Intro:

Spain is overhauling its tire waste management framework, with the publication of Royal Decree 712/2025, which replaces the longstanding 2005 regulation and tightens obligations across the extended producer responsibility (EPR) landscape. These updates bring enhanced enforcement, financial guarantees, and circularity reforms aimed at ensuring waste tyres are treated as resources—not refuse.

Major Changes & What They Mean for Stakeholders

Royal Decree 712/2025, officially published on August 27, 2025, replaces Royal Decree 1619/2005 and introduces sweeping changes to Spain’s EPR scheme for end-of-life tyres. 

Key revisions include:

• Mandatory Financial Guarantee: EPR schemes must now maintain a reserve equal to 5% of annual management costs to secure operations in the event of insolvency or dissolution. 

• Obligation Extension & Traceability: All reporting, registration, and administrative processes must become fully electronic—enhancing transparency and aligning with EU waste transfer rules. 

• Mandatory Prevention Plans: Producers placing 250 tonnes or more of tyres yearly must submit annual prevention plans by May 31, covering reuse, lifecycle extension, and recycling strategies. 

• Clarified Definitions & Loophole Closures: The decree refines terms like “replacement tyres,” “second-hand,” “retreaded,” and “casing,” especially around import and reuse distinctions. 

• Circularity Targets & Restrictions: New incremental goals for reuse, recycling, and limits on energy recovery/landfill disposal are set for 2025, 2030, and 2035. 

• Public Awareness & Eco-modulation: EPR schemes (SIGNUS, TNU) must now promote public campaigns. A new eco-modulation mechanism adjusts producer fees based on durability, reuse potential, and the percentage of recycled content. 

These changes reflect Spain’s push toward more accountable, efficient, and circular tyre management—reducing reliance on waste-to-energy pathways and promoting material recovery ambitions.

Spain has updated its Royal Decree 712/2025, which established the Spanish EPR system, one of the most successful initiatives in Europe.

The 20-year-old decree had been modified over the years, but the upcoming changes in the European Waste Shipping and Transfer Rules have guided an overhaul of the Spanish regulations to bring them in line with the proposed future oversight of waste management by Brussels. The new decree also aligns with EU Law 7/2022 on Waste and Contaminated Soils for a Circular Economy and Directive (EU) 2018/851. Having said that, there may be some way to go before Europe sees uniformity in waste shipping and transfer rules.

The new Royal Decree 712/2025 of August 26 (published in the Spanish Official Gazette on August 27, 2025) replaces Royal Decree 1619/2005 and fully updates Spain’s legal framework on end-of-life tire (ELT) management.

The new decree strengthens the EPR scheme by reiterating that producers are responsible for the collection, treatment, and recovery of tires they place on the market, either individually or through collective systems. Additionally. There is a new financial guarantee: EPR schemes must hold a reserve equivalent to 5% of annual management costs to ensure continuity if the organization becomes insolvent or dissolves.

One of the loopholes in the EPR regulations was that there were “free riders”, ie, those who fell outside the schemes. This is not just a Spanish problem. The EPR schemes across Europe, and increasingly around the world, are run on behalf of the tyre producers. They are only responsible for recovering their own waste tyres by volume. So, if, say, Michelin sold one million tyres in Spain, they are only responsible for the management of those one million tyres. The members of the EPR schemes have no obligation to collect tyre volumes from sources outside the scheme’s membership.

Of course, this means that the EPR schemes all show very high recovery levels, yet in most countries there are excess tyres entering the market through smaller importers as grey, or even black market imports.

The new Decree addresses this issue to some extent by imposing Mandatory Waste Prevention requirements on producers who place more than 250 tonnes of tires annually. These producers must submit a prevention plan by May 31 each year.

These plans must include measures to extend tyre life, promote reuse, and increase recycling.

Just how a low-level importer is going to meet those requirements remains to be seen.

In a move that is set to become a requirement across Europe, Spain will now require all reporting, registration, and administrative procedures to be fully electronic, thereby increasing efficiency and transparency.

This will be a requirement to meet the EU waste transfer and shipping rules, which will be digitally overseen from Brussels.

The latest Decree makes clearer definitions of “replacement tyres,” “second-hand,” “retreaded,” and “first fit” (OEM) tyres, improving regulatory clarity. One might presume that Spain is closing loopholes that allowed some players to evade the EPR regulations.

In terms of retreaded tyres, TNU advises that there has been clarification regarding the “casings” used in retreaded tyres.

The definition of casing is motivated by Royal Decree 731/2020, which clarifies in which cases a retreader in Spain becomes a producer:

• If, to produce retreaded tyres, imported casings are used, then the retreader is considered a producer.
• If the casing comes from within Spain, they are not considered a producer; the retreaded tyre would not be subject to an eco-fee (ecovalor), and it would not need to be reported to collective systems or the national producer registry.
• However, if the casing used is imported, this constitutes a new placing on the national replacement market, so it would be subject to an eco-fee and must be reported as placed on the market.

The circularity of tyres has always been an issue, and although recovery levels were very high, and all recovered tyres were recycled, the circularity of the process was less successful. True tyre circularity occurs when tyre-derived materials are recycled and reintroduced into the production of tyres. This has always been an El Dorado, the reality has long been that energy recovery though waste to energy and cement kilns has accounted for somewhere around 50% of all arisings in Europe, the balance going to material recovery, a small part of that going back into tyres via the reuse of steel, possibly reclaim or devulcanised rubber, and a small amount by one route or another from recovered carbon black from pyrolysis operations.

Rather than a circular economy in tyres, there is a spiral economy, but that is a topic for another discussion.

The Decree addresses this lack of circularity by setting incremental goals for reuse, recycling, and energy recovery by 2025, 2030, and 2035, with strict limits on landfill disposal and energy recovery as a last resort.

The clarification of the obligations of recycling plants, workshops, and municipal collection points regarding collection, preparation for reuse, and reporting ties these changes together. It sees stricter controls and sanctions that improve enforcement mechanisms and impose penalties for non-compliance. It also revisits the Landfill ban introduced in 2011, ensuring that, with very few exceptions, no tyres go to landfill.

The Decree establishes a unified reporting system, with annual public data by region on tyre flows and recycling rates.

It also ensures that the EPR systems – SIGNUS and TNU - must develop publicity campaigns to improve awareness among producers, workshops, and consumers alike.

This latter point reinforces the publicity campaigns that both SIGNUS and TNU have been operating to build awareness of the challenges and opportunities in the sector. In this latest Decree, Spain has listened to the industry, examined the realities of its EPR scheme, and moved to reinforce the positives and strengthen the weak elements of the system. It is making the Spanish EPR scheme fit for the future.

Both SIGNUS and TNU welcome the tightening up of the regulations and the improvement in traceability.

“We hope that this new regulation, which further involves producers and improves the traceability of end-of-life tire management, will definitely boost the value of recycled materials, thus turning waste into a resource in line with the principle of the circular economy,” says Carlos Prieto, General Manager of SIGNUS.

One of the points that SIGNUS highlighted was the Eco-modulation: The idea that the financial contribution from producers must be modulated, taking into account the tyre’s useful life, the possibility of preparing it for reuse, and the recycled material content. Essentially, if a tyre has a longer life and better economy in use, then the fees will reflect that status.

Link to original article » GO.

Learn more:

• Tire Pyrolysis Project
• Pyrolysis Oil Fuel Credits
• Tyre Pyrolysis Guide
• Plastic Pyrolysis Solutions
• Tire Pyrolysis Plant Setup

Stay Ahead of Spain’s EPR Shift with Klean’s Expertise

Regulatory Mastery. Circular Strategy. One Partner That Ensures Compliance & Opportunity.

Spain’s new EPR rules are a turning point for tire circularity. Klean Industries offers in-depth domain expertise, regulatory navigation, and project alignment strategies to help you turn compliance into an advantage.

Klean’s Strategic Support:

✅ Regulatory Mapping & Gap Analysis
✅ Financial Guarantee Strategy & Risk Structuring
✅ Circular Business Modeling & Eco-modulation Advisory
✅ Compliance & Traceability System Design
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With Klean’s experience in global EPR regimes and circular systems, your tire projects will stay ahead of regulation and unlock material value—not just compliance.

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