Submission on Australian Government tyre industry inquiry

Tyrewise Scheme Delivery Managers 3R Group, recently made a submission on the Australian Government’s Inquiry into the current state of the Australian tyre industry, and any challenges and opportunities for the industry within the context of a circular economy.

About 3R Group Ltd

At 3R Group, we are New Zealand’s leading experts in product stewardship—designing and delivering both voluntary and regulated schemes that drive real-world circular economy outcomes.

Our strength lies in bridging the gap between government and industry, co-creating practical, scalable solutions that reduce waste and environmental harm across Aotearoa.

With deep experience navigating complex regulatory landscapes and engaging diverse stakeholders, we activate stewardship systems that are not only compliant with legislation and their outcomes independently auditable, but also commercially and environmentally sustainable.

From concept to implementation, we turn stewardship into action —helping businesses meet their obligations, exceed expectations, and lead the transition to a low-waste, low-emissions future.

We have been involved in the Tyrewise regulated product stewardship scheme since work began over a decade ago. We’ve worked with industry and government to design, implement and run the scheme.

About Tyrewise

Tyrewise is New Zealand’s first regulated product stewardship scheme for a priority product under the Waste Minimisation Act 2008.

It was created to prevent millions of tyres going to landfill, being illegally stockpiled or dumped each year in Aotearoa New Zealand. The scheme officially launched on 1 March 2024 and launched operationally on 1 September 2024.

It’s funded via a Tyre Stewardship Fee charged on the sale of all new, regulated tyres in New Zealand. This fee is collected by the Ministry for the Environment and passed to Auto Stewardship New Zealand to operate the scheme. As a result, the scheme’s registered partners have access free tyre collections around the country.

Purpose of this submission

Our experience designing, implementing, and managing the Tyrewise scheme gives us unique experience, knowledge, and understanding of how to create a fit-for-purpose, regulated product stewardship scheme for end-of-life tyres.

We believe our insights will prove valuable for the inquiry, particularly in terms of:

  • Considering the role of commercially viable product stewardship schemes and whether these should be made mandatory, and identifying infrastructure gaps in collection, processing, and recycling facilities.
  • Identifying opportunities to develop high-value uses for waste tyres and tyre-derived materials, including applications in construction, manufacturing, and other commercial sectors.
  • Investigating environmental, community, and health and safety concerns related to tyre waste and recycling operations.
  • Investigating current practices in tyre reuse, retreading, recycling, and resource recovery, including reviewing federal, state, and local regulations governing tyre production, disposal, and recycling.

Our relationship with Tyre Stewardship Australia (TSA)

We have a long and productive relationship with TSA, sharing knowledge, experience, and insights. This has helped the development, implementation, and management of Tyrewise, and the voluntary TSA scheme.

In October 2025, Tyrewise and TSA jointly presented the Round Trip Tyre and Conveyer Belt Recycling Summit, in Melbourne. This event brought together leaders in the tyre supply chain as well as tyre transporters and processors.

In November 2025 Tyrewise and TSA announced the Trans-Tasman Tyre Recycling Alliance (TTRA) – a regional body dedicated to sharing knowledge, supporting market development, and advocating for circular economy solutions for end-of-life tyres across New Zealand and Australia. In the near future, it will also have a strong focus on supporting the establishment of end-of-life tyre recovery in Pacific Island nations.

Tyrewise and TSA share similarities in terms of the tyre market with many of the same brands, outputs for recycled material, and widespread use of tyres across society (private and commercial). While Australia’s far larger geographic size creates transport network challenges for a nation-wide scheme, in New Zealand the isolated nature of many communities presents similar challenges.

There is also a shared interest in research and market development for tyre-derived products, which present opportunities across both markets.

In 2024 Tyrewise wrote a letter of support for TSA, to members of the Australian Government, regarding advancing a circular economy for tyres. We maintain this position, which has only been strengthened by the success of the Tyrewise scheme.

Our experience – opportunities

Co-creation is vital

The single biggest factor in designing a scheme that worked for Aotearoa New Zealand was having industry around the table. Capable and respected representatives of industry and supply chain stakeholders understand the factors leading to market failure, and can therefore robustly evaluate proposed options to overcome them. Their deep understanding of their own industry means they have insight into potential unintended negative consequences of aspects of the scheme, and how they can be avoided or mitigated.

During scheme design and once regulations were in place, these stakeholders were key to communication to large numbers of supply chain members.

The co-design nature of the Tyrewise scheme ensured industry engagement from the outset. Technical advisory groups (TAGs) continue this trend whereby industry members are invited to contribute their expert advice across a range of areas for the purpose of improving the scheme.

 As a result, the scheme has become a hub for industry collaboration and innovation.

Regulated vs voluntary product stewardship

The tyre industry led the development of the Tyrewise scheme, with a consistent view that only a regulated framework could ensure a level playing field. This was vital to prevent the issue of free-riders and the potential for commercial advantage from not participating in the scheme.

Level playing field

A regulated scheme also levels the playing field in terms of transporters and processors by creating a uniform system which, while still allowing for competition, has mechanisms for preventing unscrupulous behaviour.

A key outcome of a national scheme is that it’s accessible to all members of the public and industry.

Robust data

It’s our experience that regulated stewardship schemes consistently outperform voluntary schemes in every aspect. Critically, they yield far more robust data than voluntary schemes.

Tyrewise, for example, is able to track:

  • How many tyres are imported into New Zealand
  • How many are collected (and where from) at their end of life, and
  • Where they go after collection and what they are used for

The Tyrewise website displays this data in real time. Reliable data across a product supply chain is vital to the ongoing success of any stewardship scheme as it enables and speeds up flexibility and adaptability.

Superior outcomes

Tyrewise has also proven that regulated schemes result in superior outcomes for collected material. This is because a regulated scheme has oversight over what happens to the collected material and has the enforcement capabilities to address compliance issues.

This creates a far greater certainty of supply of recovered material – something which is essential for providing investor confidence to create onshore uses, as well as stimulating market uptake.

Since the launch of Tyrewise we have noted an increased appetite by industry to invest. This includes new capital investment in fleet and processing, and the associated regional job creation.

We have also received reports of a decrease in illegal tyre dumping. For example, the Palmerston North City Council says they saw a 47% reduction in the number dumped tyres and 28% few dumping incidents that included tyres in the 12 months after the scheme commenced operations.

As a result, the council is saving money by dealing with far less illegally dumped tyres. There has also been a behaviour change benefit of residents having a free disposal option for tyres – as the council noted, “illegal dumping tends to attract more dumping, but clean spaces stay clean.”

Research and development

While Australia’s voluntary scheme already funds research and development, the amount of funding available to an all-of-industry scheme would create a much stronger investment base to help market development grow bigger and faster.

The financial stability created by a well-designed and well-run regulated scheme allows for substantial investment in research and development which supports medium to long-term commercial outcomes, without relying on the willingness of voluntary members to fund it.

Incentives to stimulate the domestic market

In the New Zealand scheme, incentives are used to encourage the sale of product to the domestic market over exporting tyres or tyre derived materials. Manufacturers can also claim incentives for products sold in the domestic market, which further helps stimulate domestic investment and market uptake – a vital component of creating a circular economy.

While Australia has taken the approach of banning the export of whole tyres, compliance and enforcement can be challenging. Export bans are a useful tool in the toolbox, but the carrot of domestic incentives can also drive a reduction in the attractiveness of export and non-compliance, keeping value, circular economy benefits and job creation onshore.

Consumer and participant (registered partner) sentiment

Creating and maintaining positive sentiment is key to a product stewardship scheme’s success. The level playing field of a regulated scheme creates the platform to achieve this, through a combination of good scheme design, effective messaging, and ongoing support and improvements.

The Tyrewise scheme enjoys a high level of positive sentiment, with 77% of respondents to a consumer survey saying they feel positive or very positive about the scheme – as reported in the scheme’s Milestone 4 report. Two examples of quotes from the consumer research:

“Hopefully (Tyrewise) will reduce tyres being dumped and provide a useful fully recycled end product.”

“I think it’s a great scheme, it’s great to see the innovations that NZ is getting better at.”

A survey of participants (registered partners) carried out April to May 2025 shows 92% of respondents were positive about the scheme in general, with 72% feeling ‘very positive’ and 20% feeling ‘somewhat positive’.

“Landfills are a significant environmental concern because they do not degrade, causing harm to the environment. Processing waste within the country can open up more opportunities for jobs, expand industries, and help create new industries, ultimately benefiting the economy and the environment.” – Tyre retailer

“I like the ethical disposal and you’re getting rid of those ones that were just out to make a buck and rip everybody off by charging extra and then not disposing of the tyres properly… and then spoil the environment.” – Tyre retailer

“The idea itself, we were on board with. We don’t like seeing tyres on the road, anything to help the environment is great.” – Tyre importer

“I think Tyrewise has been a game changer for us because it’s sort of evened out the playing field.” – Tyre processor

Scroll to Top