Environment Agency publishes guidance on using baled tyres in civil engineering projects


Companies that use PAS 108 standard tyre bales for civil engineering and permitted landfill works will not need to apply for an environment permit as long as they meet certain criteria.

This follows the publication of a regulatory position statement by the Environment Agency that means companies using PAS 108 tyre bales will need to notify the agency that they have met the required criteria.


To use tyres without applying for a permit, companies must notify:

  • The local Environment Agency office of the location of the project and that it falls within the scope of the regulatory position statement
  • The proposed civil engineering works the tyres bales will be used for
  • Who will be supplying the tyres
  • The number of tyres required for the project
  • Assurance that the tyres conform to PAS 108
  • The estimated commencement and duration of the storage and construction activities
  • The location of the proposed storage and construction areas
  • A construction or quality assurance plan
  • Details of the proposed project supervisor.

Any variations to this must be approved in writing by the Environment Agency and must be overseen by a recognised qualified civil engineer.

Tyres cannot be used where they harm the environment, or in locations where they will be under the water table.  The usage of them must also comply with local land use planning and statutory controls.

No more than 1,000 bales will be allowed to be stored at any location and for no longer than three months before commencement of the project.

A written statement will need to be in place to prevent, detect, contain and mitigate fires. 

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