved. Maintaining comprehensive records and proactively reporting any issues to the EA supports a lower risk rating over time.

What happens if I exceed my environmental permit’s storage limits?

Exceeding permit storage limits is a permit breach, which the EA can respond to through formal remediation requirements, financial penalties, or in serious cases, permit revocation or prosecution. The EA has the power to issue enforcement notices requiring compliance within a specified period, stop notices requiring immediate cessation of the non-compliant activity, or financial penalties under the environmental civil sanctions framework. If you anticipate needing to increase storage above your current permit limit, apply for a permit variation before exceeding the current limit.

Is there a legal requirement to provide training on waste duty of care?

There is no specific statutory training requirement for waste duty of care, but the duty of care itself requires that you take all reasonable steps to ensure waste is managed correctly. This includes ensuring that staff involved in waste transfers understand what the duty requires and how to complete Waste Transfer Notes correctly. In practice, documented staff training on waste duty of care demonstrates that you have taken reasonable steps, which is relevant in the event of a compliance investigation.

What is the difference between a waste management licence and an environmental permit?

Waste management licences were the previous regulatory instrument for waste management sites; they were replaced by environmental permits under the Environmental Permitting Regulations 2010. Existing waste management licences were converted to environmental permits at that point. There is no practical operational difference for current operators: all tyre recycling operations above the exemption thresholds now require an environmental permit from the Environment Agency rather than a waste management licence.

What should I do if I discover that a previous waste transfer was made to an unregistered carrier?

If you discover that waste was transferred to a carrier who was not registered, you should check whether the carrier has since become registered (and if so, whether they were registered at the time of transfer). If the carrier was genuinely unregistered, consider whether you have committed a waste duty of care offence and take legal advice. Self-reporting to the Environment Agency, where an offence has genuinely occurred, is generally viewed more favourably than the offence being discovered through an inspection. Document the steps you have taken to prevent a recurrence.