Related Services

11% of tyres imported into EU are found to be non-compliant with PAHs requirements

11 March 2011

The UK Environment Agency published a briefing letter based on a press release by ETRMA, the European Tyre and Rubber Manufacturers Agency on March 1st 2011. ETRMA have informed the UK agency that there have been possible breaches of the REACH restriction 50 concerning the levels of PAHs in extender oils and tyres.

On 1st January 2010, the restriction on PAHs came into force.  According to this restriction, tyres, and treads for retreading, manufactured after the 1st January 2010 are banned from being placed on the market if they contain extender oils exceeding the following limits:

- More than 1 mg/kg (0.0001% by weight) Benzo(a)pyrene (BaP), or

- More than 10 mg/kg (0.001% by weight) of the sum of all PAHs listed in the restriction.

The information in the document ETRMA released is based on the first phase of its tyre testing program which was carried out over several months up to February 18th, 2011. They tested a comprehensive sample of all the tyres that are sold in the European Union for the presence of or high levels of PAHs oils.

While the tyres produced within the EU were found to be REACH Compliant, the main findings of the report reveal that, 11% of all those tested were non compliant. Furthermore, the report details that ETRMA completed its testing on a sample of 110 tyres produced under 45 brand names for sale in several of the largest tyre markets in the EU. Of the 45 brands surveyed, 12 tyres produced under 9 different brand names were found to be noncompliant, i.e. they were found to be containing PAH levels prohibited by REACH, and therefore are being sold illegally on the EU market.
Markings on the tyres indicated that they were produced in 16 countries, including 9 EU countries and 7 non-EU countries and from a total of 92 different production plants in these countries. The 12 non-compliant tyres were all imported.


“While eleven percent is a cause for concern, it does take on staggering dimensions when one considers the fact that some 100 million tyres are imported into the EU and placed on the market each year,” states Dr Francesco Gori President of ETRMA. “This may very well just be the tip of the iceberg.”

ETRMA now calls on the EU and National Authorities to intensify and broaden their own testing and enforcement activities.
Follow this link to read the full press release.

 Polycyclic aromatic hydrocarbons (PAHs)
PAHs are a group of over 100 different chemicals that are formed during the incomplete burning of coal, oil and gas, garbage, or other organic compounds. They are known for their carcinogenic, mutagenic and teratogenic properties and thus a restriction on some substances in this category has been imposed by various regulatory authorities.

So far, the EU has restricted 8 PAHs in tyres and extender oils, Germany has introduced mandatory PAHs testing for the GS certification process and the US EPA has restricted 18 PAHs in consumer goods. Thus, it is vital that industry is aware of the risks of their products containing PAHs and is knowledgeable on the required tests to ensure PAHs are not present in their products.

PAHs can be found in petrochemicals, rubber, plastics, lubricants, antirust oil, paints, leather and other products. Rubber and plastics are materials that have a high risk of containing PAHs, while tyres, electronics and toys are some of the consumer products most affected by the restriction of PAHs in the EU, Germany and the US.

ETRMA’s findings have serious implications if you are a manufacturer or importer, distributer or retailer of any tyre. Companies need to take action immediately to ensure that the tyres that they are supplying are compliant with the law.

All of the companies in a supply chain may be committing an offence if tyres are supplied that contain PAHs above the limits stated in the restriction.

It is your responsibility to ensure that the products your business supplies are compliant.

CIRS PAHs Testing Services
Any importers of tyres need to verify with and encourage their suppliers to seek PAHs tests and PAHs free reports from a reputable service provider. REACH has designated ISO 21461 as standard testing method for 8 PAHs in finished tyres. Companies could also use IP 346 to test extender oil that has been used to manufacture tyres. If PCA conten in extender oil is <3%w/w, tyres are generally regarded as compliant with PAHs requirements. CIRS is the first and also the only third party testing agency that offers PAHs testing services according to both ISO 21461 and IP346 in China. We have completed PAHs testing on over 3,000 tyres from over 50 tyre companies. CIRS has helped many leading tyre companies from China become fully REACH compliant, including:

Hangzhou Zhongce Rubber Company Limited
Shandong Linglong Rubber Co., Ltd
Guizhou Tyre Co.,Ltd
Double Coin Holding Ltd (Shanghai Tyre & Rubber Co., Ltd)
Aeolus Tyre Co.,Ltd.

We also offer PAHs testing services according to the following criteria:

  • EU REACH 8 PAHs;
  • German 16 PAHs;
  • US EPA 18 PAHs;


PAH testing is of vital importance.  Manufacture or placing on the market of tyres within the EU that exceed the PAH limits stated in the restriction is an offence under the REACH Regulation. The full restriction wording can be viewed in Annex 17 (XVII) of EC 1907/2006 the REACH Regulation (as amended by EC No. 552/2009).

Each member state agency has enforcement powers for REACH restrictions under the REACH Enforcement Regulations 2008.

For example in Ireland Under the Chemicals Act 2008, the Authority has the power to request information and to take enforcement action for failure to respond or for responding with a false declaration. Inspectors of the Authority may also take appropriate enforcement action against non-compliance with REACH restrictions. Enforcement action may mean the issuing of enforcement notices or prosecution. Prosecution may lead to a fine or imprisonment (or both).


CIRS Ireland

Unit 1 Ardee Business Park, Hale Street, Ardee, Co. Louth, Ireland
Tel: +353 41 9806 916 | Fax: +353 41 9806 999
Email: |


CIRS China

1288 Chunbo Road, Binjiang District, Hangzhou City, China
Tel: +86 571 8720 6555 | Fax: +86 571 8720 6533