ACTUALLY MAKING TIRE RECYCLING SYSTEMS BETTER
FROM THE CEO
Across the globe, 2023 was a year of challenges, from ongoing wars to mounting geopolitical tensions. More locally, Ontarians felt the effects of global economic uncertainty, including higher fuel, energy and food prices, inflation rates and volatile markets. While these events had an impact on our company, service providers and customers, we remained more committed than ever to actually making tire recycling systems better.
During this period, our team addressed a number of challenges including: a compliance order issued to all Ontario tire PROs in April; a lengthy regulatory consultation
As the only not-for-profit tire PRO offering compliance services, our priorities were clear early on: 1) to help modernize the current Tires Regulation and ensure it sets tough but achievable requirements; 2) continue to support our service providers in tire collection and delivery by offsetting inflationary pressures; 3) engage in marketplace partnerships that drive efficiency, and support price stability; and, 4) ensure tire recycling continues to drive positive environmental outcomes without unnecessarily increasing costs to Ontarians. With this in mind, we went above and beyond to support a strong tire recycling industry in 2023.
aimed to amend the Resource Recovery and Circular Economy Act (RRCEA), including modernizing the current Tire Regulation to ensure producer compliance requirements are tough but achievable.
Despite these challenges, on our customers’ behalf, eTracks achieved a record high in resource recovery at 87.2%; a direct result of efforts to incentivize service providers in making operational improvements to increase recovery rates.
Ontario saw significant processor disruptions in 2023 due, in part, to a soft crumb rubber market that wreaked havoc on the end-of-life (EOL) tire supply chain, resulting in unprecedented closures and delays at processing sites. To ensure the continuous flow of tires, our team responded by sourcing and creating new delivery and storage options. This included engaging with a new processor and ensuring delays in tire collection were addressed quickly. While the disruption eventually resolved late in the year, we continued to take measures to reduce the risk associated with similar disruptions that could occur in the future.
From a regulatory standpoint, we demonstrated an unwavering commitment to our customers, the tire and automotive industries and Ontarians, by lobbying the Ontario government and supporting tire producers through a lengthy regulatory consultation and review process. This initiative
The year also saw an increased focus on sustainability, including increased collaboration among tire manufacturers and auto makers to support people, planet and profit as interconnected and necessary drivers of growth and security in the coming years. These are significant and somewhat unprecedented shifts in the tire industry that intertwine with the role of compliance and governance. Sustainability is no longer a nice-tohave, but a must-have strategy to ensure the long-term health of the industry, the people who depend on it, and the planet.
We could not have achieved these milestones without the trust and support of our customers, service providers and broader industry. I hope the following report illustrates why industry trust is well placed in eTracks, using specific details about our business decisions and our commitment to doing the right things for the right reasons.
STEVE MELDRUM, CEO eTracks
OUR GOAL AS A NOT-FOR-PROFIT
Our goal as a not-for-profit tire PRO is to support a healthy recycling system that enables our customers to achieve compliance; where end-of-life tires are collected and repurposed into new, useful products.
TOTAL
AMOUNT COLLECTED AND REPURPOSED SINCE 2019!
+616,000
TONNES COLLECTED FROM ACROSS ONTARIO
PRODUCER RESPONSIBILITY & TIRE RECYCLING IN ONTARIO
In 2023, Ontario tire producers were responsible for the collection, recycling and repurposing of 85% of the weight of the tires they sold into market under the Resource Recovery and Circular Economy Act (RRCEA). This amounts to a 100% collection requirement, as 15% is subtracted at the end of a tires life to account for wear. Ontario’s Tire Regulation is the only regulation under the Resource Recovery and Circular Economy Act (RRCEA) to have a 100% collection requirement.
Tires were the first of five material classes rolled out under the RRCEA in 2019, including, batteries, electronics, hazardous waste and Blue Box materials. In many instances, the classes that followed the Tire Regulation benefited from the example of tires and were amended to address implementation issues, while optimizing compliance outcomes.
A person or business is considered a tire producer under the RRCEA if they:
• are the brand holder of the tire and have residency in Canada.
• import tires from outside of Ontario and sell them in Ontario.
• are the vehicle manufacturer and have residency in Canada.
• import new vehicles into Canada and sell them in Ontario
+527,000
TONNES MADE INTO NEW AND USEFUL PRODUCTS
The Resource Productivity and Recovery Authority (RPRA) is the regulator mandated by the Government of Ontario to enforce the Tire Regulation and all of the province’s circular economy laws.
PRODUCTS MADE FROM END-OF-LIFE TIRES COLLECTED
BY e TRACKS IN 2023
• Pylon and post bases
• Speed bumps and parking curbs
• Hockey pucks
• Pipe supports used in plumbing, electrical and HVAC industries
• Bullet traps for indoor shooting ranges
• Door mats, flooring, garden products
• Agricultural applications, including comfort flooring and non-slip pathways in dairy, beef and equestrian buildings
• Rubberized asphalt and paving tiles
• Health care, wellness and residential flooring
• Infill for synthetic turf fields
• Installation for driveways, playgrounds, walkways, backyards, recreational fields, golf turfs, fitness room flooring and turf field shock padding
• Landscaping edging, tree rings and pavers
• Anti vibration support for RVs
• Blasting mats, dwarf mats sidewalls, road mats and protection mats
• Membrane engineered for waterproofing and roofing applications
• Landfill drainage chips
• Acoustical rubber construction products & sound proofing
• Impact layers for levelling uneven concrete (replaces injected concrete)
• Rubber garden mulch
• Rubber molded sports products
• Tire Derived Aggregate (TDA) for civil engineering purposes
2023 PERFORMANCE YEAR HIGHLIGHTS
87.2% MARKS A NEW HIGH IN RESOURCE RECOVERY
For the fifth year in a row, all eTracks customers exceeded their 85% resource recovery rate as per Tire Regulation 225/18 by achieving 87.2%!
RESOURCE RECOVERY RATE:
the total weight of materials resulting from end-of-life (EOL) tires used for an approved purpose, this is then divided by the total weight of all end-of-life (EOL) tires collected by eTracks in a calendar year.
We accomplished this by refining our approach to identifying non-eligible materials (e.g. loose rocks, dunnage, debris, etc.) and working with service providers to keep those materials out of our resource recovery efforts. We also changed our processing payment approach to better align recovery value across all service providers, and worked closely with processors to improve the allocation of recovered tire material.
TIRE COLLECTION & ACCESSIBILITY
What began as an intense post-pandemic review of our collection network in 2022, continued throughout 2023 with multi-pronged outreach and analysis of the collection network. Our deep dive included regulatory awareness campaigns, site checks to verify activity status (i.e. determining what businesses had changed, closed or moved during the pandemic) and developing a mapping system to better understand tire disposal accessibility in practice.
DOING THE RIGHT THINGS, FOR THE RIGHT REASONS
Throughout the year, our team continued to implement robust activities aimed at building the most compliant collection system possible. This included implementing steps outlined in eTracks’ Compliance Order Report and establishing an ongoing and dynamic verification process of the 6,678+ sites in our collection system. These activities were completed in tandem with additional engagement and compliance tactics, including, hosting collection events in potentially under-serviced areas.
Our collection network activities were further punctuated by a Compliance Order issued to all Ontario tire PROs in April 2023 as Ontario’s Regulator sought to bring all tire collection networks into compliance.
2024 STATEMENT FROM THE REGISTRAR CONFIRMS ETRACKS HAS ‘ COMPLIED WITH ’ APRIL 2023 COMPLIANCE ORDER
On April 5, 2024, RPRA issued a statement regarding their review of the Compliance Order Report submitted by eTracks on August 31, 2023. The report was based on the requirements of a Compliance Order that was issued to all Ontario tire PRO’s in April 2023, regarding non-compliant elements in all tire collection networks. (These are the same elements being reviewed in the Ministry of Environment, Conservation and Parks (MECP) consultation process regarding unachievable requirements in the Tire Regulation.)
MANAGING COLLECTION NETWORK COMPLIANCE
Managing the behaviour of both consumers and collection sites to achieve the requirements in the current Tire Regulation is a dynamic, ongoing, comprehensive process. A by-product of these efforts, our team was able to identify areas of the Regulation where requirements needed to be adjusted to better reflect the needs of Ontarians when it comes to tire disposal options and accessibility.
SUMMARY OF COLLECTION SYSTEM COMPLIANCE ACTIVITIES:
Developed comprehensive mapping of Ontario municipalities and collection accessibility requirements using the ArcGIS platform. This allowed us to examine areas where the current regulatory requirements were not accounting for either population
density or proximity when considering the number of tire collection sites needed to service a municipality.
Verification of collection site location and active status via targeted email campaigns and cold calls to over 6,678+ sites across Ontario, completed by eTracks staff and a third-party call centre.
Reminder and assessment of understanding about the requirements of sites under Section 68 (3) of the RRCEA and Tire Regulation 225/18 (Section 10) pertaining to accepting end-of-life tires from the public.
Educational handouts for collection sites: eTracks haulers and investigators were provided educational resources to increase collection site awareness of accessibility requirements, and how to enroll with eTracks for free tire pick-ups.
Social media awareness campaign: Facebook, X, LinkedIn, and blog content on free tire disposal and the role of collection sites in Ontario.
Advertising campaign in Ontario Tire Dealership Association (OTDA) trade magazine promoting the value of tire recycling and outlining collection site requirements.
Industry-wide service provider webinars and engagement activities hosting eTracks enrolled collection sites, haulers and processors.
Ongoing, professional and transparent communications with the Regulator throughout the Compliance Order reporting process.
ADVOCACY EFFORTS TOWARDS TOUGH BUT ACHIEVABLE REQUIREMENTS
TOUGH BUT ACHIEVABLE –AMENDING THE TIRE REGULATION
In June 2023, eTracks initiated a government relations campaign to support meaningful regulatory change within Tire Regulation 225/18. This was done with the understanding that periodic reviews and assessments are necessary to ensure that regulations are being carried out in the spirit they were intended. The Resource Recovery and Circular Economy Act (RRCEA) includes many essential objectives: protecting the natural environment and human health, fostering a more circular economy and minimizing waste by making producers responsible for the recovery of the products they manufacture and sell into the marketplace (i.e. Individual Producer Responsibility (IPR).
GOVERNMENT RELATIONS
Throughout the year, we met with the Ministry of Environment, Conservation and Parks (MECP), the Premier’s Office, the Regulator, Automakers, Industry Associations and other key stakeholders to discuss industry challenges and solutions.
We know our customers want to be compliant, but to do so, regulatory requirements must be achievable. Between 2019 and 2024, even by the Resource Productivity and Recovery Authority’s (RPRA) own data, even if all the tires collected in Ontario were combined, tire producers would not be able to collectively meet the 100% collection requirement.
CONSULTATION PROCESS
In August 2023, the MECP announced the start of a formal consultation process to evaluate and determine what could be improved in the RRCEA,
including Tire Regulation 225/18. Along with other industry stakeholders, including tire producers, eTracks submitted its recommendations and supporting data to the MECP as part of the consultation.
Our recommendations focused on two key issues: the collection network accessibility requirement and the minimum collection requirement.
We informed our customers in weekly status updates providing transparency around our compliance activities throughout the year, including bimonthly webinars and 1-1 meetings with members of our leadership team.
Our CEO, Steve Meldrum attended the MECP’s September 2023 in-person consultation to provide eTracks’ perspective and feedback. In November, we received a summary of the consultation and provided our final written feedback. We were encouraged to see the efforts of our amendment suggestions and proposed solutions reflected in the “Summary of the Consultation process”.
Our lobbying efforts have continued into 2024 as we work to actually make the tire recycling system better
SUSTAINABLE FINANCIAL MANAGEMENT
PRICE STABILITY
After maintaining price stability for five years (since 2019), like many businesses, the pandemic took a toll on our financial reserves requiring us to increase our compliance service fees on January 1, 2023. Even with this increase, our fees remain well within the average across Ontario and Canada.
FINANCIAL EXPERTISE
We welcomed Kate Hayer, our new Chief Finance Officer (CFO), to support our strategic financial planning requirements, and to continue to build best in class internal controls. We also re-committed to utilizing our small but mighty finance team to support our producers with thoughtful and timely responses.
STREAMLINED AUDIT
Our external audit concluded with an even smoother process than in prior years and our finance team remains committed to timely internal stakeholder reporting and analysis. We will be looking to accelerate this in 2024, while building a 5-year vision and financial plan for eTracks in 2024!
ADAPTING & BUILDING A BETTER BUSINESS
NEW FOUR-YEAR DIRECT HAULING & PROCESSING CONTRACTS
At the start of 2023, our team began the process of re-negotiating new hauling and processing contracts. We used this as an opportunity to update many of the features in previous agreements to increase accuracy and efficiency.
Updated hauling zone and rate structures to ensure haulers were incentivized to collect tires from the entire province, including remote areas.
Increased our hauling rates twice during the year and continued to provide a fuel surcharge benefit to offset increases in both gas and diesel fuel.
Implemented a central scheduling system across our processor network so all haulers would have options to deliver tires.
Engaged haulers to ensure our rates and zoning structures were in line with the market and functioning as intended; saving time and fuel without compromising on hauling or the flow of end-of-life tires in the province.
SOFT CRUMB MARKET & REDUCED PROCESSOR CAPACITY
A soft crumb market had many processors slowing their intake of tires, leading to unreliable processing services. In addition to this, multiple processors dealt with unforeseen maintenance issues, fires, and one facility permanently closed in November 2023. As a result, some areas of the province experienced a slowdown in tire collection during peak winter season, prompting us to implement a variety of solutions to keep tires moving.
HOW WE KEPT TIRES & HAULERS MOVING:
Throughout November we deployed 25, 53-foot trailers around the province to provide additional consolidation and staging points for haulers to deliver tires; ensuring that collection sites continued to be serviced in spite of processor challenges.
Our team sourced and contracted with a new, large capacity processor in midDecember, offering both cost savings and greater resource recovery. In working with this processor, we found new opportunities to increase circularity, with our tire materials going back into the tire manufacturing process and moving up the value-added ladder of recycled material use.
TRACKING FORWARDS & BACKWARDS
THROUGH THE SUPPLY CHAIN
We made several enhancements to our eSRP platform, including: making it accessible from the Apple App Store and Google Play Store, and enabling a feature that allows users to trace tire shipments backwards and forwards, with real time traceability – such as linking tire shipments to after-market materials.
Digital transformation continues to be top of mind, not only from a business perspective, but also through the lens of sustainability. As tire management practices advance around the world, understanding what and how material moves through the supply chain becomes increasingly important to the resource recovery process, avoiding emissions and spurring innovation.
Managed 125,000 transactions in 2023
Managed more than 7,400 eSRP platform participants
Completed second successful performance audit since going live January 1, 2021
Enhanced audit and traceability functionality
Enhanced security and digital access policies
CREDIT PURCHASES & MEETING THE 100% COLLECTION REQUIREMENT
Year-end is typically when PROs start discussing the buying and selling of credits; something that every tire PRO has done each year. We negotiated with all tire PROs to buy and sell collection and recovery credits – offering comparable prices to what we are currently paying service providers, including increases for fuel and inflationary pressures.
KICKING OFF OUR FIRST HAULER SUMMIT
If there’s one thing we’ve learned over the last five years, it’s that communication and engagement with our stakeholders, including staff, customers and service providers – is extremely important.
Processor challenges throughout the year made it even more crucial for our team to bring our haulers together for a face-to-face event.
WHY WE DID IT:
1 2 3
Improve our communications and relationship with haulers.
Engage with haulers in a way that allowed us to land our messages around compliance, while also allowing them to be heard in a forum where their input and ideas were welcome.
To collaborate in problem solving and actually making the tire recycling system better.
We offered three sessions for attendees focused on operational improvements, understanding compliance, and establishing new and better ways to communicate.
Our inaugural event received a 100% satisfaction rating from attendees and produced many actionable items that improved our service delivery.
Photos to the left: Hauler attendees joined us from across the province at the Nottawasaga Inn and Resort to network and learn at the 2023 Hauler Summit.
INDUSTRY ENGAGEMENT & COLLABORATION
WHAT WE IMPLEMENTED AS A RESULT OF THE 2023 HAULER SUMMIT:
• Text message notifications: the introduction of text notifications ensured processors were able to communicate unforeseen events and closures to eTracks and haulers in real time. Prior to this, eTracks and haulers would find out about a closure hours after it had occurred, or upon arrival at the processor gatehouse. In addition to this, eTracks now has the ability to text service providers on other urgent issues, saving time and resources.
• Support for collection site enrollment: we created short, postcard-sized print and digital handouts for haulers and eTracks’ field investigators to give to collection sites outlining enrollment steps, site requirements and how to arrange for a free tire pick-up.
• Better incentives for haulers: we implemented steps to encourage haulers to service more remote areas beyond just their preferred areas.
• Gathered feedback on the addition of switch trailers: these were placed in specific locations to ensure the continued flow of tires in the event that a processor could not accept them, reducing travel time and fuel.
• Gathered hauler feedback on implementing storage solutions: our team secured physical locations to deliver and temporarily store tires, in the event of a processor closure.
• Established a Hauler Committee: with the goal of engaging haulers in working with us to find solutions and including their feedback in our own decision-making process.
• Moved from monthly to bi-weekly invoicing for hauling, making their earnings more accessible when needed.
• Updated the eTracks’ Voicemail system: significantly shortened the voicemail options to make it easier for service providers to reach the right person while on the road.
SERVICE AWARDS & RECOGNIZING EXCELLENCE IN END-OF-LIFE TIRE HAULING AND COLLECTION
Each year we recognize our service providers for excellence in supporting a strong and sustainable tire recycling system, driving compliance and supporting our efforts to keep tires out of landfills.
Hauling companies and collection sites were acknowledged in 2023. Each winner received an award prize pack for their drivers and/or staff, along with an award certificate or plaque to showcase in their place of business.
Pictured above, William Day Construction Ltd. was the recipient of a 2023 Award of Excellence in Hauling.
ANNUAL SCRAP TIRE LIFE CYCLE ASSESSMENT
COMPARING ENVIRONMENTAL IMPACTS WITH & WITHOUT TIRE RECYCLING ACTIVITIES IN ONTARIO
The second year of the “Scrap Tire Life Cycle Assessment (LCA),” included the elective participation of seven members of the Canadian Association of Tire Recycling Agencies (CATRA). The study includes collection and analysis of participating tire recycling agencies using data spanning 2017 – 2022, and in Spring 2023, participants received their second annual individual LCA report. The engagement of a critical review panel ensured that the methodology of analysis and reporting aligns with the requirements of the International Organization for Standardization (ISO 14044).
WHAT IS AN ISO CRITICAL REVIEW?
The purpose of a critical review is to ensure studies are performed in a manner consistent with ISO methodology and best practices, and that the conclusions of a report are supported by the data used. The LCA review found that the report was in conformance with ISO standards, the methods used to carry out the LCA are scientifically valid, and the findings are supported by the information presented. Note: the provincial model and findings for Ontario were included in the scope of the critical review, the individual provincial report was not.
The following summary of the life cycle assessment focuses on data provided by eTracks for its tire recycling
activities in Ontario including: used tire collection, hauling, processing and repurposing activities.
STUDY OVERVIEW
The LCA study looks through a lens of six environmental impacts, including: global warming (climate change), smog, air particulates (human health particulates), acidification, ozone depletion, and air and water eutrophication. Results show how a TDP fares, in each of these categories, when compared to the life cycle impacts of its respective displaced material. Results also show how each TDP compares with another when it comes to ecological impacts. For each of these ecological impacts, the magnitude of avoided impacts in Ontario were at least twice the magnitude of those where new materials were used, with scores for climate change/global warming, human health (air) particulates and acidification being particularly favourable.
The six impact categories used in the study measured the emission impacts of tire recycling activities, in comparison to the emissions that would have been created if making the same TDP from new/raw materials:
(Numbers have been rounded up/down as appropriate.)
Source: Scope 3 Consulting LLC (2023), Scrap Tire Recovery and Recycling in Ontario: CATRA 2022 Scrap Tire Life Cycle Assessment
CLIMATE CHANGE/GLOBAL
WARMING (KG C02): indicates the radiative forcing potential of greenhouse gas emissions (carbon dioxide) on a 100-year timescale. With tire recycling: 54,000,000 kg C02. Without tire recycling: 170,000,000 kg C02. Total amount of avoided emissions: 116,000,000 kg C02
SMOG FORMATION (KG 03): indicates the potential creation of ground level ozone from emissions of volatile compounds that create “dirty air”. With tire recycling: 4,100,000 kg 03. Without tire recycling: 11,000,000 kg 03. Total amount of avoided emissions: 6,900,000 kg O3
HUMAN HEALTHPARTICULATES (KG PM2.5): indicates the quantity of particulate matter released into the air, adjusted for severity by comparison to 2.5-micron dust. These particles can’t be seen by the human eye but can be inhaled. With tire recycling: 30,000 kg PM2.5. Without tire recycling: 120,000 kg PM2.5. Total amount of avoided emissions: 90,000 kg PM2.5
ACIDIFICATION (KG S02): reports emission of compounds that contribute to increased acidity in the air, either by droplet or particle. With tire recycling: 240,000 kg S02. Without tire recycling: 800,000 kg S02. Total amount of avoided emissions: 560,000 kg S02
OZONE DEPLETION (KG CFC-11): describes the destruction of ozone in the stratosphere by highly persistent halogenated chemicals. With tire recycling: 46 CFC-11. Without tire recycling: 75 CFC-11. Total amount of avoided emissions: 29 kg CFC-11
EUTROPHICATION (KG N): reports environmental emissions of compounds containing nitrogen and phosphorus, which can destabilize aquatic ecosystems. With tire recycling: 17,000 kg N. Without tire recycling: 34,000 kg 03. Total amount of avoided emissions: 17,000 kg N
THE PRODUCTS MOST EFFECTIVE IN REDUCING EMISSIONS - Products that were most effective in avoiding emissions in Ontario include: re-use of used tires, re-treading used tires, crumb rubber (including fiber and acrylic sand), rubberized asphalt, moulded rubber, moulded concrete and blast mats.
RESULTS INFORM DECISIONS - The study results invite us to consider the ecological implications, along with many other factors that go into planning, decision-making and meeting compliance obligations.
CANADIAN ASSOCIATION OF TIRE RECYCLING AGENCIES (CATRA), ANNUAL MEMBERS MEETING
Pictured above: Members of the Canadian Association of Tire Recycling Agencies (CATRA) at the 2023 Annual Members Meeting in Halifax, Nova Scotia.
TRAC SUMMIT
• Tire and Rubber Association of Canada (TRAC)
• Rubber Recycling Symposium
• Sponsor and Exhibitor
SPEAKING ENGAGEMENTS
• Waste to Resource Ontario (W2RO)
• The Year Ahead Conference and Annual General Meeting (AGM)
• Speaker and Sponsor SUPPORTING THE COLLECTION NETWORK
• Ontario Tire Dealership Association (OTDA)
• Annual Golf Tournament and Fundraiser Sponsor
TIRE COLLECTION & MANAGEMENT FLOW
ACTUALLY MAKING TIRE RECYCLING SYSTEMS BETTER
