Not a day goes by without new legislation emerging that affects the retreading industry and this time, the spotlight returns to the European side of the Atlantic. In Spain, the proposed “Ley de Consumo Sostenible” (Sustainable Consumption Bill) has triggered concern in the tyre industry. The Spanish Retreading Association, Asociación Española de Neumáticos Reciclados (AER) warns that the draft could significantly impact the visibility of retreading as a circular solution in the country.
The Spanish Retreading Association Warns of Unintended Consequences in the Sustainable Consumption Bill
The Spanish Retreading Association (AER), in collaboration with the Spanish Confederation of Business Organizations, Confederación Española de Organizaciones Empresariales (CEOE), has expressed concern about several provisions included in the draft bill which is currently in the public consultation stage. In particular, it highlights the potential negative impact the law could have on the communication and promotion of retreads —a solution that is fully aligned with the objectives of the circular economy and transport decarbonisation.
The Sustainable Consumption Bill is intended to reduce environmental harm, greenwashing and protect its consumers. Among its headline measures:
- A ban on advertising fossil-fuel based products such as gasoline and diesel
- Restrictions on advertising vehicles powered exclusively by fossil fuels
- A ban on short-distance flight advertisements when a suitable alternative exists
- Stricter standards for environmental claims in advertising
- Anti-obsolescence rules, including extended warranties and repair rights
There are other measures and impacts that the bill is expected to have as well, but for most fair-minded these are all objectively good things to see. However, the controversy lies in “Final Provision One” of the draft, which introduces an explicit ban on advertising energy products of fossil origin. The original and translated text for this section is outlined here:
It’s clear to see from the text that the legitimate aim is to prevent greenwashing, but the AER is warning that the ambiguous wording could lead to unintended side effects for sectors like retreading, which directly contribute to sustainability, but are linked in their value chain to fossil-based products. In the past two months alone, tyre associations have repeatedly urged lawmakers to provide clearer legal language in proposed regulations. For example, the ETRMA recently cited the ambiguous language used in the European Union’s FAQ document and Delegated Act for its looming deforestation regulations.
In its recent press communication, AER stated that the vague wording in the draft could discourage manufacturers, fleet operators, or transport brands from promoting retreads for fear of non-compliance or reputational risk. “This media and commercial invisibility penalises an industry that is part of the solution, not the problem,” the statement read.
With the public consultation phase well underway and set to close on August the 31st, AER has already formally requested through the participation channel opened by CEOE (which is coordinating the submission of comments on behalf of its member organisations) and also directly via the Ministry of Social Rights, Consumer Affairs, and the 2030 Agenda.
Fernández and AER Look for Legal Exemption in Legal Text
Speaking to Retreading Business, Adrián Fernández the new Secretary General for AER confirmed that although he hasn’t engaged personally with the administration, discussions are ongoing with working groups where the AER is represented as part of the CEOE.
“Unfortunately, I haven’t yet had the opportunity to speak directly with anyone inside the Administration. However, we have discussed the matter within the commissions and working groups where we are actively represented as part of the CEOE, and they are usually the ones who contact government representatives directly.
I hope to soon reconnect with some of my former colleagues from the Spanish Office for Climate Change (OECC) within the Ministry for Ecological Transition, in order to give retreading the visibility and importance it deserves in the world of sustainability and the environment, given that we play a key role in our country’s circular economy.”
AER is calling for a clear and explicit exemption that safeguards sustainable business practices such as retreading. Fernández proposed a targeted clarification within the legal text itself:
“We are requesting a specific exemption (or an explicit legal clarification within the same article) that says something like:
‘This prohibition shall not apply to products, services, or processes that contribute to the circular economy or to the reduction of environmental impact, provided such benefits can be demonstrated in accordance with applicable national or European regulations.’”
Ambiguous fossil-product restrictions spark concern for new tyre manufacturers
The concern doesn’t stop with retreads. Eagle-eyed readers will have noticed that as Fernández points out, the generic nature of the law’s current wording could create widespread legal uncertainty, with potential collateral damage across the tyre industry.
New tyres, despite being essential for transport safety and increasingly engineered for fuel efficiency and lower emissions, still contain fossil-derived materials. Under a strict interpretation of the law, their marketing could also be restricted, particularly for tyres used on internal combustion vehicles.
While the Sustainable Consumption Bill sets out to tackle real challenges like greenwashing and environmental degradation and ultimately play a part in Europe’s journey towards net-zero and decarbonisation, stakeholders like AER argue that its success will depend on precision, not just principle. Without legal clarity, even the most sustainable solutions—like retreaded and efficient new tyres—may be sidelined.
