The Ministry of Climate and Environment has launched preliminary consultations on amendments to the Act on the obligations of entrepreneurs in waste management. The reform aims to align Polish legislation with EU circular economy standards. The Polish Tire Recyclers Association (PSRO) has expressed its support for the direction of the proposed changes while calling for a stronger extended producer responsibility (EPR) system, a clear priority for recycling over incineration, and full traceability of all tires placed on the market. The organization also announced that it will publish a new report on the state of tire recycling in Poland in November, outlining key challenges and recommendations for both the industry and public administration.
Extended producer responsibility under review
As part of the ongoing work on the amendment to the Act on the obligations of entrepreneurs in managing certain types of waste and on product fees, the Ministry of Climate and Environment is conducting consultations on changes to the extended producer responsibility (EPR) framework. For pneumatic tires, the ministry proposes to increase the recovery rate to 95%, including at least 50% recycling. This adjustment would reflect current technological capabilities and EU circular economy objectives. The ministry also plans to extend the law’s scope to solid tires, with minimum recovery and recycling targets set at 80% and 40%, respectively. In addition, the amendment would update product fee rates in line with European Commission implementing decisions and replace the existing Polish PKWiU classification with the EU’s Combined Nomenclature (CN) system.
The current state of tire recycling in Poland
The tire market in the European Union is currently valued at around €45 billion, with Poland being one of the largest sales markets in the region. In 2023, approximately 360,000 tons of tires were placed on the Polish market, with domestic production meeting only part of the demand. Tires remain an indispensable component of road transport, directly affecting safety through regular monitoring of their technical parameters and timely replacement once worn or damaged. The key safety indicators include tread depth and the time elapsed since production—usually around ten years.
The need for regular tire replacement means that the number of used tires continues to rise, making proper waste management crucial for environmental protection. Although tire recycling technologies have advanced significantly, a fully closed-loop system for tire-derived materials has yet to be achieved due to low environmental awareness and insufficient regulatory incentives for the use of recyclates. In Poland, technologies already exist for using rubber granulate in road construction, but its actual use remains limited. Moreover, PSRO stresses that rubber granulate should be used as a substitute for virgin rubber in tire retreading, which would yield tangible environmental and economic benefits.
Limitations of the current system
Poland has had an extended producer responsibility system in place since 2002, yet according to PSRO, its effectiveness remains limited. The system suffers from a lack of reliable data, low mandatory recovery and recycling levels (currently 75% and 15%, respectively, only for pneumatic tires), and numerous exemptions. Solid tires and tires imported with used vehicles are excluded from both the EPR obligation and the product fee. As a result, a large share of used tires ends up in cement kilns rather than recycling plants, while loopholes in the law allow a thriving grey market and illegal dumping. Estimates suggest that as many as two million tires escape official records every year, meaning thousands of tons of waste remain outside the formal system.
The association has repeatedly called for an update to existing regulations to ensure full traceability of all tires placed on the market and to raise the mandatory recycling rate to 50%. Such measures, PSRO argues, would not only optimize the capacity of domestic recyclers but also significantly reduce CO₂ emissions—by up to 700 kilograms per ton of tires diverted from incineration to recycling.
PSRO’s recommendations and priorities
PSRO welcomes the government’s proposals to raise recovery and recycling levels to 95% and 50% for pneumatic tires and to include solid tires under the same obligations. The organization also supports the indexation of product fees and calls for the introduction of a waste management hierarchy aligned with EU standards. This would ensure that energy recovery applies only to tires or tire components that cannot be recycled due to quality limitations. The association also supports replacing the national PKWiU classification with the EU CN nomenclature to improve regulatory consistency.
Beyond the ministry’s proposals, PSRO recommends additional reforms consistent with the EU’s policy direction. A key measure is the introduction of an explicit priority for material recycling over energy recovery, in line with Article 4 of Directive 2008/98/EC. PSRO proposes that tire incineration should be permitted only when material recycling is impossible due to quality reasons—such as heavily contaminated or colored tires. The organization also calls for tightening the national tire registration system, particularly for used vehicles imported into Poland. It suggests requiring a declaration of tire quantity during vehicle registration or excise procedures. Such measures would help eliminate the grey market, ensure full traceability of tire flows, and strengthen the overall efficiency and transparency of the EPR system.
“The Polish tire market stands at a crossroads. On one hand, we have tremendous technological potential and entrepreneurs ready to fully process used tires; on the other, we are still operating within a legal framework that dates back over a decade,” said Andrzej Kubik, Vice President of the Polish Tire Recyclers Association. “We welcome the direction of the proposed reforms and call for the amendment to deliver a genuine strengthening of the extended producer responsibility system. We need clear rules, full traceability, and a firm priority for recycling over incineration. Only then can Poland become an example of a modern and responsible circular economy.”
Outlook for 2025: new report and next steps
The Polish Tire Recyclers Association announced that it will release an updated report on the dysfunctions of the Polish tire recycling system in November 2025. The publication will present the latest market data and detailed proposals for updating the legal framework to close loopholes, increase recycling rates, and fully implement circular economy principles.
Source: CEO.com.pl – “New Tire Recycling Regulations Coming Closer: PSRO Supports the Direction of Changes”
