France Tyre Thermolysis Oil Rules Create End-Of-Waste Pathway

France has created binding end-of-waste criteria for oil produced by vapothermolysis or thermolysis of waste tyres and used as material feedstock in chemical or petrochemical installations. The 21 July order was published on 2 August and entered into force on 3 August 2026, opening a structured market for tyre thermolysis oil while imposing detailed quality and traceability controls.

The measure affects authorised tyre-recovery sites, waste operators, chemical producers, petrochemical plants, laboratories and buyers seeking circular hydrocarbon feedstocks. It does not automatically classify every recovered oil as a product.

When Tyre Thermolysis Oil Stops Being Waste

Eligible input is limited to non-hazardous end-of-life tyre waste under code 16 01 03, shredded below 250 millimetres. Loads must exclude hazardous waste, asbestos, PCBs, healthcare waste, specified vehicle components, brominated flame-retardant waste and material exceeding EU persistent organic pollutant limits.

Recovered tyre thermolysis oil must be free from damaging or unsafe impurities and perform with comparable safety to the feedstock it replaces. The order caps sulphur at 30,000 parts per million, nitrogen at 10,000, total oxygen at 20,000 and combined halogens at 1,000.

Aluminium, chromium, cobalt, copper, manganese, nickel, vanadium, iron, zinc, magnesium, cadmium and titanium are limited together to 500 parts per million. Arsenic, mercury, lead and antimony are limited together to 10 parts per million.

Contracts, Testing And Traceability Duties

Product status depends on a quality-management system, incoming-waste checks, self-monitoring, validation trials and a transfer contract with an eligible user installation. The general rule is lot testing at least monthly. Specified per-lot analyses may be omitted where homogeneous, stable incoming waste is demonstrated using an analogous recognised method.

Mercury, arsenic, lead and antimony testing may move from monthly to quarterly after one compliant year; an exceedance restores more frequent checks. Each marketed lot needs a unique identifier and an electronic or paper conformity certificate. Records demonstrating compliance must be retained for at least five years.

The user must be a qualifying chemical or petrochemical installation. Use cannot increase permitted emission limits, materially increase channelled emissions or raise quantified diffuse emissions. The oil must also comply with REACH and CLP. The order does not determine recycled-content accounting or later-chain traceability rules.

Building A Compliant Secondary-Feedstock Route

Operators should align waste specifications, sampling plans, laboratory methods, contracts and certificates before marketing tyre thermolysis oil as a non-waste product. Buyers should verify installation eligibility, trial results and emissions compatibility. International suppliers should note that this is a French pathway and does not automatically establish equivalent product status in other jurisdictions.