New proposals could mean that all tractors and all agricultural machinery will be subject to a levy of up to €80 per tyre, depending on the tyre weight. This will apply to new, secondhand and imported machines that are fitted with tyres. Circol ELT, which operates Ireland’s tyre compliance scheme under approval from the Department of Environment, Climate Action and Communications (DECC), has proposed the agricultural tyre recycling tax in a submission to the Department.
This crippling tyre recycling levy proposal will be paid for by the end user, which will essentially be the farmer and the agricultural contractor. The fee will be collected on behalf of Circol ELT by the machinery dealer or the person importing the machine, under what is called the Extended Producer Responsibility (EPR) scheme. Circol ELT has confirmed to the Irish Farmers Journal that it has submitted proposals for this levy on agricultural tyres to the Minister for the Environment, Climate Action and Communications. It’s understood that within weeks, this could be signed off and a Statutory Instrument to be introduced this autumn.
While the Department of Environment sought stakeholder submissions on extending the recycling charge to agricultural and earthmoving tyres last year, it is only in recent weeks that stakeholders have become aware of the proposals.
It’s believed that the proposed fees were not negotiated with any input from farming stakeholders. This situation only came to light following a recent meeting between the Association of Farm and Forestry Contractors in Ireland (FCI) and Circol ELT.
Cost to industry
The scale of the fees being proposed in Circol ELT’s plans for the expansion of the current tyre recycling scheme is detailed on page 2. FCI estimates that there are 36,700 vehicles in Irish agricultural and forestry contractor fleets accounting for a total of 137,400 individual tyres.
“With 20,000 tractors in the national agricultural and forestry contractor fleet, plus the other machines, we estimate that this proposed levy will add in excess of €10.9m in costs to the sector,” said Ann Gleeson Hanrahan, managing director of FCI. “We believe that this tyre recycling levy is unjustifiably high for our sector as supporting primary food production and there is no way that we can pass on this exorbitant fee to our farming clients in the form of an increase in contractor charges by our members,” she added.
“We had our first meeting with Circol ELT in recent weeks after making representations to the minister many months ago.
“Our view is that Circol ELT is not interested in stakeholder feedback support from our sector, but is more interested in dictating an unrealistic recycling fee for agricultural tyres, without the opportunity for prior consultation or negotiations,” said Ann Gleeson Hanrahan.
“We understand our responsibility in terms of tyre recycling within our sector, but we feel that in the absence of a proper and traceable tyre recycling process, coupled with the exorbitant fee being proposed, it is highly unfair to our sector,” she added.
“For this reason, we are requesting a further extension of the exemption to allow for meaningful discussions that reflect the realities of an additional levy for our sector and fully examine the proposed costs of compliance for our sector,” said Ann Gleeson Hanrahan.
This tyre recycling levy proposal will be paid for by the end user, which for the most part will essentially be the farmer and the agricultural contractor.
Postpone tyre levy expansion – says FTMTA
The Farm Tractor and Machinery Trade Association (FTMTA) has expressed serious concerns about the implementation of the Extended Producer Responsibility (EPR) scheme, as it relates to agricultural tyres, calling for a postponement until a number of critical issues are resolved.
The EPR scheme was first introduced in 2017 to improve tyre recycling and ensure responsible waste management. However, according to the FTMTA, the application of the scheme to agricultural tyres is not yet fit for purpose
Speaking on behalf of the organisation, Maurice Kelly, president of the FTMTA, stated: “While we fully support the principles of the circular economy and the polluter pays model, the current proposal to include agricultural tyres under the EPR scheme is premature.
“There are still too many unresolved questions and ambiguities, particularly regarding the treatment of farm machinery tyres.
“We are calling on Minister Darragh O’Brien, the Department of the Environment, Climate and Communications and Circol ELT to defer the inclusion of agricultural tyres in the EPR scheme until all outstanding questions have been satisfactorily resolved.
“It is vital that a scheme intended to support environmental goals does not inadvertently place an unfair burden on our sector due to a lack of sector-specific understanding and proper consultation,” Kelly concluded.
Michael Farrelly, the association’s executive director, added: “Our engagement with Circol ELT to date has been limited, and despite raising specific concerns over recent months, several critical issues remain unaddressed.
“It is deeply concerning that after eight years, the nuances of the farm machinery sector are still not fully understood within the scheme’s administration.”
The FTMTA has identified multiple areas where clarity is still lacking, including:
The classification of farm machinery manufacturers under the scheme – should they register with Producer Register Limited (PRL) as producers, or with Circol ELT as retailers? The treatment of tyres fitted to machinery that is subsequently exported. Whether farm machinery dealers who do not sell tyres directly are still obligated to register and report monthly to Circol ELT. The FTMTA stated that it stands ready to engage constructively with all stakeholders to develop a scheme that is fair, workable and environmentally effective.
What is Circol ELT?
Circol ELT operates Ireland’s tyre compliance scheme, under approval from the Department of Environment, Climate Action and Communications. Circol CLT was set up in 2017 to meet the requirements of being an approved body under the Waste Management (Tyres and Waste Tyres) Management Regulations 2027 (SI 400 of 2017), as an approved body. In 2024 Circol ELT managed approximately 4.8m tyres or 42,000t (up from 39,000t in 2023, or 4.4m tyres) of waste tyres, on behalf of members through a network of 22 authorised and licensed collectors.
Circol ELT’s work focuses on finding sustainable outcomes for end-of-life tyres, as it operates under approval from the Department of Environment, Climate and Communications (DECC).
New proposals could mean that all tractors and all agricultural machinery will be subject to a levy of up to €80 per tyre, depending on the tyre weight. This will apply to new, secondhand and imported machines that are fitted with tyres. Circol ELT, which operates Ireland’s tyre compliance scheme under approval from the Department of Environment, Climate Action and Communications (DECC), has proposed the agricultural tyre recycling tax in a submission to the Department.
This crippling tyre recycling levy proposal will be paid for by the end user, which will essentially be the farmer and the agricultural contractor. The fee will be collected on behalf of Circol ELT by the machinery dealer or the person importing the machine, under what is called the Extended Producer Responsibility (EPR) scheme. Circol ELT has confirmed to the Irish Farmers Journal that it has submitted proposals for this levy on agricultural tyres to the Minister for the Environment, Climate Action and Communications. It’s understood that within weeks, this could be signed off and a Statutory Instrument to be introduced this autumn.
While the Department of Environment sought stakeholder submissions on extending the recycling charge to agricultural and earthmoving tyres last year, it is only in recent weeks that stakeholders have become aware of the proposals.
It’s believed that the proposed fees were not negotiated with any input from farming stakeholders. This situation only came to light following a recent meeting between the Association of Farm and Forestry Contractors in Ireland (FCI) and Circol ELT.
Cost to industry
The scale of the fees being proposed in Circol ELT’s plans for the expansion of the current tyre recycling scheme is detailed on page 2. FCI estimates that there are 36,700 vehicles in Irish agricultural and forestry contractor fleets accounting for a total of 137,400 individual tyres.
“With 20,000 tractors in the national agricultural and forestry contractor fleet, plus the other machines, we estimate that this proposed levy will add in excess of €10.9m in costs to the sector,” said Ann Gleeson Hanrahan, managing director of FCI. “We believe that this tyre recycling levy is unjustifiably high for our sector as supporting primary food production and there is no way that we can pass on this exorbitant fee to our farming clients in the form of an increase in contractor charges by our members,” she added.
“We had our first meeting with Circol ELT in recent weeks after making representations to the minister many months ago.
“Our view is that Circol ELT is not interested in stakeholder feedback support from our sector, but is more interested in dictating an unrealistic recycling fee for agricultural tyres, without the opportunity for prior consultation or negotiations,” said Ann Gleeson Hanrahan.
“We understand our responsibility in terms of tyre recycling within our sector, but we feel that in the absence of a proper and traceable tyre recycling process, coupled with the exorbitant fee being proposed, it is highly unfair to our sector,” she added.
“For this reason, we are requesting a further extension of the exemption to allow for meaningful discussions that reflect the realities of an additional levy for our sector and fully examine the proposed costs of compliance for our sector,” said Ann Gleeson Hanrahan.
This tyre recycling levy proposal will be paid for by the end user, which for the most part will essentially be the farmer and the agricultural contractor.
Postpone tyre levy expansion – says FTMTA
The Farm Tractor and Machinery Trade Association (FTMTA) has expressed serious concerns about the implementation of the Extended Producer Responsibility (EPR) scheme, as it relates to agricultural tyres, calling for a postponement until a number of critical issues are resolved.
The EPR scheme was first introduced in 2017 to improve tyre recycling and ensure responsible waste management. However, according to the FTMTA, the application of the scheme to agricultural tyres is not yet fit for purpose
Speaking on behalf of the organisation, Maurice Kelly, president of the FTMTA, stated: “While we fully support the principles of the circular economy and the polluter pays model, the current proposal to include agricultural tyres under the EPR scheme is premature.
“There are still too many unresolved questions and ambiguities, particularly regarding the treatment of farm machinery tyres.
“We are calling on Minister Darragh O’Brien, the Department of the Environment, Climate and Communications and Circol ELT to defer the inclusion of agricultural tyres in the EPR scheme until all outstanding questions have been satisfactorily resolved.
“It is vital that a scheme intended to support environmental goals does not inadvertently place an unfair burden on our sector due to a lack of sector-specific understanding and proper consultation,” Kelly concluded.
Michael Farrelly, the association’s executive director, added: “Our engagement with Circol ELT to date has been limited, and despite raising specific concerns over recent months, several critical issues remain unaddressed.
“It is deeply concerning that after eight years, the nuances of the farm machinery sector are still not fully understood within the scheme’s administration.”
The FTMTA has identified multiple areas where clarity is still lacking, including:
The classification of farm machinery manufacturers under the scheme – should they register with Producer Register Limited (PRL) as producers, or with Circol ELT as retailers? The treatment of tyres fitted to machinery that is subsequently exported. Whether farm machinery dealers who do not sell tyres directly are still obligated to register and report monthly to Circol ELT. The FTMTA stated that it stands ready to engage constructively with all stakeholders to develop a scheme that is fair, workable and environmentally effective.
What is Circol ELT?
Circol ELT operates Ireland’s tyre compliance scheme, under approval from the Department of Environment, Climate Action and Communications. Circol CLT was set up in 2017 to meet the requirements of being an approved body under the Waste Management (Tyres and Waste Tyres) Management Regulations 2027 (SI 400 of 2017), as an approved body. In 2024 Circol ELT managed approximately 4.8m tyres or 42,000t (up from 39,000t in 2023, or 4.4m tyres) of waste tyres, on behalf of members through a network of 22 authorised and licensed collectors.
Circol ELT’s work focuses on finding sustainable outcomes for end-of-life tyres, as it operates under approval from the Department of Environment, Climate and Communications (DECC).
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