The Ministry of the Environment has sent a letter to all consortiums authorised to manage End-of-Life Tyres about the correct interpretation of the Ministerial Decree 82/2011. Pneusnews has asked for a comment to the General Manager of Ecopneus, Engineer Giovanni Corbetta, which we fully report here below.
The original articles of Pneusnews can be consulted on its website at these links:
ELT collection: the fast tracks have been forbidden
End-of-Life tyre management is a system paid by consumers who pay an “eco-fee” upon buying tyres. The legislation on this matter is promulgated by the Ministry of the Environment. The activities ought to be carried out in the citizens’ interests. “Ought to”, because the Ministry noticed that some producers/importers are behaving incorrectly, offering ELT management exclusively to their clients and, thus, transforming it into a proper commercial strategy: if you buy my tyres, I’ll come and collect your ELTs.
The Ministry of Environment reacted immediately and wrote to the bodies involved in the activities of ELT collection and management highlighting, in a very clear and strict way, that those who behave in this way “elude the discipline expressed in the directorial decrees of approval of the articles of associations of the consortiums”. Basically, they do not comply with the regulations.
In the Ministry’s note, it is read that, upon verification of the websites of the operators of the sector “it has been noted that some producers/importers inform their potential clients about the possibility of guaranteeing ELT collection from a specific consortium in the case they were to buy the tyres they themselves sell”. “About this, it is highlighted that the activities of ELT collection from the points of generation is completely independent from the commercial strategies put into place by the same generation points (tyre dealers) and that the authorised consortiums cannot decide on ELT collection based on the purchases made by those who ask for the collection (the tyre dealer). In other words, the commercial strategies of the operators of the sector cannot interfere with the activities of ELT collection”.
Besides, the law (MD 82/2011) has always been very clear: every year, the producers/importers have to collect an amount of ELTs equal to at least the amount they put on the market; however, we are talking about tyres of any brand or type, and without any possibility of choosing what brands to collect or not. In attachment D of the same Decree, it is repeated that “the collection has to be carried out at every generation point of the spare parts market” and not only for the chosen ones, only because they are clients of the producer/importer the consortium represents.
The Ministry peremptorily concludes: considering that ELT collection is of public interest and is financed by the community, the producers/importers and their consortiums “must not manage ELT collection requests favouring their own clients among tyre dealers”.
The comment of Ecopneus to the note of the Ministry of the Environment – Interview to Giovanni Corbetta
The note of the Ministry of the Environment that makes reference to those producers/importers who have transformed ETL collection into a commercial strategy to their advantage rather than a service in favour of the community (that pays for it) has shocked the sector. We have talked about it with Giovanni Corbetta, General Manager of Ecopneus, the consortium that collects the majority of ELTs in Italy.
Did you expect this intervention from the part of the Ministry?
I was surely surprised by the fact that the Ministry wrote such a clear and incisive note on an issue as delicate as this one, even if it was already known to the operators of the sector.
Is it common practice then?
The trend of assimilating ELT management to one’s commercial activities has involved everybody to a greater or lesser extent. Probably, precisely for this reason, the Ministry has decided to intervene. Denying it, many people have done it, sometimes also in good faith.
Where does the problem stem from?
Unfortunately, considering the wide presence of goods on the Italian black market, it is not possible to quickly reply to all the collection requests you receive and, so, to offer a timely collection to you clients. It has become a strategic service, that can push the same sales.
Favouring those who buy the products of the partners of the consortium has become a common trend. This does not mean that is not illegal, or, at least, incorrect.
How does Ecopneus behave in the planning of the collection interventions?
From the moment that we manage large numbers of End-of-Life tyres, we have set up a very precise automated system, in order to try and give a system that is as efficient and uniform as possible.
To be honest, some years ago we also made some exceptions as we were getting anxious of emptying the full yards of some operators that were in greater difficulty. However, we then went back to the standard procedure, based on which we intervene respecting the chronological order of requests, without making any preference, on all the Italian territory and collecting every typology of ELTs.
How can you make everybody happy, especially in the most critical zones?
The management of such a complex system must guarantee the service to all those who apply for it, but it must also respect the cost-effectiveness and the efficiency of the same system. After all, the same Ministry, in its note, explains that the consortiums “have to answer to the requests of collection they received from every generation point”… “without prejudice, however, the right to organise the management with modalities that guarantee its efficiency, effectiveness, cost-effectiveness, and transparency”.
It is evident that intervening in the Po valley or in the Apennines implies different costs. There are areas where small tyre dealers work, which are spread out on mountainous or impervious territories. A consortium must, however, organise its activities so that they can reach everybody, keeping average costs aligned. It is not correct to choose to go only where it is easy and cheap. One must intervene everywhere, even if with different frequency.
In our system, we also have an indicator, which shows if we are in below (in red) or above (in green) with the collection for every province and based on the population. It is an important and immediate indicator that allows us to change our course, if needed.
What can you tell us about the transparency the Ministry’s note makes reference to?
It is fundamental to always aim at transparency to prevent problems. The next step we would like to take is, indeed, the introduction of a sort of dashboard onto our website. This dashboard should contain all the indicators that are useful to understand how we spend the money the consumers give us to manage end-of-life tyres. Indeed, consortiums like ours live because they receive money from the end-users by law, not because they earn it. Moreover, considering that we make no profit by definition, it is correct to show our contributors how we spend the money they give us.
How do you judge the message of the Ministry?
It is a warning sign and a further support to the structure. The note clarifies the rules also for those who worked in good faith, not realising they were putting wrong behaviour into place.
For us, this message reinforces and confirms the procedure that we have always applied, giving us the certainty we are walking the right way. And, however, we shall be even more rigorous from today on.
It would be nice that some clarification letters were published also on other critical issues of the legislation, so that we can all uniform to the Ministry’s authentic interpretation.