Page 12 - RB-107-2023-4
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 INTERVIEW EDUARDO ACOSTA  Circular Economy point of view. From the point of view of Asian tyre im- porters, we understand that their busi- ness is to sell units. The EPR Law puts the responsibility for the waste generated on the producers, however, it has been demonstrated that this alone does not produce the neces- sary incentive for users to increase reu- se by retreading tyres. Next, there is the difficulty in explai- ning the hidden environmental costs of not using retreads. If the comparative environmental costs between new and retreaded tyres, such as CO2 footprint, water consumption, and raw material consumption, as well as the whole issue of waste management, are not made ex- plicit and are not translated into incen- tives for users to adopt a reuse policy, communities will continue to absorb the- se costs until the authorities create the necessary regulations. And finally, the message that we must point out strongly is: “NO TO SIN- GLE-USE TYRES”. RB These are clearly very valuable and enlighte- ning arguments. But what was the reaction of the attendees at the conference? EA The audience was very respectful and lis- tened attentively. I did my best to captu- re their attention. However, most of the audience were people with an interest in tyre recycling and management sys- tems in the EPR models, rather than in tyre reuse. Unfortunately, there were no questions at the end. RB We understand. On the other hand, I would like to take advantage of this interview be- cause we have seen the re-emergence of the concept of industrial consumers in the case of the EPR Law in Chile to recognise the role of fleets, what is your view on this? Is it in- teresting to demand traceability from the fleet, and is it feasible? EA In Chile we mix the concept of industrial consumers of the EPR models, unders- tood as the one who introduces tyres to the market for their own consumption, versus the industrial consumer according to an ordinance of Housing and Urbanism, which defines them as establishments that generate waste and therefore must declare them. In my view, making fleets declare themselves as industrial consu- mers and waste generators will dilute the producer’s responsibility and may lead to duplication of information. The fact is that most fleets have not registered. I believe that, in Chile, we should return to the beauty of simplicity in the formalities, without this implying any shirking of the responsibility that the State defines for its citizens. RB Finally, what actions do you think are mis- sing from the EPR Law to support the effec- tive promotion of tyre retreading? EA In Chile we have been pioneers in recogni- sing tyre retreading as a valorisation activi- ty. Every used tyre (NU) becomes an end- of-life (EOL) tyre if it is not reused. This concept is very important and crucial for the life cycle of the tyre because it should not be forgotten that the EPR Law aims first and foremost to reduce waste genera- tion. I strongly believe that reuse through tyre retreading should have a particular target, different from collection and mate- rial recovery and energy recovery. From the beginning of the EPR Law process in Chile, tyre retreading was understood as Preparation for Reuse. On the other hand, the same EPR Law states that the activi- ties of preparation for reuse, recycling and energy recovery will be understood as va- lorisation. Different targets for different valorisation actions would ideally exist in a first update of the EPR Law.   P. 12 

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