D3.3.1 SWOT Analysis of Rubberised Asphalt Mixtures

EU‐LIFE + Environment Policy and Governance

LIFE 09 ENG/GR/304 “ROADTIRE”

“Integration of end of life tires in the life cycle of road construction “

Deliverable 3.3.1

SWOT ANALYSIS

Scuola Superiore Sant’Anna (SSSUP)

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TABLE OF CONTENTS

1. OBJECTIVE OF THE STUDY ................................................................................................................................3

2. SWOT ANALYSIS: THE ORIGINS.........................................................................................................................3

3. SWOT METHODOLOGY APPLIED TO ELTS SUPPLY CHAIN ...................................................................................4

3.1. BACKGROUND...................................................................................................................................................4

3.2. METHODOLOGY ................................................................................................................................................4

4. SELECTION OF OPINION LEADERS OF THE ELTS SUPPLY CHAIN SECTOR..............................................................6

5. CONSTRUCTION OF THE ALTERNATIVES AND EXPRESSION OF THE EVALUATIONS ..............................................7

5.1 DECISION NODE 1: TREATMENT TECHNOLOGIES OF ELTS ................................................................................................ 8 5.2 DECISION NODE 2: DESTINATION OF THE TREATED ELTS MATERIAL.................................................................................. 13 5.3 DECISION NODE 3: ECONOMIC SUPPORT ALTERNATIVES FOR THE ELTS MANAGEMENT SUPPLY CHAIN..................................... 19 5.4 DECISION NODE 4: NON‐ECONOMIC INCENTIVES TO THE DEVELOPMENT OF THE ELTS MANAGEMENT SUPPLY CHAIN................. 22

6. EVALUATION PROCESS........................................................................................................................................ 27

7. SWOT METHODOLOGY RESULTS TO ELTS ALTERNATIVE RECOVERY CASES FOR THE CASE OF GREECE.................... 36

8. DISCUSSION....................................................................................................................................................... 37

9. CONCLUSIONS.................................................................................................................................................... 38

REFERENCES .......................................................................................................................................................... 39

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1. Objective of the study This SWOT analysis (Strengths, Weaknesses, Opportunities, Threats) on the End of Life Tires (ELTs) supply chain was carried out in the context of the Project ROADTIRE LIFE09/ENV/GR/000304, supported by LIFE + Program Environment Policy & Governance, in 2009‐2011 (www.roadtire.eu).

The main objective of the project is to promote the use of ELTs in the construction and maintenance of road pavements, mainly in Greece but also in Italy, with the target of both reducing the environmental impacts due to the (landfill) disposal or to the temporary stockpiling and improving the environmental and technical performances of the road construction sector.

This SWOT analysis is focused on the Italian and Greek ELTs supply chain scenario and is aimed at analyzing the potential capability of development of the ELTs recovery chain towards a correct and sustainable management system, through reliable valorization processes, both in material recycling and energy recovery. The outcome of this research is to provide the best available solutions on potential problems faced by the recycling systems in both countries.

In fact, while the installed treatment capacity (grinding and granulating) of ELTs in Italy is well above the need required by the generated amount of ELTs, the final recovery opportunities for the obtained materials are still relatively poor, resulting in a problematic management of the whole supply chain.

Currently in Italy, energy recovery is the first ELTs destination, both in national plants and abroad, while the material recycling is still somewhat limited, mainly to traditional sectors, such as sport fields, engineering applications, rubber manufactured products, etc. More alarming, is the 26% of ELTs with unknown destination, for which an urgent solution is needed.

The aim of the SWOT analysis is therefore to investigate on how the different aspects of the chain, technological, economic, regulatory and organizational, are perceived by the ELTs chain stakeholders, in order to identify the most effective development strategy to close the recovery chain.

Due to the large heterogeneity of stakeholders operating in the sector, we opted for the involvement of the relevant category associations and of those consortia established by the tires producers and importers in order to comply with the extended producer responsibility principle, which has been introduced by art. 228 D.Lgs 152/2006 and enforced in 2011, by DM 82/2011.

2. SWOT analysis: the origins SWOT analysis (Strengths, Weaknesses, Opportunities, Threats) is a largely diffused methodology in the field of strategic consultancy for the identification and the analysis of strengths, weaknesses, opportunities, and threats perceived by specific stakeholders regarding project hypotheses and predefined development areas.

In management sciences this technique is often used in complex contexts, where choices have multidimensional characteristics (i.e., technical, organizational, economic, environmental aspects) and both the boundary conditions and the internal features of the project are to be investigated.

The development of methodologies for a SWOT analysis started in 1950s (Smith, 1951) and continued in the

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following decades (Andrews, 1971), with the involvement of both the academic and the consultancy community. In particular, efforts were made for the definition of protocols for an objective and reproducible acquisition of internal factors (strengths and weaknesses) and external factors (opportunities and threats), for the achievement of a shared opinion of the proposed scenario.

The main critics to SWOT analysis (Hill et al. 1997) are related to the difficulty in achieving a sound method for the prioritization of strengths, weaknesses, opportunities and threats, and to the possible biases due to the different perception of the respondents towards future, i.e. foreseen as carrier of threats or opportunities. Therefore, several schemes have been proposed to better support planning processes, in particular focusing on the possibility to gather detailed and systematic data, able to describe the external and internal environment of the project.

3. SWOT methodology applied to ELTs supply chain

3.1. Background The SWOT report focused on Italy where the supply chain is more developed. Nevertheless Greek partners supplied the Italian ones with information (national level) on the existing opportunities. The blending of the information contributed to the development of the alternatives (presented in chapter 5). The stated limits and specifications are based on adaptation of EU legislation (common for both countries). Additionally the case of pyrolisis and combustion as recovery options for Greece are presented due to the recent public discussion of it in Hellenic technical and political meetings.

3.2. Methodology Important elements have been considered during the development of this SWOT analysis: - Selection of relevant opinion leaders in the ELTs sector; - Inclusion of all the relevant issues - Consideration of the different opinions within the community. Opinion leaders were mainly chosen among the category associations and those consortia involved in the ELTs management. The analysis of ELTs chain development perspective was based on the following aspects: - Identification of alternative paths and potential articulation of the chain; - Identification of internal and external factors, able to affect the success of one alternative instead of the other;

- Identification of the stakeholders’ perception and achievement of a shared evaluation with the prioritization of registered points.

- Discussion and sharing of strategies for the success of the chain.

The first step is a qualitative investigation, based on interviews to the opinion leaders, carried out according to the same scheme in order to have a uniform approach and to be reproducible, to collect opinions on alternative paths and relevant factors for their success. In a second step, single factors scores were attributed from the average and the width of the recorded values (media; min; max). These data allow, during the interpretation step, to integrate the quantitative model with a qualitative analysis of the

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scenarios. The potential supply chain development is described through alternatives for a set of key and independent decisions. N (= four) decision nodes were identified as the different variables to which a (= four) alternatives for the chain development are attributed. Therefore, a*n determinants represent the dimension of the morphologic space of the possible supply chain configurations (Figure 1). Each alternative configuration was established through a decision itinerary defined by n linguistic descriptors (one for each cardinal point).

Then the scores relative to the SWOT parameters for the n*a (=16) determinants have been attributed as well as the compatibility parameter C, which allows the elimination of inconsistent chain itineraries. A criterion for exclusion is defined by the constraints which make unrealizable several groups of solutions.

Each interviewed opinion leader was asked to express scores to the different alternatives keeping in mind the objective of a sustainable development of the national ELTs recovery chain (therefore rejecting possible speculative or short‐term strategies).

Figure 1. Scheme of SWOT analysis through itinerary aggregation

SWOT parameters and C compatibility factors have been attributed according to the following schemes:

SWOT Parameter Description

1 The parameter is absolutely non‐relevant for the strategy definition

2 The parameter is not particularly relevant for the strategy definition and determines non relevant effects.

3 The parameter is important for the strategy definition and determines relevant but not certain effects

4 The parameter is important for the strategy definition and determines relevant but and certain effects

Parameter C Description

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0 Unsubstantial alternatives: the occurrence of the first alternative prevents the occurrence of the second one

0,5 Compatible alternatives but reciprocally weaken each other

1 Substantial alternatives: the occurrence of the first alternative allows the regular occurrence of the second one

2 Substantial and synergic alternatives

By combining the qualitative variables as described in the tables above, the a*n determinants are described with a value parameter and a compatibility parameter. In a non‐reductionist perspective, the scores interpretation step is aimed at the definition of a development alternative for the supply chain, which better fits the point of view and the expectations of each stakeholder (i.e., risk propensity, short or long term perspective).

4. Selection of opinion leaders of the ELTs supply chain sector During the research phase of Action 3.1 (Market analysis) of Roadtire project, SSSUP has described the structure of the Italian ELTs market and its operators. The network developed includes both companies operating on the Italian market and other relevant stakeholders, such as category associations and consortia established for the application of the producers’ extended responsibility principle. SSSUP maintained contacts with these stakeholders in order to monitor the dynamics occurring after the approval of DM 82/11, which enforces the art. 228 del D.lgs 152/06 establishing the EPR principle. Since then, the producers and importers of tires are obliged to manage an equal amount of ELTs to that introduced on the national market. Several organization, with different juridical status, have been established and registered to the Ministry of Environment (MATTM). The largest organization present in Italy is Ecopneus, established in 2009 by the major tires producers (> 90% of total market). Other organizations, such as Greentyre Scrl (established by the largest tire importers) and Ecotyre Scrl, started their activity more recently and although manage smaller amounts of ELTs are also of great interest.

On the other hand in Greece Ecoelastica runs the total ELT collection/recover/recycling processes and figure below presents the overall statistic data for 2011.

The ELTs supply chain consists in the following steps: 1. Waste generation; 2. Collection, transport and selection; 3. Milling (shredding and rubber particles production); 4. Valorization (rubber recycling plants).

ELTs as waste can be produced in any place where tire replacement occurs, including tire dealers, petrol stations, garages etc.. ELTs are then collected and transported by companies authorized for the management of this type of waste and usually conferred to shredding and milling plants. The type of milling occurring in this phase is functional to the following valorization step: for the energy recovery, coarse shredding is sufficient in order to reduce the size of the tire, while for material recycling, granules and powder are usually produced.

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Energy recovery occurs mainly in cement kilns, while recycled material is often used in the sports fields.

As a consequence, the type of companies involved along the ELTs chain is extremely varied in terms of size, type of activity, market position etc. For instance, the number of collectors nationwide is about 7000 companies, and very often this is not their only business. The number of milling companies is about 90 nationwide, although this number is continuously fluctuating.

Due to the large complexity of the companies involved in this sector, we identified those stakeholders, which could represent the point of view of a whole category, such as:

‐ Federazione Gomma Plastica : National federation of rubber and plastics manufactures ‐ Unirigom and Argo: Category associations of companies dealing with ELTs recovery and recycling ‐ AIRP: Italian association of tire retreaders ‐ FEDERPNEUS: National association of tire specialists (retailers) ‐ Consortia or organizations established for the ELTs management (according the EPR principle) However, only three organization turned out to be available to be involved in this study: Ecopneus and Greentyre scrl (ELTs management organizations) and Unirigom (ELTS recycling category association).

5. Construction of the alternatives and expression of the evaluations

In a first step, the decision nodes for the potential development of a sustainable ELTs supply chain were elaborated. The alternatives were then proposed on the following four decision nodes:

1. Treatment Technologies of ELTs

2. Recovery alternatives for the treated materials

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3. Economical support to incentivize the supply chain

4. Institutional support to incentivize the supply chain

For each decision nodes, four alternatives were proposed in order to define possible independent itineraries for the supply chain.

5.1 Decision node 1: Treatment technologies of ELTs The stakeholder should express his/her position regarding the contribution of different technologies to the sustainability of the ELTs supply chain. These technologies should be evaluated in terms of their capability to yield suitable products that meet the requirements of the market for both the energy and the material recovery.

Alternative 1: Mechanical (and non mechanical) treatments, which produce granulate and/or powder compliant with high quality standards (impurities content, granulometry), according to the Technical Specification CEN TS‐14243. I.e., the application of high‐quality room temperature mechanical processes or cryogenic processes STRENGTHS Score WEAKNESSES Score

►High quality and cleaness of the separated components

Mechanical plants:

‐ Companies provided with high quality mechanical plant working at room temperature (recently installed or adapted) that are flexible and able to satisfy the request of high standard products from the market. For instance, Kall plants are excellent mechanical plants with lower energy consumption and components wear and their cost is decreasing due to the increase demand of this type of plants.

Cryogenic:

‐ The technology is able to produce extremely fine powders and clean metal

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Mechanical plants:

‐ Significant investments are required to improve the quality production of existing plants, increase their flexibility, and provide continuous maintenance. Very often these costs are not bearable by the plants owners.

Cryogenic:

‐ Costs are very high and currently products have no market since there is no demand yet. Plants having the cryogenic module prefer not to use it.

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OPPORTUNITIES Score THREATS Score

‐ The production of high quality standard material allows the company to satisfy the market requests and to remain competitive. A correct management of the plant moreover allows for a quality improvement and also for consumptions reduction.

Cryogenic:

1. The fine powder obtainable with the cryogenic treatment could favor new applications (i.e. thermoplastics production); also the high quality metal scraps could be used for new applications.

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General considerations

1. The market demand of high quality standard materials may lead to the exclusion of those companies unable or unwilling to make investments to improve the technical aspects of their plants and to make efforts to place their products on the market.

2. Lobby action may occur from the virgin raw materials producers to prevent the achievement of a certification for the secondary raw materials, which is considered a threat since it may lead to equalize SRM with virgin raw materials

Cryogenic:

1 High production costs and failed valorization of the products on the market would prevent this technology from being sustainable and attractive for new investors and therefore hinder its diffusion. Rubber powder should be sold at 8‐900 euro/kg in order to make the technology sustainable.

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Alternative 2: Ordinary mechanical treatment yielding current average quality material, granules and powder. i.e. the maintenance of the current status of the Italian treatment plants where, on average, little attention is paid to the quality of the process outputs (size and quality)

STRENGTHS Score WEAKNESSES Score

Maintenance of the status quo of the average Italian plants

Diffusion on the national level of the treatment capacity

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1. Nationwide presence of non suitable technologies and non flexible plants, which spread in the past years due to the availability of incentives and the proposal by the plants producers of untrue business plans for their plants.

2. Total absence of a market analysis for the products and frequent inexperience of the operators.

3. Market saturation of these products: they are often sold on foreign markets to overcome the difficulties to be sold in Italy for their low quality.

4. A large number of extemporized plants producing low quality materials is a threat for skilled operators.

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1. Adequate investments and market analysis allow the mechanical treatment operators to succeed on the National market

2. The current market of standard materials by performing a market analysis could be expanded

3. The increase in offer should increase in quality of the materials

4. Plant verticalization, integrating the treatment and the valorization steps by increasing the organization size, will allow to control directly the final destination market, thus avoiding the current bottleneck.

5. Improvements in the material recovery plants will be possible with the cogeneration of energy from the production scraps

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1. Lack of investments to improve the plant performances would maintain a low quality production, which does not match the requests of the market and thus would contribute to the quick saturation of the low quality secondary raw material (granules, powder) market

2. The permanence of operators with low performing plants until the achievement of their ROI may cause serious problems to the survival of skilled operators

3. The possible market saturation for the secondary raw material may cause a decrease in input amounts of ELTs to the plants, provided by the Consortium Ecopneus system. This can harm those operators who have invested for improving their plants.

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Alternative 3: Devulcanization technologies (rigeneration) I.e. all the processes yielding devulcanized (partially or wholly) rubber, by breaking the sulphuric bonds created during the rubber vulcanization process. At present, the Water Jet (High Pressure) technology is considered to be very promising since during the pulverization of the rubber it provides also a significant percentage of devulcanized material, without the use of additional chemical or biological reactants. Also micro‐wave technology is considered very promising. These technologies allow to open new application sectors especially in blends, thus completely recycling the polymer. STRENGTHS Score WEAKNESSES Score

The introduction of new technologies is an obligation which should be carried out in parallel with the renovation of old plants.

Devulcanization (in general):

1. It is a key solution, which provides relevant changes in the market of virgin raw materials, as a consequence of their increase in price and difficult availability.

2. Production of secondary raw materials with a wide range of applications

HPWJ: leads to the pulverization and to a partial devulcanization in the same process, thus avoiding the use of chemicals; it is used/useful for the treatment of oversize ELTs. Lower wear of the plant. (still experimental)

MW: At experimental level it seems possible to devulcanize the surface of rubber granules.

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►These technologies are still in an experimental stage

► A consistent investment by the company is needed to start these technologies.

1. Currently, the regenerated polymer is mostly produced in India and Far East, where energy costs are lower and environmental legislation is less stringent than in Italy (and Europe). The costs would be 5‐10 times higher and would be charged on the final price of the product (environmental dumping)

HPWJ:

1. The technology is still experimental and operates at very high pressure and with extremely high energy consumption. It is only used for oversize ELTs (agricultural tires) and not with car tires.

2. The obtained product is not compatible with any standards and not appealing for the market (it is a wet powder). The technology is unable to separate the textile fraction. The energy consumption is not sustainable.

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HPWJ:

1. If correctly managed, it would be able to produce in a single step a partially devulcanized and already reactive rubber powder.

2. Expansion of the application fields of secondary raw materials: the market for these powders should be enhanced, in order to diversify the application and close the supply chain .

3. It would give the possibility to substitute virgin raw materials which are more and more costly and rare

4. The success of one technology with reasonable costs will favor the success of devulcanization (i.e., the water jet)

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►Competition for price/quality of the virgin raw material would hinder the development of this sector

1. Low chance to access those application fields where the technological requirements are particularly stringent

2. Little psychological acceptance of recycled materials for some applications

3. Competition of the Far East production may not allow the evolution of the local production in Italy, which results less competitive.

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Alternative 4: Mix of the previous alternatives


►More flexibility in the technological offer

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►Little influence on the development of specific policies

Absence of a ‘silver bullet’ technology, which can close the loop of the supply chain

Need to overcome the experimental stage of some technologies

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►Lower dependence on specific sectors

►Absence of lock‐in in the future chain evolution

Natural selection of operators based on the quality of their products

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►Absence of critical masses of investments in order to guarantee the technological development of the chain options.

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5.2 Decision node 2: Destination of the treated ELTs material In this decisional node, the contribution of the different final destination options for the treated materials is evaluated. The focus is set on those activities, which may provide a large capability to treat a large amount of ELTs

Alternative 5: Use of powder recovered from ELTs in the tire manufacture and in ‘high performance’ blend in general (close loop supply chain) I.e. this alternative considers the use of ELTs powder in the tire production processes and in blending processes for high performance blends.


Recycling in the tire manufacture

1 Close loop supply chain

2 Green marketing for the tire manufacturers

3 ELTs powder can be used up to maximum 7‐8% in some parts of the tire. It is conveniently used only when virgin natural rubber price increases.

High tech blends

The recycling in high‐tech items where high performances are required (windscreen wipers, gaskets etc.) suffer from similar drawbacks of tire manufacture.

Low‐tech blends

The use of devulcanized rubber allows for lower amounts of binders and therefore lower costs. Low tech blends have more chances to be accepted by the market than high tech blends. Moreover, new material characteristics can be achieved for instance higher elasticity due to the lower amount of binders can be useful for new applications.

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►High costs for the development of new blends, with respect to consolidated blends.

Recycling in the tire manufacture

1. This close loop re cycling is hindered by the complexity of the testing phase of these new materials, which are must guarantee excellent technical performances. Therefore it is difficult that this sector is able to absorb large amounts of material.

2. At present, it is possible to use only up to 7‐8% wt of ELTs rubber powder and only in specific parts of the tire.

3. At present, the economical advantage is not significant

Blends

1. At present, the devulcanized material comes from the Far East is not qualitatively equal to the virgin raw material

2. It is difficult to introduce modification to processes which are consolidated by blends producers and customers both for high tech and low tech blends.

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1. The close loop recycling would help solving the ELTs management issue, considering the global amount of produced tires

2. The success in recycling in tire and blends manufacturers would be a powerful driver for the whole chain.

3. The use of regenerated powder would foster new applications for blend recycling

4. The economic advantage, occurring in case of price increase of natural and synthetic rubber, and the better performances would help the success of devulcanized rubber powder in blends

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1. The failure of performances of materials containing regenerated ELTs rubber powder with respect to traditional materials would jeopardize the supply chain thus, hindering the success of these applications.

2. Natural selection of those operators in the supply chain unable to keep pace with the technological evolution

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Alternative 6: Material recycling in applications such as civil engineering, street furniture, rubberized asphalts, rubber playgrounds, sport fields, etc.

I.e., all those applications, which are, more or less, currently diffused.


►The variety of applications allows for the placement of different quality materials secondary raw materials

1. Excellent performances in all the applications: improved performances of sport grounds, of railroad antivibration rubber, of quality and life time of rubberized asphalts.

2. The costs of these established applications are reasonably cheap.

3. The material recycling applications are compliant with the priorities set by the European environmental legislation

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1. Rubber powder is often used only as filler and therefore in small amounts

2. Sports ground application in Italy require the painting of the granules surface (due to potential cancerogenicity of the material)

3. The operators in the sector of asphalts and antivibration structures are not interested in improving the quality and the duration of their products and therefore do not cooperate for the diffusion of these applications

4. The National market of most of these items is limited and often dependent on the financial availability of local municipalities (since most of these applications fall within the municipalities responsibility), which has been restricted by the ‘Patto di stabilità’ and the general crisis trend

5. Very often these manufactured products are produced in China and in the Far East and are sold on the Italian market with lower quality but more competitive prices than those produced in Italy.

6. The current configuration of the EPR system, mainly dominated by Ecopneus consortium, does not favor the material recycling with respect to the energy recovery

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►Diversification of the potential application fields

1. The use of ELTs rubber powder in new blends and in rubberized asphalts would be the two main drivers of the material recovery

2. New potential application of the rubber granules may occur in the acoustic insulation field, in case of implementation of the obligation of a acoustic certification of buildings (as it occurs for the energetic certification)

3. The consolidated applications may be supported through investments aimed to the integration of the treatment and valorization steps in the chain.

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1. Currently it is difficult to provide incentive to the material recovery applications due to the present and future preponderance of the energy recovery sector

2. In case of little innovation and development of new blends applications the current market may face easily a saturation situation

3. The competition of the Asian countries may hinder the success of the Italian operators thus yielding negative consequences for the National (i.e., occupational) production and for the global environmental performance of the sector.

4. The rubberized asphalt application of ELTs rubber powder may be hindered by SBS rubber producers and in general by any kind of binders producers, which are competitors on the market.

5. New materials are competing for the sports fields applications

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Alternative 7: Energy recovery in cement kilns, thermoelectric plants, pyrolisis plants etc. I.e. all the Energy recovery applications are considered here


Cement kilns:

1. This is a simple and cheap technology that allows to treat large amounts of ELTs with energy recovery, therefore contributing significantly to close the loop of the supply chain. The energy recovery is a relief valve to avoid the material recycling market

2. Better economical conditions for the ELTs supply to the plants have been achieved with the intermediation role of the consortium, which has more contractual power with the large cement kilns.

Pyrolisis:

1. It allows for obtaining chemical intermediates for the production of energy

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► Limited environmental performances

Cement kilns:

1. Only few cement kilns are present nationwide (2 plants Marangoni and few smaller cement kilns). They are not used for lime production (since the color of the product is affected) and are seldom used for waste co‐incineration to increase the CP of waste. Globally, the energy recovery options in Italy are currently quite limited

2. The strict environmental legislation prevents from the diffusion to other energy recovery options nationwide.

3. A large percentage of the ELTs are exported for energy recovery to Far East countries and north Africa.

4. The current (and past) large environmental contribution which is due by the tire buyers does not correspond to the large predominance of a low tech technology, such as incineration, to close the loop of the ELTs supply chain.

5. The large application of energy recovery hinders investments in the material recycling applications

Pyrolisis:

1. Currently, there are no commercial plants: the experimental ones are not auto‐sustainable since their management is too costly

2. Gas, oil, char products are difficult to manage and often require an additional purification step, which is complicated and expensive

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Pyrolisis:

1. Potential production of fuels, which could be used to feed the process itself thus decreasing the energy consumption and production of other chemicals

2. It could be a suitable alternative to solve some specific situations: for instance the management of ELTs in Sardinia.

Incineration

1. If the rate of ELTs incineration in Italy achieves the average European, the amount of ELTs destined to energy recovery would rise up to 150000 ton/yr and the export would be avoided.

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Incineration

1 A decrease in the ELTs incineration amounts can be faced in case of construction sector crisis and in case of stricter environmental regulation. These factors would favor the export to Far East countries and north Africa

2. The economic support of the incineration sector hinders in the long term investments in more complex sectors such as the material recovery and even may penalize them.

3. Regulation evolution may hinder the export abroad.

4. Regulation evolution may incentive the material recycling, in coherence with the European priorities

Pyrolisis:

1. The average operators in Italy do not have adequate technical and managerial skills to run such complex plants

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Alternative 8: Mix of the recovery alternatives listed before


►Complementary and integrated alternatives

Diversification of final market destination of the materials

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►Absence of a stimulus to incentive one sector with respect to the others 3


►Subsidiarity of different sectors

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►The competition among different sectors may hinder the development of each valorization sector (dispersion of capital investments)

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5.3 Decision node 3: Economic support alternatives for the ELTs management supply chain

This node focuses on the possible economic support actions, connected to the implementation of the EPR system, which may help stimulating the sustainability of the ELTs supply chain.

Alternative 9: Economic incentive proportional to the amount of treated ELTs

This incentive is proportional to the treated amounts, independently from the technology used and the final destination of the secondary raw materials. It does not consider the technological innovation or the environmental impacts connected to the technology.


The incentive proportional to the amount of treated ELTs is useful to close the loop of the supply chain

The input amount of ELTs is guaranteed to those organization that demonstrate the actual destination of their product.

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►Adverse selection of those who invest in technological innovation

Penalization of material recovery activities with lower treatment capacity in favor of incineration plants, treating larger amounts.

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►Strong stimulus to close the chain as requested by the National legislation

►Incentive to manage and reduce the historical stocks

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Incentive to a management supply chain which is not environmentally sustainable, not enough diversified and discouraging with respect to more innovative technologies

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Alternative 10: Economic incentive proportional to investments in research and development aimed to the development of innovative technologies and to the development of final applications and market penetration by the products

This incentive is proportional to the effort of the companies to improve their technological assets and the placement of their products in the final market (i.e., by obtaining a high standard quality secondary raw materials, which can be easily placed on the market).


Ecopneus can provide a guaranteed input amount of ELTs to those plants, which are more innovative in technologies and which are already integrated in the valorization step thus allowing for the supply chain sustainability, especially in some areas which are otherwise difficult to manage. Often these organization have also the best offers in terms of efficacy and efficiency and thus can win the supply selections.

Support to R&D projects, which ground on the market requests

Support to the improvement of plants

Support organisations doing market analysis

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Fragmentation of research activities and non synergic exploitment of investments

Few organisations carry out R&D and ask for support for concrete projects to the consortium

Support is often given to research projects, which are not relevant to the market

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►Boost the engagement of partnerships along the supply chain, by reducing the costs of products’ market penetration ‘ at National and International level.

1. Support to the recycled products by reducing the VAT: this could also boost the local municipalities to green procurement

2. Support to the products standardization procedures, to facilitate their market penetration

3. Incentives to companies committed in the product placement on the market: this would contribute to increase the profit margin of the products thus helping reducing the environmental contribution at the entrance gate

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1. Contributions may shift investments to technologies which are innovative but have a limited treatment capacity to absorb the ELTs amounts needed to close the supply chain.

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Alternative 11: Economic incentive proportional to the ecological footprint of the applied technology

I.e. This criterion is based on the ecoprofile evaluation of the final product (i.e. LCA )


►Coherence with the European policy on waste

1. In general, any ELTs management approach with respect to landfill disposal (not to speak about the illegal dumping) is advantageous from the environmental point of view and should therefore be supported: the environmental benefits are evident both in the material recycling and in the energy recovery

2. Often more efficient plants are also more environmentally performing and thus truly competitive.

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1. Environmental criteria are not currently a driver for investments

2. Lack of acknowledgment of the recycled manufactured products and acceptance on the market (the origin of the secondary raw materials is often hidden and not advertised)

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►Valorization of ecological footprint on the green purchase markets (es. GPP)

The incentives should be coherent with the waste hierarchy, as indicated by the EU

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Little acceptance from the market of green labels for recycled products.

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Alternative 12: Mix of the economic incentives listed before


Presence on the market of technologies having heterogeneous features

3 Less selectivity in the choice of technologies 3


Larger diversification of potential technological trajectory

3 Lack of interorganisation alliances on strategic objectives

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5.4 Decision node 4: Noneconomic incentives to the development of the ELTs management supply chain

These types of incentives should support the market of the materials obtained from ELTs treatment operations, through institutional tools which can favor their competitiveness

Alternative 13: Inclusion of ELTs recycling products in the green public procurement.

GPP, (green public procurement), is an environmental policy voluntary tool that intends to support the market of products and services with a low environmental impacts, by exploiting the public demand from local administrations, which have the duty to buy a certain percentage of products obtained from recycled materials (D.Lgs 163/2006 e DM 203/2003). Rubberized asphalt containing ELTs powder rubber, sport grounds made with ELTs rubber granules, street furniture etc., are the most interesting application in this field


►High guarantee of placement of recycled products on the market

GPP:

1. It is both a protection and incentive tool

2. It is the only tool that can favor the ‘made in Italy’ without applying customs duty

4

GPP:

At present it does not work properly since it is neither compulsory nor rewarding

The definition of the minimal environmental criteria for the different items is a slow process due to the lack of will of the involved stakeholders, who are not efficiently coordinated

Incapacity and lack of will of the stakeholders of different sectors to boost this process

4


23

The actual implementation of GPP would be useful to boost the final application of ELTs deriving materials, which often are within the competences of public administration. It may be useful in order to change mentality of the public administrators so that they could be apply as routine the green purchasing.

The GPP implementation would increase the competitiveness of Italian products over the foreign ones, which usually have a larger ecological (carbon) footprint and lower quality.

GPP: it will finally promote the material recycling activities, by providing more certain final applications and thus overcoming the bottleneck of the whole management supply chain.

GPP for roads: should boost roads showing better performances and long term costs for the local administrations; the diffused application of rubberized roads would be a great contribution to the MATTM to solve the problems connected to the ELTs final destination.

4

The definition of GPP on roads faces problems due to the difficulty in defining truly rewarding characteristics of the specific material (parameters should be set in terms of technical performances rather than in the type of material). Once the materials are defined, high chance of failure of this sectors could be faced in case the operators are not able/willing to work with rubberized bitumen.

The still delayed implementation of GPP does not help the Italian production towards the competition of products from China and the Far East. The absence of GPP for the road asphalt prevents even to reward the environmental benefits connected with saving raw materials for the construction or for the maintenance

Lack of political will to carry on the insertion of new items in the GPP list.

3

Alternative 14: The clear application of relevant environmental regulation for the ELTs supply chain. I.e. the clear application of ‘end‐of‐waste’ mechanism would allow the trade of granules and powder (nationwide and internationally) without the obligations imposed by the waste regulations, and would make it much easier the diffusion of these materials. Also the dispensation of REACH regulation, as foreseen for the MPS deriving from waste, should be made clear. The present uncertainty of regulation is a serious hurdle to the functioning of the ELTs recovery system.

24


EPR decree is already an excellent contribution to the management of this recovery chain, which so far had no set rules.

End of waste: the clear application of end of waste mechanism simplifies the organization activities

Standard: the diffusion of quality standards contributes to establish a common language among sector operators and it allows also the acknowledgment of the recycled origin of the materials.

Regulation: current regulation does not hinder the production of secondary raw materials and it allows also the protection of organizations

REACH: it is not applied in the sector since the operators do not carry out a chemical modification of the materials

3

Problems connected to the modification of art 181 on the secondary raw materials definition.

Problems derive from the incoherency of regulations and authorizative procedures over the Italian territory (i.e., some activities are allowed in some areas and forbidden somewhere else)

Restrictive limits for the use of ELTs in incineration.

Restrictive limits for the export activities.

TS14243 standard defines only a measurement methodology and does not set limits, thus not defining a proper classification. Lack of knowledge of standards by the control authorities makes the communication difficult.

The EPR decree is not largely shared among the sector operators. Moreover it is not coherent with the European legislation in terms of waste hierarchy (material recycling first), since it does not foresee the integration of the final applications within the management chain. This may lead to a saturation of the final market applications and the blockage of the whole management chain. The ELTs incineration will then be favored since it will bring relief to the chain management.

3


25

1. Less regulatory uncertainties in the legislative and administrative fulfillments would give a boost to more regular activities in the sector.

2. The application of diffused standards would ease the trading of the materials in Italy and abroad

3. The homogenization of authorizative documents would make it more easy to operate in the sector (i.e., plants, customs, harbors)

4. The sharing of a common language among operators and authorities would make it more easy to operate in the sector.

4

End of waste decree is awaited. Depending on the definition regarding the ELTs (exclusion of ELTS), it will increase the export of materials because it will be more difficult to operate nationwide for both the material recycling and energy recovery.

Standard: the lobby of virgin raw materials producers may oppose to the setting of a standard with limits, in order to exclude these materials from the market competition.

Administrative simplification may cause the proliferation of companies in the sector.

3

Alternative 15: Provision from the public bodies of economical incentives, financing new plants etc. to support the development of the ELTs management supply chain


►Boost of R&D activities in the organizations

(Ecopneus) Support for the chain quality certification as a marketing tool as well as a boost for increased quality production by operators

2

►Incentives given to old plants producing low quality materials, which are difficult to place on the market

4


Support will be effective in case it is given only to those organizations providing innovative technologies

Support will be effective if given to those organizations making efforts to penetrate the application markets

Support should be guaranteed to those organizations which are capable to manage large amounts of ELTs but especially to those who innovate in treatment technologies and in applications

2

Lack of initiative by the single organization

3

26

Alternative 16: Mix of the above mentioned tools


►Limited dependence on the availability of resources

►Balanced resolution of the different constrains to the development of the supply chain

3

►Complexity in the coordination and promotion of the single supporting actions

►Complexity in the evaluation of the different options by smaller and less structured companies.

3


►Possibility to correctly help the development of the chain by efficiently intervene on the different axes, according to the acquired experience 3

►Potential reciprocal weakening of support tools having different focus

► Potential excessive impact on the natural development of the market (introduction of a lock‐in in the technological trajectories)

3

As regards the compatibility factors among the above described alternatives, the following table reports the score assigned to the elements of the matrix, which is symmetric with respect to the diagonal:

Alt. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

1 X X X X 2 2 1 1 2 2 1 1 2 2 1 1

2 = X X X 0 0.5 0.5 0.5 1 0 0.5 0.5 0.5 0.5 0.5 0.5

3 = = X X 2 1 0.5 1 1 2 1 1 2 2 1 1

4 = = = X 0.5 1 1 1 1 1 1 1 1 1 1 1

5 = = = = X X X X 0.5 2 2 1 1 1 1 1

6 = = = = = X X X 0.5 2 2 1 2 2 1 1

7 = = = = = = X X 2 0.5 0 0.5 0 1 0.5 0.5

8 = = = = = = = X 1 1 1 1 1 1 1 1

9 = = = = = = = = X X X X 0.5 1 1 1

10 = = = = = = = = = X X X 2 2 1 1

11 = = = = = = = = = = X X 2 1 1 1

12 = = = = = = = = = = = X 1 1 1 1

13 = = = = = = = = = = = = X X X X

27

14 = = = = = = = = = = = = = X X X

15 = = = = = = = = = = = = = = X X

16 = = = = = = = = = = = = = = = X

6. Evaluation process The decisional process has been divided in 4 thematic nodes with a total of 16 alternatives as follows:

List of the alternatives

N° node N° alternative Title

Treatment Technologies of ELTs

1 1 Mechanical (and non mechanical) treatments which produces granulate and/or powder compliant with high quality standards (impurities content, granulometry) according to the Technical Specification CEN TS‐14243.

1 2 Ordinary mechanical treatment yielding current average quality material, granules and powder.

1 3 Devulcanization technologies (rigeneration)

1 4 Mix of the previous alternatives

Destination of the treated ELTs material

2 5 Use of powder recovered from ELTs in the tire manufacture and in ‘high performance’ blend in general (close loop supply chain).

2 6 Material recycling in applications such as civil engineering, street furniture, rubberized asphalts, rubber playgrounds, sport fields, etc. .

2 7 Energy recovery in cement kilns, thermoelectric plants, pyrolysis plants etc.

2 8 Mix of the recovery alternatives listed before

Economic support alternatives for the ELTs management chain.

3 9 Economic incentive proportional to the amount of treated ELTs

3 10 Economic incentive proportional to investments in research and development aimed to the development of innovative technologies and to the development of final applications and market penetration by the products

3 11 Economic incentive proportional to the ecological footprint of the applied technology.

28

3 12 Mix of the economic incentives listed before

Non‐economic incentives to the development of the ELTs management chain

4 13 Inclusion of ELTs recycling products in the green public procurement.

4 14 The clear application of relevant environmental regulation for the ELTs supply chain.

4 15 Provision from the public bodies of economical incentives, financing new plants etc. to support the development of the ELTs management supply chain

4 16 Mix of the above mentioned tools

Two itineraries are preferred for the compatibility and they share three nodes out of four, highlighting the coherence towards developing material recovery alternatives, by improving the pre‐existing mechanical treatments plants (alt. 1), by supporting the already consolidated material recovery applications and also by boosting those options that are not established in Italy yet, but could however bring a significant contribution to the material valorization sector such as, for instance, rubberised asphalts and new blends (alt 6). These itineraries would be supported by economical incentives given preferably to those organisation that are more active in technological innovation and in scouting opportunities in the market for their recycled products (alt 10). Also non economical incentives would be greatly helpful, such as the implementation of GPP and the sound application of environnemental legislation relevant in the ELT sector (i.e., end of waste definition, authorization issues etc.).

CMd CMax nI>CMd nI<CMd nI:C=0

3,17 64 54 202 55

Itineraries preferred for the compatibility

1 6 10 13

1 6 10 14

Regarding the itineraries preferred for the Strenghts, the following results were obtained:

SMd Smax nI>SMd nI<SMd nI: C=0

11.5 15 54 202 55

And the preferred itineraries are

29

Itineraries preferred for the strenghts

1 6 9 13

1 6 10 13

1 6 12 13

1 7 9 13

1 7 10 13

1 7 12 13

The itineraries preferred for the strengths are largely overlapping and highlight, as regards the technological node, the advantages of improving the already existing treatment plants in Italy. The survey in fact highlights that the large majority of the treatment plants in Italy utilizes room temperature mechanical treatment, mostly with low performances, low flexibility of the production and poor managerial capabilities of the operators. This situation was built up over the past years since several investors have been attracted to this business with little understanding of the sector and little managerial skills, by diffused incentives provision and without a sound evaluation of the business plans proposed by the plants sellers. On the contrary, few far‐sighted operators invested on the quality and the efficiency of their plants, on the seek for niches in the valorization market (national and international) that could absorb their production, and are actually able to provide high standard products and flexibility according to the request of the market. This proves that it is possible to improve the standards of the existing plants in order to fit the market demand without, at least in the short‐term, the need for investing in more complex technologies such as cryogenic plants, which at the moment are too expensive and provide products with features not yet acknowledged by the market.

This option is in coherence with the material recovery options that include playgrounds, sportsfileds, civil engineering applications as well as other, not yet diffused nationwide applications, such as rubberised asphalts, that could give a significant contribution to the material recovery (alt 6). On the other hand, the energy recovery of ELTs especially in cement kilns, is currently the most applied option, to the detriment of the material recovery options, but in any case acknowledged in the short‐medium term necessary to close the loop in the ELTs supply chain, (alt 7.). It should be remarked that the coexistence of alternatives 1 and 7 in the same itinerary is not contradictory as it may seem. In fact, the interviewees mentioned that, also for the energy recovery destination, certain standard parameters should be constantly respected, otherwise products may not find a place on the national market and have to be exported.

Coherently with these perspectives, incentives proportional to amount of ELTs treated (alt 9) would be appreciated, because it is an important support to close the loop of the supply chain, as well as incentives awarding the technological innovation and the vertical integration among the activities of treatment and valorization in the supply chain (alt 10). Also a mix of the economic supporting intiatives would be helpful (alt 12).

Finally, most of the itineraries converge on the urge of implementing the GPP, as an effective tool to support the material recovery supply chain.

30

As regards the itineraries preferred for the weaknesses, the main results are

WMd Wmin nI>WMd NI<WMd

12 9 80 84

And the preferred itineraries are:

Itineraries preferred for weaknesses

3 6 10 14

3 6 10 16

These itineraries overlap for three nodes out of four (3‐6‐10), outlining a well defined pathway towards the development of the material recovery supply chain, through the implementation and incentives of innovative technologies such as devulcanization. This would expand the range of applications and also consolidate the current material recovery alternatives. A relevant point emerging here, is the importance of a correct implementation of the sectoral legislation.

Regarding the itineraries preferred for the opportunities:

Omd Omax nI>Omd nI<Omd

13.5 16 131 125

The itineraries are the following:

Itineraries preferred for the opportunities

1 5 10 13

1 5 10 14

1 6 10 13

1 6 10 14

1 8 10 13

1 8 10 14

3 5 10 13

3 5 10 14

3 6 10 13

31

3 6 10 14

3 8 10 13

3 8 10 14

Itineraries preferred for the opportunities include either alternative 1 and 3 for the technological node. Alternative 1 suggests that a production carried out according to high qualitative standards allows for a consolidation on the market of more reliable organisations that are also able to create a connection with the valorization market. On the other hand, devulcanization (alt 3) is seen as the technology that may be able to transform completely the market of ELTs rubber material. In fact, devulcanized rubber may be introduced both in the closed‐loop supply chain of tires and also in other applications, substituting virgin rubber material (especially in case of rising prices).

Regarding the applications of treated materials, recycling within the tire supply chain and in ‘high tech’ blends is considered to be a winning solution that would allow to close the loop of the supply chain (alt5 ). However, also other applications such as rubberised asphalts, acoustic insonorization and other type of ‘low tech’ blends are of interest. Also a mix of application would be positive for its subsidiarity role (alt 8). Economical incentives are considered useful when they award innovation and integration with the valorization market. For instance, the application of a reduced VAT on recycled products, the support to the implementation of products standardization procedures, etc.

The GPP implementation is seen as the most powerful stimulus for public bodies and municipalities to the green purchasing, which could be a good starter of the recycled items market. Also the sound implementation of legislation is wished for the correct functioning of the supply chain (alt 13 and 14).

Regarding the itineraries preferred for threats:

TMd TMin nI>TMd nI<TMd

11.5 10 128 128

The itineraries are the following:

Itineraries preferred for threats:

1 6 10 13

1 6 10 14

1 6 10 15

1 6 10 16

1 6 11 13

1 6 11 14

1 6 11 15

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1 6 11 16

3 6 10 13

3 6 10 14

3 6 10 15

3 6 10 16

3 6 11 13

3 6 11 14

3 6 11 15

3 6 11 16

4 6 10 13

4 6 10 14

4 6 10 15

4 6 10 16

4 6 11 13

4 6 11 14

4 6 11 15

4 6 11 16

For these itineraries the threats are less relevant and in fact they roughly correspond to the itineraries preferred for the opportunities. The implementation of the different nodes of the itineraries should contribute to reduce the threats. Other itineraries are present, which foresee the coexistence of different ELTs treatment technologies, confirming that, at least in the short‐medium time, the subsidiarity of the alternatives is important. Regarding the application scenarios, the itineraries converge on alternative 6, which includes the more traditional applications and the new applications that could provide the absorption of significant amounts of treated ELTs. Among the economical incentives, those awarding the innovation are preferred but also those awarding the ecological footprint (alt 11) are considered interesting, even though the operators admit that, currently, this aspect is not taken in consideration at all (except the obvious recognition of the advantages of any treatment alternative in comparison to landfilling or even worse illigal dispersion). Very often, in fact, operators prefer not to mention the recycled origins of their products, since this characterist is not rewarding on the market.

As for the non economic incentive is concerned, the itineraries equally consider all those suggested.

Finally, the itineraries having all the parameters above the average are:

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Itineraries with all the parameters above the average

1 5 10 13

1 5 10 14

1 5 10 16

1 6 9 13

1 6 9 14

1 6 10 13

1 6 10 14

1 6 10 15

1 6 10 16

1 6 11 13

1 6 11 14

1 6 11 16

1 6 12 13

1 6 12 14

1 7 10 14

1 8 10 13

1 8 10 14

3 6 10 13

3 6 10 14

3 6 10 16

3 6 11 13

3 6 12 13

3 6 12 14

3 8 10 13

4 6 10 13

4 6 10 14

34

4 6 11 13

4 6 11 14

The itineraries having all the parameters above the average may be considered as ‘winning’ and some of the alternatives are recurring more often, therefore contributing to a ‘best’ itinerary. This is constituted by alternatives 1‐6‐10‐13.

Figure 2. Representation of the morphological space of the itineraries

This itinerary is definitely oriented towards a development of the supply chain for the material recovery, which should increase compared to the energy recovery option, currently dominating. The itinerary foresees the improvement of the currently existing treatment technologies, without recurring, for the moment, to innovative technologies such as cryogenic treatment or even devulcanization. It is expected that this improvement will result in a natural selection of the treatment plants nationwide, favoring those plants which, with adequate investments and production management, are able to be competitive on the market and meet the qualitative standards required by the valorization operators.

The current material valorization applications are considered to be important, and need to be further developed with other alternatives able to absorb large volumes of ELTs derived material (i.e., rubberized asphalts). In general these applications not only have the environmental advantage due to the material recovery, but also achieve excellent performances in the different sectors (anti vibration materials, playgrounds, rubberized asphalts). However, a significant effort is required to increase their success despite the opposition of most of the sectoral operators that use other materials, often with lower quality and performances, and despite the fact that most of these applications fall within the competences of public administrations, that need to be sensitized on the use of recycled materials.

A significant support is envisaged in case of incentives awarding the technological innovation and the market penetration efforts of the operators, also through their integration and verticalization along the supply chain to search for new opportunities for their products.

Another winning itinerary indicates the ecological footprint as a rewarding criterion, although currently this

35

is not the case. This criterion would couple synergistically with the effective implementation of GPP . GPP is indeed the type of support that the supply chain operators expect from the institutions to stimulate the material recovery supply chain, since it would allow to start a market for the different typologies of recycled products, as well as, based on environmental considerations, to favor the national production with respect to the imported items therefore supporting the development of a national sustainable supply chain. It is however recognized that the effective implementation of GPP is connected to the stakeholders will to cooperate and proceed in the definition of the minimal environmental criteria for the different product categories.

Alternative 14, regarding the implementation of the relevant legislation, is often mentioned among the preferred itineraries. In fact, operators consider of great importance the adequate implementation of legislation relative to: end of waste definition for ELTs; TDF definition relative to ELTs content; authorization issues etc. to allow the companies for operating with more certainties in the sector. Moreover there is a strong need for sharing between sectoral operators and public controlling authorities a common language for standards and definition of produced materials.

Other interesting itineraries are 3‐6‐10‐13 and 3‐6‐10‐14, where the technological alternative is focused on the devulcanization, which is raising many expectations among the operators, since it would allow the production of new materials and new applications. It is certainly considered to be the key solution towards the sustainability of the supply chain. Current experimental tests show that, together with the devulcanization, a further functionalization of the material occurs, thus allowing for its use in new blends with lower amounts of crosslinker and consequent economic advantages. The experimental processes that are drawing interest are the high pressure water jet (HPWJ), which was originally applied to produce powders and then turned out to provide also devulcanization. The process still has very high energetic consumption. Another experimental technology under development is based on microwaves.

Parallel it would be important to define the standard features of the obtained products so as to facilitate their placement on the market.

Among the best itineraries, alternative 7, relative to the energy recovery, is present only once (1‐7‐10‐14). In fact, the option of energy recovery alone is not considered to be useful for the supply chain sustainability, even though it is useful to contribute to close the loop. However potential hurdles may arise from the environmental legislation (which may turn stricter towards incineration) and also from the economical crisis of the sector, which may cause the reduction of cement production demand. Moreover it is evident that the development of the energy recovery sector alone hinders the development of alternative material recovery options, that are more coherent with the EU waste hierarchy and also allow to develop more complex supply chain nationwide, with more economical fallouts.

Alternative 9, regarding provision of incentives proportional to the amount of treated ELTs is present in only two itineraries: if on one hand it allows to close the loop in the supply chain and to accomplish with the legislation, on the other hand it penalizes those organizations who have invested in material recovery options, which usually handle lower amounts of material.

Alternative 15, relative to incentives for new plants is present only in one itinerary, since the incentives provision of this kind from public bodies occurred in the past years have favored the chaotic and irrational development of this sector, with a proliferation of plants unable to operate in the supply chain in a sustainable way.

36

Alternative 2, relative to the maintenance of the status quo of the Italian treatment plants is never present in the itineraries, since none of the interviewees consider a valid option to maintain a large number of mechanical treatment plants that provide low standard quality products which tend to saturate the national market. Moreover this plants are definitely a threats for those plants having better features.

7. SWOT methodology results to ELTs alternative recovery cases for the case of Greece

The established Joint Alternative Management System (JAMS) for the alternative management of tires is described, along with the adopted valorization routes. The adopted Energy recovery routes in Greece are discussed with focus on pyrolysis. A SWOT analysis was further developed for the comparison of pyrolysis with combustion and the results are also presented.

SWOT analysis for ELTs pyrolysis [Samolada et. al, 2012].

Internal

Strengths Weaknesses

1.Reduced air emissions 2.High efficiency and energy self sufficient 3.Potential marketable products 4.Almost zero wastes 5.Funding availability (green activity) 6.Raw material availability 7.Typical pyrolysis plants are more compact, compared to incineration plants. 8.Existing positive collection system in Greece 9.Existing legislation

1.High investment and operation cost 2.New technology, few commercial application and lack in product standardization 3.Viability is proven only in large scale plants (>20,000 t/yr) 4.JAMS low interest

External

Opportunities Threats

1.Extensive research expertise 2.Turn a waste into a valuable raw material—high added value process 3.Reduction of the PR collection fee of ELTs 4.Minimize/eliminate abroad recovery 5.Well developed legislative frame 6.Funding opportunities through dissemination programs 7.Zero national competition—niche market 8.Increase energy independence

1.Public's great skepticism 2.Lack in environmental standards and Best Available Technologies (BATs) 3.Unstable economic environment. 4.Unproven/unstable markets for end products 5.Confused legislative frame (pyrolysis is considered as incineration)

37

SWOT analysis for ELTs combustion [Samolada et. al, 2012]

Internal

Strengths Weaknesses

1.Well developed technology 2.Energy savings 3.Raw material availability 4.Existing infrastructure of energy kilns5.Existing emissions control systems

1.Strict and expensive emission control 2.High investment and operation cost for shredding and storage 3.Subsidiary policy 4.Low degree of vaporization 5.Wastes and ash disposal problems 6.Low materials recovery degree 7.Low energy efficiency 8.Far from zero waste method

External

Opportunities Threats

1.Extensive expertise‐known technology 2.Turn a waste into a fuel 3.Minimize/eliminate abroad recovery 4.Well developed legislative frame

1.Raw material availability and price 2.Potential substitution of the waste 3.Strong public's opposition 4.Unstable economic environment. 5.Strong emissions environmental concern

8. Discussion The SWOT analysis reported in deliverable 3.3.1 reports on the Italian scenario of End of Life tires management, currently under development. The aim of the analysis was to collect the point of view on technical issues from the main stakeholders and their opinions on the suitable strategies for the development of a ELTs supply chain management that could guarantee both sustainability and legislative compliance. Starting from the present situation, in which energy recovery has larger weight compared to material recovery options, the effort to make more sustainable the supply chain is to boost the material recovery options. To this end, a number of technologies are starting to be developed, and could result as winning in the long term (e.g., ELTs rubber devulcanisation).

The analysis actually included the overall supply chain of end of life tires, among which the application in rubberized asphalt is acknowledged, by the representatives of the main stakeholders, as being one of the most promising valorization steps, at least in the mid‐term period, to help the future development towards a more sustainable supply chain.

Stakeholders recognized rubberized asphalts as being one of the most promising applications, and one of the main drivers for the development of material recovery options, both capable of absorbing large quantities of ELTs, and of providing the added value of a high performance product from the technical point of view, as recognized by technical studies on rubberized asphalt.

However, interviewees recognized that in order to boost this application, it is of utmost importance to implement supporting tools, such as the Green Public Procurement on roads, and to this aim they call for the Environment Ministry intervention. This approach may be of help also to stimulate to a change of the perceived attitude by pushing the operators in the sector of asphalts and antivibration structures who do

38

not seem to be interested in improving the quality and the duration of their products and therefore do not cooperate for the diffusion of these applications.

The results of the SWOT analysis have been shared and are going to be discussed back with the interviewees, especially Ecopneus and Unirigom (who have long experience on this field1), so that the document may be of support in future discussion tables to which these stakeholders do usually take part.

The results of this SWOT analysis have not been presented yet to any scientific conference, but SSSUP is planning to submit this work to the coming SDEWES 2013 Conference in Dubrovnik.

9. Conclusions The overall survey allowed to draw the picture of the current ELTs supply chain scenario and of the future scenario which could guarantee both sustainability and legislative compliance.

The survey was carried out in a time frame short after the implementation of the extended producer responsibility principle (art 128 dlGS 152/2006 e DM 82 April 2011) with the establishment of organizations that took a coordinating role of the stakeholders of the supply chain.

The current scenario highlights the presence of a large number of companies also in the treatment step, established thanks to the incentives provision and without a sound assessment of the business plans. Therefore the average production standards are not in general considered to be acceptable from the valorization operators. In this scenario organizations responsible for the EPR system such as Ecopneus (the largest) and Greentyre, representing a smaller number of importers, started their activity with the aim of developing a sustainable supply chain in parallel with the obliged compliance with the current legislation. Also Unirigom was involved in this perspective as well as the (only) Hellenic Alternative Management System EcoElastica.

The opinion leaders involved agreed on the need to improve the qualitative standards of the existing treatment plants and that this would be already sufficient to direct the development towards sustainability. In parallel, the attention is also focused on technological developments of devulcanization for instance, which in the long term is considered to be the winning solution. As regards the destination of the treated materials, starting from the current scenario which privileges the energy recovery nationwide as well as in foreign countries where the material are exported to. The energy recovery alone is not suitable for an adequate development of the material recovery alternatives, which are instead to be supported both according to the EU waste hierarchy and for the economic development connected. To this aim, together with the technological fitting, economic and non economic incentives are also needed in order to award both the technological innovation and the building of the products valorization through GPP implementation, lobbying activities, communication actions for the diffusion of products among consumers and other stakeholders. The stakeholders are aware that energy recovery is necessary in the short‐medium term in order to comply with the legislation, but they recognize the need to further efforts towards the material recovery supply chain development. In fact, there is a concrete risk that the predominance of the energy recovery may lead to a loss of competitiveness of companies operating in the material recovery up to their disappearance.

1 For instance, Ecopneus participates to the GPP tables organized by the MATTM (Environment Ministry) on Roads and works in synergy with Dr. Silvano Falocco, GPP net Coordinator.

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References Samolada M.C., Zabaniotou A.A. (2012), Potential application of pyrolysis for the effective valorisation of the end of life tires in Greece, Environmental Development, Volume 4, Pages 73–87.

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D3.3.1 SWOT Analysis of Rubberised Asphalt Mixtures

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