The NEW LIFE initiative welcomes the draft of a National Circular Economy Strategy (NKWS) for Germany, but calls for adequate consideration of sustainable used tyre recycling.

The recycling of used tyres is in line with the guiding principles of the NKWS for the transformation to a resource-conserving economy. Some of the guidelines and goals described in the NKWS draft are already fulfilled in exemplary fashion by the recycling of used tyres. For example, this keeps valuable raw materials (especially rubber) in the cycle, which helps to conserve natural resources, reduces dependence on raw material imports and also saves 700 kg of CO2 emissions per tonne of used tyres (compared to their incineration), which corresponds to the NKWS goal of decarbonisation.

NEW LIFE has appealed to the authors to give appropriate consideration to the proven, climate-friendly processes for used tyre recycling and the production of sustainable recycled products from tyre rubber granulate in order to further expand them and secure their future. NEW LIFE considers the inclusion of the following measures to be essential:

1. Used tyres that can no longer be retreaded must be 90 percent recycled in an environmentally friendly manner.
2. The export of used tyres to non-EU countries must be banned.
3. Used tyres that are still used as fuel must be recycled as quickly as possible. Only non-recyclable tyres may be thermally recycled.
4. Recycled rubber granulate contains firmly bound PAHs, the migration of which cannot be measured under realistic conditions. As part of the EU Commission's review of current PAH limit values, hazard-related, migration- and emission-based measurement methods must be implemented at EU level in order not to jeopardise the sustainable recycling of used tyres.
5. All regulations and certifications should be checked for their suitability for the circular economy. The use of recycled materials should be encouraged and not prohibited.

The implementation of these measures can secure the future of sustainable used tyre recycling, safeguard numerous jobs in SMEs, strengthen Germany's position as a pioneer in the circular economy and at the same time make an important contribution to climate and environmental protection.