The Spanish Association of Recycled Tyres (AER) has collaborated with the Spanish Confederation of Business Organisations (CEOE) and other business entities to draft a series of proposals for the Ministry for the Ecological Transition and the Demographic Challenge (MITERD). These contributions are part of the consultation process for the III Circular Economy Action Plan (III PAEC) 2027-2029.
A Strategic Plan for Industrial Transformation
This process is integrated into the work of the Circular Economy Advisory Council, a forum designed to collect input from economic and social agents to define the strategic lines of the state plan, which will serve as the roadmap for the circular economy in Spain in the coming years.
The III PAEC 2027-2029 is a strategic tool intended to advance towards an economic model that is more efficient in resource use and aligned with European policies on sustainability, decarbonisation, and industrial autonomy.
Within this framework, AER has worked to incorporate proposals to strengthen the role of the tyre retreading and recycling industry. The association provides a technical and industrial perspective based on product life cycles.
AER Proposals
Within the joint draft, AER has promoted several key proposals to improve the effectiveness of public policies:
- Ecodesign: Products Designed to be Retreaded
AER proposes specific measures to encourage ecodesign oriented towards tyre circularity, promoting the design of casings suitable for multiple life cycles through retreading or recycling. This approach, based on verifiable technical criteria and life-cycle analysis, aims to reduce material consumption by up to 30% by treating the design phase as a key element of industrial circularity.
- Green Public Procurement Based on Services
Rather than establishing rigid obligations or purchase quotas, AER advocates for more efficient models by incorporating circular-economy-linked services into public procurement. This includes promoting solutions such as repair, reconditioning, and reuse. This approach seeks to optimise resource use, extend product life, and improve the efficiency of public spending.
- Promoting Preparation for Reuse in ELTs
AER suggests strengthening measures to boost the preparation for reuse in the flow of end-of-life tyres (ELTs), prioritising retreading when technically viable, in accordance with the waste hierarchy. This approach preserves product value, reduces raw material consumption, and decreases environmental impact compared to manufacturing new products.
- Training and Skilled Employment
The sector proposes measures to ensure harmonised training in the circular economy at the European level, alongside the development of programmes to build a skilled workforce. This is considered essential for a just transition, improving employability, and generating local industrial employment.
A Strategic Sector in Public Policy
AER emphasises that the tyre retreading and recycling sector is a clear example of the applied circular economy, capable of reducing emissions, optimising resources, and generating industrial value. However, the association warns that these industrial activities require greater visibility and recognition in public policy to ensure that circularity is not limited to theoretical approaches or final recycling.
“The circular economy does not start with waste; it starts with design and industrial reuse. To make real progress, we need policies that support and reinforce these models,” says Adrián Fernández, Secretary General of AER.
A Demand for a Measurable Industrial Focus
The association insists that the future III PAEC must reinforce a vision of the circular economy grounded in tangible, measurable results aligned with industrial reality. AER considers it a priority for public policies to move beyond waste treatment and incorporate instruments that favour prevention, reuse, and the utilisation of product value throughout the life cycle.
For the tyre sector, this involves recognising the strategic role of retreading as an advanced expression of industrial circularity, as it extends product life, reduces dependence on raw materials, and lowers energy consumption. AER argues that these activities should occupy a more prominent position in national strategies due to their environmental contribution and ability to sustain industrial infrastructure and specialised employment.
AER’s Commitment to the Consultation Process
AER will continue to participate in the definition of the III Circular Economy Action Plan, providing technical proposals to support effective public policy. The association remains ready to work with public administrations and business organisations to promote a circular economy that combines environmental ambition with technical and industrial viability. According to the entity, the success of the next plan will depend on its ability to translate strategic objectives into concrete measures that facilitate the implementation of circular production models.
