Strategic Alliance (PPP) with the Cement Industry and Tyre ... · PDF fileStrategic Alliance...

Strategic Alliance (PPP) with the Cement Industry and Tyre Manufacturers and Dealers in Kenya

Concept and Feasibility Study for Collection, Pre-processing

and Marketing of Waste Tyres in Kenya

Prepared by: INFRASTRUKTUR & UMWELT On Behalf of GIZ

March 2012

Office Darmstadt Julius-Reiber-Strasse 17 D 64293 Darmstadt / Germany

Fax +49-6151-8130-20 Tel. +49-6151-8130-0

www.iu-info.de

Office Potsdam Georg-Mendel-Strasse 9 D 14469 Potsdam / Germany

Tel. +49-331-50581-0 Fax +49-331-50581-20

www.iu-info.de

Partners Dipl.-Ing. Gernod Dilewski Dipl.-Ing. Hans Jürgen Gräff Dr. Ing, Peter Heiland Dr. Ing. Jürgen Neumüller

Strategic Alliance (PPP) Waste Tyre Management, Kenya

Concept and Feasibility of Waste Tyre Collection

I

Content

1 Introduction .............................................................................................................. 4

1.1 Background ............................................................................................................. 4

1.2 Current Situation and Project Justification .............................................................. 4

2 Estimation of the Amount of Waste Tyres in Kenya ........................................... 10

2.1 Waste Tyre Generation ......................................................................................... 10

2.2 Tyre Imports into Kenya ........................................................................................ 12

3 Options for Utilization of Waste Tyres ................................................................. 15

3.1 Screening of Options of Waste Tyre Utilization ..................................................... 15

3.2 Capacity for RDF Utilization in Cement Kilns in Kenya ......................................... 19

3.3 Pre-Processing of Waste Tyres ............................................................................ 19

3.3.1 Baling of Tyres ................................................................................................... 20

3.3.2 Shredding of Tyres ............................................................................................ 20

3.3.3 Feeding of Waste Tyres into the Cement Kiln ................................................... 21

3.3.4 Options for the Transport of Waste Tyres .......................................................... 22

4 Investigation of Possible Options / Scenarios for the Collection and

Coprocessing of Waste Tyres in Kenya ............................................................... 24

4.1 Scenarios for Coprocessing of Waste Tyres in Cement Kilns ............................... 24

4.2 Integration of the Informal Sector into the Waste Tyre Management

System .................................................................................................................. 24

4.3 Scenarios for the Collection and Transportation of Waste Tyres .......................... 26

4.3.1 Implementation Steps and Amounts of Waste Tyres Collected ......................... 26

4.3.2 Logistics for Collection, Pre-processing and Disposal of Waste Tyres .............. 28

4.4 Costs for the Collection and Transportation of Waste Tyres ................................. 31

4.5 Cost Balance for Collection and Transportation versus Revenues from

Marketing of Waste Tyres ..................................................................................... 34

5 Assessment of the Organisational Setup for WTMK .......................................... 35

6 Conclusions and next steps .................................................................................. 38



II

List of Tables

Table 1 Typical composition of a tyre by weight ........................................................... 7

Table 2 Estimated amounts of waste tyres in Kenya in 2009 ..................................... 10

Table 3 Tyre imports into Kenya in 2011 (source: Kenya Revenue

Authority) ....................................................................................................... 13

Table 4 Estimation of imported tyres coming into Kenya with imported

cars (based on newly registered cars in 2009) .............................................. 14

Table 5 Density of whole and shredded waste tyres .................................................. 20

Table 6 Cost for shredding/processing of waste tyres ............................................... 21

Table 7 Revenues from selling steel of waste tyres after open burning ..................... 25

Table 8 Collectable quantities of waste tyres ............................................................. 28

Table 9 Cost calculation collection, storage and transport for scenario 1 .................. 32

Table 10 Cost calculation collection, storage and transport for scenario 2 .................. 33

Table 11 Cost balance of the waste tyre management system .................................... 34

List of Figures

Figure 1 Final destinations of waste tyres in Kenya in 2011 ......................................... 5

Figure 2 Steel wire recovery from tyres at Kariobangi outside Nairobi

(photo by Ms. Janet Ruto – Bamburi) .............................................................. 6

Figure 3 Footwear made by reusing tyre ....................................................................... 6

Figure 4 Tyres ready for burning (photo by Ms. Janet Ruto – Bamburi ......................... 6

Figure 5 Tyre burning site .............................................................................................. 6

Figure 6 Recovered steel wires from burnt tyres ........................................................... 8

Figure 7 Share of major urban centres in tyre generation ........................................... 11

Figure 8 Forecasted quantities of waste tyres ............................................................. 12

Figure 9 Source of tyres in Kenya ............................................................................... 14

Figure 10 Used tyre recovery in Europe in 2010 (source: European Tyre

and Rubber Manufacturers’ Association) ...................................................... 15

Figure 11 Retreading of a truck tyre - Nairobi ............................................................... 16

Figure 12 Shoes from tyres – in Nairobi ........................................................................ 17



III

Figure 13 Tyre bales ...................................................................................................... 20

Figure 14 Feeding of whole tyres .................................................................................. 22

Figure 15 An example mobile shredder for waste tyres ................................................ 23

Figure 16 Current and proposed future tyre streams .................................................... 26

Figure 17 Implementation steps of the formal waste tyre collection .............................. 27

Figure 18 Collection, storage, and transportation of waste tyres in

scenario 1 ...................................................................................................... 29

Figure 19 Collection, storage, pre-processing and transportation of waste

tyres in scenario 2 ......................................................................................... 30

Figure 20 Impact of coal price on the costs of the waste tyre management

system ........................................................................................................... 35

Figure 21 Organisational setup for a waste tyre management system

controlled by the Kenyan government ........................................................... 36

Figure 22 Organisational setup for a waste tyre management system based

on extended producer responsibility .............................................................. 37



4

1 Introduction

1.1 Background

An agreement for a strategic alliance for implementation of a waste tyre management

system in Kenya has been signed by GIZ and the companies Bamburi Cement,

Treadsetters, Multiple Hauliers and Sameer Africa in May 2011. The agreement is based

on the project description, approved by the German Federal Ministry for Economic

Corporation and Development. In this project description the main activities, objectives

and indicators of the project as well as the contributions of the different partners are

defined.

The objective of the partnership is to develop a sustainable waste tyre management

system in Kenya, where the regulatory framework is provided by the Kenyan government

and where the private sector is designing and implementing the system. The programme

is divided into two phases.

The aim of the first phase is the development and adoption of necessary rules and

regulations for the collection and recycling of scrap tires. The drafting of the regulations is

closely linked with the development of technical solutions, cost analysis and the

organisational setup of the proposed system. Phase 1 includes the following work

packages:

- Preparation of a concept and feasibility study for collection, pre-

processing and marketing of waste tyres (presented in this report)

- Preparation of a feasibility study on the co-processing of waste tyres in cement

kilns in Kenya (presented in a separate report, but results considered in this

report)

- Drafting of waste tyre regulations based on the technical studies

Infrastruktur & Umwelt has been assigned with assisting the implementation of Phase 1 of

the Strategic Alliance. This report is presenting the results of the first work package.

1.2 Current Situation and Project Justification

In 2011, about 1.9 Million scrap tires have been generated in Kenya (see chapter 2).

Scrap tires represent both a disposal problem and a resource opportunity. The current

situation of waste tyre disposal is shown in the figure below.



5

Figure 1 Final destinations of waste tyres in Kenya in 2011

As shown in the diagram the, by far, biggest amount of scrap tyres is burnt in the open to

recover the steel from the tyres. Only a minor amount, most likely well below 10 % is used

for material recycling (i.e. production of shoes, ropes, carpets, etc.).



6

Figure 2 Steel wire recovery from tyres

at Kariobangi outside Nairobi (photo by Ms. Janet Ruto – Bamburi)

Figure 3 Footwear made by reusing tyre

The recovery of the steel wire found within the tyres is a common practice all over Kenya.

The steel wires are recovered by burning the tyre and thereafter the recovered metal is

sold to a scrap metal trader. Scavengers collect the tyres and then set fire to them. The

burning usually takes place at night as this practice is illegal. Other than NEMA arresting

the scavengers that are burning tyres, second approach to prevent this practice would be

to make it illegal for steel mills to accept scrap metal from tyres.

Figure 4 Tyres ready for burning (photo by Ms. Janet Ruto – Bamburi)

Figure 5 Tyre burning site

When tyres are burnt this leads to severe air pollution, this applies both when tyres are set

on fire to recover the steel wires, as well as to dumpsite fires. So any procedure that will

ensure that waste tyres are collected and treated in a responsible manner will greatly

benefit public health and lead to a cleaner environment.

Also, some of the rubber is used in simple furnaces as cheap source of fuel, in order to

replace coal or wood. It is assumed that a small part of the used tyres are stockpiled by



7

consumers, workshops, and tyre sellers, etc. End of 2010, the Bamburi Cement Plant

near Mombasa has started using waste tyres as a fuel in one of their kilns (see Report on

Co-processing).

Furthermore, many tyres are dumped indiscriminately. Such discarded tyres present a

significant health hazard, as they will accumulate stagnant water and can then become

breeding grounds for Aedes mosquitoes, the carrier of dengue fever. Furthermore, if the

tyres are dumped with household waste, the local population may set fire to the waste to

eliminate odours, rodents and vectors. When tyres are burned together with the

household waste, the air pollution will be more acute than otherwise.

There are many companies in Kenya which re-tread worn tyres. In Europe 8 % of the total

amount of worn tyres were re-treaded in 20101. In Kenya, this amount, most likely is much

higher. However, eventually all tyres will reach the end of their service life, and become

waste tyres. Re-treading has already been included in the estimation of lifetime of tyres

and estimation of waste tyre amounts (Table 2).

In Kenya, there are no official statistics on waste tyres (except the statistics on used tyres

in Bamburi Cement Plant); therefore the data presented above are rough estimations.

However, there is no doubt that open burning for steel recovery represents the most

common method for waste tyre disposal. In the table below the main material components

of a tyre are presented:

Table 1 Typical composition of a tyre by weight2

Components Passenger Tire Truck Tire

Natural rubber 14% 27%

Synthetic rubber 27% 14%

Carbon black 28% 28%

Steel 14 - 15% 14 - 15%

Fabric, fillers, accelerators, antiozonants, etc. 16 - 17% 16 - 17%

Average weight [kg] new 11 54

scrap 10 50

1 End of life tyres - A valuable resource with growing potential - 2011 edition. European Tyre and Rubber Manufacturers’ Association 2 Source: US-Rubber manufacturers association



8

As shown in the table there are app. 1.5 kg steel in a passenger tyre and 7.5 kg in a truck

tyre. According to a market research in Nairobi and Mombasa revenues for selling the

steel from scrap tyres are in a range of 15 – 40 KES per kg steel scrap. There a two

different types of wires which have different market value:

a. thick wires found along the rim of the tyre. They are strong and don’t get corroded

easily.

b. thin wires found elsewhere around the tyre. They are not durable as they rust

easily and are weak.

These two products fetch different prices with the type A going KES 25 to 40 and being

most preferred; type B goes for as low as KES 15.

Figure 6 Recovered steel wires from burnt tyres

Considering average revenues of 20 KES per kg a single truck tyre could earn 150 KES; a

stockpile of 5000 truck tyres would earn 750,000 KES. Thus, burning of tyres in Kenya in

recent years became an interesting business opportunity for the informal sector, and a

system for waste tyre utilization has been developed, which – from the point of costs and

efficiency - is functioning quite well.

Unfortunately, the current practice of open burning of waste tyres is connected to very

negative impact on environment and human health. Quite frequently in the outskirts of

Nairobi the black smoke from open burning of large amounts of tyres is covering the sky

and many residents complain about the harassment.



9

The open burning of tyres has significant impacts on the environment, human beings and

flora and fauna. A wide variety of decomposition products is generated during the open

burning of tyres. For instance, ash (containing carbon, zinc oxide, titanium dioxide, silicon

dioxides, cadmium, lead, and other heavy metals), volatile organic carbons, polynuclear

aromatic hydrocarbons (PAHs), aromatic oils, sulphur compounds, carbon and nitrogen

oxides, and several light-end aromatic hydrocarbons (e.g. toluene, xylene, benzene, etc.)3

are released in an uncontrolled burning of tyres. The type and quantity of the

decomposition products vary depending on several factors, e.g. type of tyre, burn rate,

temperature and humidity. In addition to the air, soil and surface and ground water are

polluted with these materials if they are washed or rained out by rainwater. The pyrolysis

oil, which is also a highly pollutant and flammable decomposition product, hazards the soil

and water sources. The burning of 21,000 tons of tyres produces about 165,000 litre

pyrolysis oil. The remaining solid residues after burning can penetrate the soil through

rainwater or surface water.

Due to the negative impact, NEMA has banned the open burning of tyres and is tracking

unlawful behavior. Unfortunately, it is almost impossible to fully control tyre burning, since

places for storage and burning are always changed. Furthermore, burning often happens

at night, and next morning only moldering ashes are left.

In general, there is a broad consensus that open burning of tyres is very harmful and

should no longer be accepted. However, first of all until today, no environmentally friendly

alternative is available in Kenya. Even if these solutions are available, it will be difficult if

not impossible to hinder waste pickers from open burning of tyres if no competitive

business / income opportunities are provided.

Thus key requirements for the new waste tyre management system are:

1. The new system should avoid negative impact on health and environment (thus

eliminating the negative impact of open tyre burning, which now is the common

practice)

2. Income opportunities of the poor population (currently involved in open burning of

waste tyres) should be at least maintained or if possible improved

3 Revised guidelines on environmentally sound management of used tyres, Basel Convention, UNEP/CHW, November 2008



10

2 Estimation of the Amount of Waste Tyres in Kenya

In the mission report for establishing a Strategic Alliance on Waste Tyre Management in

Kenya (September 2010), the amount of waste tyres generated in Kenya has been

calculated. The chapters below present a

Verification and detailing of the 2010 calculations

Update to 2011 data and 10 year forecast

Division of results into urban centers (Nairobi, Mombasa) and other areas

2.1 Waste Tyre Generation

In the Statistical Abstract 2011, the Kenya National Bureau of Statistics has published

statistics for the transport sector. The latest data available is from 2009 and accordingly

1.2 million vehicles were registered in that year. Thus the total number of vehicles and

used tyres is much higher than the estimated number in the Mission Report from

September 2010. Based on the statistics for each type of vehicle, the amount of waste

tyres per year has been actualised and presented in the following table.

Table 2 Estimated amounts of waste tyres in Kenya in 2009

Total number of vehicles in

Kenya

Average number of tires per vehicle

Average mass of

tyre

Time period of use

including retreading

Total mass of waste tyres

Total number of

waste tyres

no no kg / tyre years / tyre tons no

Motor Cars 499,679 4 9 3.5 5,140 571,062

Utilities, Panel Vans, Pick-ups, etc. 219,901 4 25 2.5 8,796 351,842

Lorries, Trucks and Heavy Vans 91,431 10 50 2.5 18,286 365,724

Buses 26,558 8 50 2.5 4,249 84,986

Mini Buses/Matatu 58,286 6 25 2.5 3,497 139,886

Trailers 27,039 6 50 2.5 3,245 64,894

Wheeled Tractors 25,091 4 60 5 1,204 20,073

Motor Cycles 239,104 2 5 4 598 119,552

Three Wheelers 13,856 3 6 3 83 13,856

Other motor vehicles 20,138 4 15 3.5 345 23,015

Total 1,221,083 45,443 1,754,889

According to the statistical data, the average urbanisation rate in Kenya is about 32%.

However, the vehicles are mainly used in urban centres and it can be assumed that about



11

80% of the waste tyres have been generated in urban centres. If it is presumed that the

tyre generation rate is directly related to the population number, the share of major urban

centres in tyre generation will be as shown in the following figure.

Figure 7 Share of major urban centres in tyre generation

The figure above shows that about 46% of the waste tyres are generated by the

mentioned seven urban centres. As expected Nairobi, where about 8% of the total

population lives, is the largest generator of waste tyres with about 20% of the total

generated tyres. This figure may even be higher because of more urban style life than

other urban centres, higher number of workshops and tyre dealers and intensive vehicle

trading. However, exact number of registered vehicles in Nairobi or other related statistical

data are not available.

Between 2001 and 2009, the registered number of vehicles in Kenya has doubled and

increased about 9% per year. The annual new registrations have increased rapidly as

well. While in 2001 only 26.000 vehicles were registered, in 2009 this figure was 162.000.

Although the number of passenger cars per 1,000 inhabitants is with about 13 cars

relatively high compared to the Kenya’s neighbouring countries, there is a potential for

growing vehicle numbers compared to e.g. South Africa (99 cars), or countries in North

Africa (Egypt 22 cars, Morocco 47 cars and Tunisia 62 cars). This potential will certainly

Nairobi20%

Mombasa6%

Kiambu6%

Nakuru5%

Machakos4%

Kisumu3%Uasin Gishu

2%

Other urban centres

34%

Rural areas20%



12

be exhausted with the growing economy of Kenya and purchasing power of inhabitants4.

Based on these facts and with a conservative approach, it is estimated that the number of

registered vehicles in Kenya will increase by 5% each year. The following figure shows

the forecasted quantities of waste tyres until 2031.

Figure 8 Forecasted quantities of waste tyres in Kenya

According to this estimation, the amount of waste tyres will increase from 52,600 tons in

2012 to 81,600 tons 2021 and 132,900 tons in 2031.

2.2 Tyre Imports into Kenya

There is only one company in Kenya actually producing tyres, which is Sameer Africa Ltd.

The major amount of tyres, used in Kenya is imported into the country. Based on statistics

from the KNBS, the imports of tyres (including re-treading material) have been evaluated.

According to the KNBS figures, in the last three years (2009 – 2011) a total of 1,182

different companies imported tyres into Kenya; in 2011 590 companies were registered.

Imported tyre amounts per registered company range from 1 kg to more than 4,000 tons

in 2011 (see table below).

4 International Monetary Fund estimates that the GDP of Kenya will increase annually 6.3% and be doubled in 2016 compared to the GDP of 2010 which was 32.163 Billion U.S. Dollars.

40,000

50,000

60,000

70,000

80,000

90,000

100,000

110,000

120,000

130,000

140,000

To

ns/

a

Year



13

Table 3 Tyre imports into Kenya in 2011 (source: Kenya Revenue Authority)

Imported tyres per company

[tons in 2011]

No. of companies

Amount of tyres [tons in 2011]

Percentage of total weight

more than 1000 5 13,759 42%

250-1000 21 8,647 27%

100-250 36 5,176 16%

25-100 66 3,572 11%

0.001-25 462 1,390 4%

Total 590 32,544 100%

As shown in the table, in 2011 five companies have imported more than 1,000 tons each.

Looking at the total amount of tyres (in weight) these companies come up for 42% of the

imports. In total 62 companies imported 85% of the tyres in weight.

Overall, these data show that there is a very large number of importers for tyres. However,

besides a few hundred companies importing only small numbers, there are only 62

companies importing more than 100 tons. 26 companies import 69% of tyres (by weight).

It has to be considered that the ranking according to the recorded value (CIF5) differs

considerably from the ranking according to weight.

Furthermore, tyres come into the country with newly registered cars. In the following table

the amount of tyres from imported cars is estimated on the basis of newly registered cars.

5 CIF: The c.i.f. price (i.e. cost, insurance and freight price) is the price of a good delivered at the frontier of the importing country, including any insurance and freight charges incurred to that point, or the price of a service delivered to a resident, before the payment of any import duties or other taxes on imports or trade and transport margins within the country



14

Table 4 Estimation of imported tyres coming into Kenya with imported cars (based on newly registered cars in 2009)

Newly registered vehicles in

Kenya in 2009

Average number of tires per vehicle

Average mass of tyre

Total mass of waste tyres

no no kg / tyre tons / year Motor Cars 44,529 4 9 1,603Station Wagons 0 4 9 0Utilities, Panel Vans, Pick-ups, etc.

7,120 4 25 712

Lorries, Trucks and Heavy Vans

6,037 10 50 3,019

Buses 1,734 8 50 694Mini Buses/Matatu 3,806 6 25 571Trailers 2,883 6 50 865Wheeled Tractors 2,526 4 60 606Motor Cycles 86,158 2 5 862Three Wheelers 4,993 3 6 90Other motor vehicles 2,027 4 15 122Total 161,813 9,142 5% increase 2010 9,599 5% increase 2011 10,079

Based on these figures tyres from imported cars come up for app. 20% of the tyres in the

country. There, certainly, might be some grey market imports as well, which however

cannot be quantified. The diagram below is presenting an estimation of the different

sources for tyres in Kenya.

Figure 9 Source of tyres in Kenya

Tyre imports62%Tyres

imported with cars20%

Others (tyres

produced in Kenya, grey market

imports, …

Source of tyres



15

3 Options for Utilization of Waste Tyres

3.1 Screening of Options of Waste Tyre Utilization

After the end of their useful life, the tyres can be utilised for various purposes. Extended

research has been undertaken and different solutions have been developed for

processing and utilization of waste tyres. The following figure shows the latest statistics for

waste tyre management in Europe6.

Figure 10 Used tyre recovery in Europe in 2010 (source: European Tyre and Rubber Manufacturers’ Association)

Energy recovery still is the main purpose for waste tyre utilization in Europe. Also, material

recycling increased in recent years, and new technologies for processing and utilization

have been developed.

However, it has to be taken into account that in Europe considerable funds are spent for

waste tyre management. According to the European Tyre and Rubber Manufacturers’

Association, the annual cost for the management of waste tyres is estimated at € 600

million. Considering an amount 3.3 Mio tons of waste tyres in 2010, average specific costs

amount to 180 Euro per ton (app. 1.80 Euro for a small tyre and 9 Euro for a truck tyre).

In the following available technics are described and their suitability to the conditions in

Kenya is discussed briefly.

6 End of life tyres - A valuable resource with growing potential - 2011 edition. European Tyre and Rubber Manufacturers’ Association

Reuse4%

Export6%

Retreading8%

Civil Engineering

7%

Recycling32%

Energy38%

Landfill5%

Waste Tyre Recovery in Europe



16

Re-utilisation

Scrap tyres can be reused for different purposes, such as:

As a wharf or pier fender and on vessels

To prevent the fly over of tarpaulins on piles or dung heaps, as well as during landfill

construction or operation

In noise barriers or as supporting structure for erosion control, slope stabilisation

As playground equipment (e.g. swing)

Artificial reefs

However, reuse of old tyres will not be a feasible solution to be applied as a countrywide

system since the possibilities and the number of tyres to be used are limited.

Re-tread

The re-treading is the buffing away of the worn tread and bonding of a new tread to the

suitable worn tyres. If manufactured according to certain standards, like UN/ECE 108/109,

the re-treaded tyres are safe as much as the new tyres. The re-treading process requires

about a quarter of the rubber compound and one fifth of the oil which is needed for the

manufacturing of new tyres. However, the road resistance of the re-treaded tyres is about

3% higher than the new tyres. This cause increased fuel consumption compensating the

cost balance over the entire service lifetime. In Kenya, there are already several

companies which produce re-treaded tyres. However, even with re-treading, life time of a

tyre is limited, and finally (when for example the chassis is damaged) all tyres will become

waste tyres.

Figure 11 Retreading of a truck tyre - Nairobi



17

Material Recycling

The material recycling of used tyres includes the use of reshaped tyres or use of the

granulated material as rubber secondary raw material. The simple form of material

recycling is already in place in Kenya. Several small enterprises produce footwear or

buckets from used tyres.

Figure 12 Shoes from tyres – in Nairobi

The grinding in order to produce granulates or meal can be done either by mechanical

shredding systems or by cooling and following crushing. The standard shredding systems

successively process the tyres down to a size of approximately 0.8 mm. Therefore, it is

very energy intense. By grinding with cooling the tyres must be shredded before cooling

with liquid nitrogen (additional costs). Thus both processes are very cost intensive.

Devulcanization is another form of material recovery. Using different processes, the tyre

rubber is converted into a state in which it can be mixed, processed, and vulcanised

again. The available processes are chemical, ultra-sound, microwave, and biological

processes. They all are very costly technologies which need highly skilled personnel and

experience.

Granulate or meal could be used for several purposes, such as:

Filler material for the rubber industry,

Shock-absorbing floor covering (for sport halls and playgrounds)

Formed/ shaped parts and mats

Thermoplastic elastomers



18

Granulated material/ pellets for horticulture and landscape architecture

Oil absorbent

Granulated material/ pellets as additive for asphalt

As it can be seen in the list above, the further utilisation of granulated material requires

further industrial processes. Taking the high shredding costs and the industrial facilities in

Kenya into consideration, it can be said that the utilisation potential of the granulated

waste tyres is very limited.

Energy Recovery

Both in North America, as well as in many European countries, the energy recovery is

currently the quantitatively most important disposal method for used tires. For energy

recovery four alternatives are available:

Co-combustion in the cement industry

Use of waste tyres as auxiliary fuel in coal-fired power plants

Combustion of waste tyres in power plants exclusively designed for the combustion of

waste tyres

Pyrolysis

In Germany, the cement plants are with about 250,000 tons per year by far the largest

user of end of life tyres. Due to high combustion temperature in the rotary kilns even

whole tyres can be burned safely and environmentally friendly.

Currently there is no coal-fired power plant in Kenya. Kenya is highly dependent on hydro

power plants and in times of dry hydrology emergency thermal power must be used. In

order to prevent this, the Kenyan Government plans to construct a coal-fired power plant

north of Mombasa near a cement plant in Kilif. The 300MW-plant is planned to be in

operation earliest in 2016. Since it is in the planning phase, it might be an option to

consider the use tyre derived fuel in this plant. However, for the purpose of this study it is

not clear, if this option indeed will be considered in the plant design.

The construction of a separate power plant exclusively designed for the combustion of

waste tyres requires huge investments, know-how and a significant planning. The current

small quantities of waste tyres and absence of a well implemented reverse logistic system

and experiences do not allow the justification of the implementation of such a plant.

With pyrolysis the waste tyres are thermally degraded in the absence of oxygen (without

combustion). Although technical feasibility of the pyrolysis has already been proved, it is



19

very complex and economically not viable. For instance, in the United States over 30

plants have been constructed, but all of them failed in terms of economical operation.

Conclusion

The utilisation of rubber from used tyres will remain in a small extent in future, but this

option cannot provide a nationwide solution for the entire waste tyre streams. More

sophisticated material recovery of waste tyres requires high investment costs, know-how

and a following processing industry. Since there is no coal-fired plant in operation and

separate power plants and pyrolysis currently are not economical options, the co-

processing in cement plants is considered as the most relevant solutions for the start of

the waste tyre management system. Certainly, analysis and development of alternative

marketing options should be an integral part of a future waste tyre management system.

3.2 Capacity for RDF Utilization in Cement Kilns in Kenya

In the Feasibility Study for Coprocessing the potential for utilization of waste tyres in

cement kilns in Kenya has been assessed. According to this estimation, the theoretical

potential for co-processing of waste tyres in Kenya is equivalent with the amount of

generated waste tyres. However, this estimation is just a theoretical figure, since it is

based on the assumption that all cement companies, indeed, are interested in buying the

waste tyres. For the cement companies this decision would require considerable

investments and modifications in their kilns and operations (see Feasibility Study Report

on Co-processing). So far, Bamburi is the only cement company in Kenya that clearly

stated its interest to utilise waste tyre. In fact, Bamburi has already adapted its kilns for

pre-processing of waste tyres and has started the collection and utilization of waste tyres.

With the current technical setup the capacity for waste tyre utilization at Bamburi is

possible for up to 6,000 tons per year. With a more sophisticated setup (requiring higher

investment) this amount could be increased to app. 20,000 tons per year.

3.3 Pre-Processing of Waste Tyres

Requirements for pre-processing are mainly defined by the later purpose of waste tyre

utilisation. In cement kilns waste tyres can be supplied in three different forms; as whole

tyres, as chips or as crumb. The different technologies are discussed in detail in the report

concerning co-processing in cement kilns.

Furthermore, transport of whole tyres is not very efficient, since the specific weight of

stapled tyres hardly exceeds 200 kg per m³. With baling, the specific weight for

transportation can be increased to app. 500 kg per m³, whereas crumb rubber would have

a density of more than 1000 kg per m³.



20

Table 5 Density of whole and shredded waste tyres

Tyre Form Density of Tyres

In bulk (stacked): 175 - 225 kg/m3

Baled: 400 - 500 kg/m3

Shredded (chips): 320 – 640 kg/m3

Shredded (crumb rubber): 1,150 kg/m3

3.3.1 Baling of Tyres

As can be seen from the table, there is considerable benefit in compressing the tyres.

Specific costs for baling are in a range of 6 to 10 US-Dollar per ton of waste tyres. These

costs have to be mirrored against savings in transport.

Figure 13 Tyre bales

3.3.2 Shredding of Tyres

Shredding and processing of waste tyres involves special technologies and based on

particle size and separation efficiency, fairly high costs have to be considered. In the

following table specific costs for different types of shredding are presented.



21

Table 6 Cost for shredding/processing of waste tyres7

Size Description Application

Cost per ton* (US-Dollar)

Process Rate (tons/hour)

2" (5.08 cm)

Clean cut. Ply & bead steel remains

Cement Kilns, Civil Engineering $10 10-12

2" (5.08 cm) minus

Minimal wire, cut beads removed by magnets

Industrial utility, pulp paper mill boilers $25 7

1" (2.54 cm) normal

Same as 2" minus with extra shredded pass

Power utility boilers (cyclone tspe) $10-$30 4-5

1/2 " (1.27 cm) minus

Truly wire free, requires additional shredding equipment

Feed stock for crumb rubber, playground and sport field surfaces $25-$55 2-3

*Cost per Ton includes power, labor, equipment and maintenance costs. No overhead profit or transportation included

As shown in the table above, average costs per ton are in a range of 10 to 55 US-Dollar.

Besides cutting the tyres, high effort is required for separation of wires from the rubber.

Certainly, costs for labour would be lower in Kenya compared to the US. However,

considerable part of the costs is for equipment and maintenance, which might even be

more expensive in Kenya.

3.3.3 Feeding of Waste Tyres into the Cement Kiln

The feeding of waste tyres as whole into the cement kilns is very common, since no pre-

processing of the tyres is necessary. However, some cement kiln designs are not suitable

for using whole waste tyres and must be modified to accept whole tyres. Furthermore, the

costs for transporting of tyres are higher than the transport of chips or crumps because of

low quantity per transport. The space requirements for the storage and handling of waste

tyres are high as well. Usually the tyres manually loaded on a conveyor connected to an

injection setup that inserts tyres into the kiln. Most of the injection setups insert one or two

tyres per kiln revolution (ca. 90 seconds). In Bamburi Cement Plant in Mombasa, the tyres

are weighed and according to their weight fed into the kiln. On average one tyre is fed

about every 5 minutes.

7 Source: US Rubber Manufacturers‘ Association, 2005: Considerations for Starting a Scrap Tire Company. A Blueprint for Planning a Business Strategy



22

Figure 14 Feeding of whole tyres

In order to feed the tyres continuously, they can be shredded up to a size of 15x15 cm to

2x2 cm. In addition to continuous feeding, the feed rate can be regulated precisely. Since

the feeding is regulated by automated systems, the investment costs are high, but

operating costs may be lower due to fewer requirements for manual labour. If the tyres are

shredded at the collection point, the transport costs can be minimised considerably.

In the crumb form, the waste tyres are blown in with pulverised coal into the cement kiln.

The pre-processing of waste tyres in order to bring them into the crumb form is very costly

and therefore not considered furthermore.

Currently the cement plant in Mombasa utilises whole waste tyres without any pre-

processing. However, the utilisation of tyre chips would bring some benefits to the cement

plant. E.g. the tyres can be fed continuously into the kiln and thus more waste tyres can

be utilised. Furthermore, the feed rate can be regulated precisely.

3.3.4 Options for the Transport of Waste Tyres

The shredded or baled tyres have an average density of 400 – 500 kg per cubic meter,

compared to less than 200 kg for whole tyres. Thus, the same container can transport

app. 2.5 times more tyres compared to transport of whole tyres in the same transportation

vehicle. On the other hand, costs for shredding and baling have to be considered in the

overall cost balance.



23

If the tyre chips are used, one important factor to be considered is the point of shredding.

Shredding could take place at

a) (central) collection point(s)

b) at the cement kiln

Shredding at the collection points at first sight seems to be more reasonable since this

supports transportation as well as co-processing in the kilns. However, since the tyres are

collected at different places, shredding would be required at each place. There are (semi-)

mobile shredders on the market, which could for example service different collections

points in the Nairobi area. Otherwise, using the same mobile shredder at the collection

point in Mombasa might not be very efficient due to the large distance between Mombasa

and Nairobi and the short transportation distance between the Mombasa collection point

and the Bamburi cement kiln.

Figure 15 An example mobile shredder for waste tyres

Furthermore, if Bamburi is responsible for shredding at their plant, they can exactly define

the processing according to the needs in the kiln. Thus, it might be preferable to use

baling for long distance transport of large amounts of waste tyres, whereas the shredding

(if required) should be done at the cement kiln.



24

4 Investigation of Possible Options / Scenarios for the Collection and

Coprocessing of Waste Tyres in Kenya

4.1 Scenarios for Coprocessing of Waste Tyres in Cement Kilns

As already mentioned, currently only Bamburi has stated interest in utilization of waste

tyres in its cement kilns. Thus, calculations are based on the possibilities at the Bamburi

kilns in Mombasa. Two different scenarios will be considered for

the further investigations which are both based on the capacities of the Bamburi kilns for

co-processing.

Scenario 1. 6,000 tons of waste tyres per year are delivered to the Bamburi cement

kilns in Mombasa

Scenario 2. 20,000 tons of waste tyres per year are delivered to the Bamburi cement

kilns in Mombasa

However, these are just theoretical scenarios, which are defined in order to analyse and

compare different options. In reality, assuming a successful implementation of the new

system, waste tyre amounts for scenario 1 will most likely be exceeded in a few years

(requiring additional solutions for waste tyre utilization). On the other hand it will take

several years to build up a system for collection of 20,000 tons of waste tyres per year

(scenario 2).

4.2 Integration of the Informal Sector into the Waste Tyre Management

System

As already stated burning of tyres for recovering and selling the steel in recent years

became an interesting business opportunity for the informal sector. A system for waste

tyre collection and utilization has been developed, which – from the point of costs and

efficiency - is functioning quite well.

The existing informal collection system can be used as well for the planned waste tyre

management system. The critical point is that payment for waste tyres should be

competitive to what people at the moment can earn from burning of waste tyres.

For the calculation below an average revenue of 20 KES per kg steel from waste tyres is

considered, paid to the primary collectors. Furthermore, in most cases, middlemen will be

involved, for example for collection of the tyres from the waste pickers and transportation

to the collection point. Thus, additional 10 KES per kg are considered for this purpose,



25

summing up to 30 KES per kg of scrap steel. As shown in the table below, currently a

small tyre will generate a revenue of app 45 KES, if the tyre is burned and sold to the

scrap dealer. In order to attract the informal sector and small enterprises to deliver the

tyres to the new waste tyre scheme, at least equal prices should be paid.

Table 7 Revenues from waste tyres, if steel is sold to scrap dealers after open burning

# Item Calculation Unit Tyre for passenger car

Van, Mini-bus Tyre

Truck tyre

1 Weight of tyre Kg 10 25 50

2 Percentage of steel % 15% 15% 15%

3 Weight of steel per tyre

= #1 x #2 Kg /tyre 1.5 3.75 7.5

4 Payment to waste picker for one tyre

= 20 KES x #3 KES / tyre 30 75 150

5 Payment to middle man for one tyre

= 10 KES x #3 KES / tyre 15 37.5 75

6 Revenue per tyre = Cost for tyre acquisition

= #4 + #5 KES / Tyre 45 112.5 225

The table above only gives an indication about the price range – since scrap prices are

fluctuating, the actual price might change over time. Indeed, Bamburi is already

successfully cooperating with the informal sector in the Mombasa region in order to

acquire waste tyres for the Mombasa cement kilns.

In this way, the present collection system can also be integrated into the new formal

system, provided that sufficient funding for paying a competitive price to the informal

sector can be secured. The following diagram shows the existing and the proposed waste

streams. In both systems the informal sector plays a major role.



26

Figure 16 Current and proposed future (waste) tyre streams

4.3 Scenarios for the Collection and Transportation of Waste Tyres

4.3.1 Implementation Steps and Amounts of Waste Tyres Collected

The formal collection of waste tyres will face several obstacles regarding technical,

financial and institutional issues. The stepwise implementation will help to see the

problems in time and to develop suitable solutions. In this way, the future investments and

institutional setup can be planned much better. For this purpose following stepwise

implementation of formal waste tyre collection is proposed.



27

Figure 17 Implementation steps of the formal waste tyre collection

In 2009 about 1.2 million vehicles were registered in Kenya, with an expected average

increase of 5 % per year. It is assumed that 80% of the vehicles are utilised in urban

areas which means that 80% of the waste tyres are generated in urban areas. Therefore

the proposed collection system focuses on urban areas. Nairobi and Mombasa are the

only cities with completely urban structure. In both cities waste tyre collection takes

already place. Nairobi because of its size and Mombasa because of existing cement

factories are selected for the first implementation locations. The collection system shall be

tested here for three years. After that the counties with higher urbanisation rates around

Nairobi, Kiambu and Machakos, and around Mombasa; Kilifi and Kwale, shall be

connected to the system. Since most of the waste tyres will be transported from Nairobi to

Mombasa and another large city Makueni is on this route, it shall also be connected to the

system. Again after three years of operation, the urban areas in the northwest of Nairobi,

particularly Nakuru and Kisumu, are included into the system. As already happens, it is

expected that from Nakuru waste tyres will be delivered to the cement plants by existing

tyre collectors before the formal collection is implemented. From 2021 on, in all urban

areas of the country, the waste tyres shall be collected separately.



28

Parallel to the stepwise extension of the collection system, the collection rate of waste

tyres will be increased. At the beginning of the implementation, the collection rate will be

low and expected to be 60% (of the generated quantity in the respective urban area). This

rate will progressively be increased to 80% until 2021 and 90% until 2030. Since there is

no data on the registered vehicle number in each county or city, it is assumed that the

number of vehicles is proportional to the population number (only for urban areas).

Following tables shows the estimated quantities of collectable waste tyre amounts until

2031.

Table 8 Collectable quantities of waste tyres

Year Total tyre generated

Total tyres from urban

areas

Collection rate in connected urban areas

Total collected in connected urban areas

tons/a tons/a % tons/a %

2012 52,606 42,085 60% 8,246 16%2013 55,237 44,189 60% 8,658 16%2014 57,999 46,399 65% 9,848 17%2015 60,899 48,719 65% 15,657 26%2016 63,943 51,155 70% 17,704 28%2017 67,141 53,712 70% 18,590 28%2018 70,498 56,398 75% 30,910 44%2019 74,023 59,218 75% 32,455 44%2020 77,724 62,179 75% 34,078 44%2021 81,610 65,288 80% 52,230 64%2022 85,690 68,552 80% 54,842 64%2023 89,975 71,980 80% 57,584 64%2024 94,474 75,579 85% 64,242 68%2025 99,197 79,358 85% 67,454 68%2026 104,157 83,326 85% 70,827 68%2027 109,365 87,492 85% 74,368 68%2028 114,833 91,867 85% 78,087 68%2029 120,575 96,460 85% 81,991 68%2030 126,604 101,283 90% 91,155 72%2031 132,934 106,347 90% 95,712 72%

It should be stated here again that the formal collection of waste tyres will not be

implemented in all urban areas from the beginning. The implementation will be stepwise,

and first in 2021 all urban areas will be connected to the collection system. The collection

rate compared to the total generated waste tyres will be 16% in 2012 and increase to 72%

in 2030.

4.3.2 Logistics for Collection, Pre-processing and Disposal of Waste Tyres

The logistical concept, presented below is looking at the first implementation step with

collection of waste tyres in Mombasa and Nairobi. Furthermore, the concept will be

developed for the scenarios defined in chapter 4.1 with utilisation of 6,000 tons per year



29

(scenario 1) respectively 20,000 tons per year (scenario 2) in the Bamburi cement kilns in

Mombasa.

Scenario 1 (6,000 tpa)

In Scenario 1 one collection point in Nairobi and one collection point in Mombasa shall be

implemented. From the collection points the tyres will be delivered to the Bamburi plant

via road transportation. The possibility of rail transportation has been analysed but was

found to be more expensive.

Figure 18 Collection, storage, and transportation of waste tyres in scenario 1

Scenario 2 (20,000 tpa)

For this purpose four collection points in Nairobi and one collection point in Mombasa

shall be implemented. One of the collection points in Nairobi shall be a central facility

where the whole tyres will be delivered from other collection points. From this collection

point the tyres will be baled and delivered to the Bamburi plant via road transportation. In

scenario 2 at this central point, the collected waste tyres will be baled and transported to

the cement plants.



30

In Mombasa one collection point will be established, from where the tyres will be

transported to the Bamburi kiln by road transportation as well. It is assumed that the waste

tyres from the Mombasa area will be transported to the cement kilns as whole tyres

without baling or shredding in both Scenarios.

Figure 19 Collection, storage, pre-processing and transportation of waste tyres in scenario 2

Storage of waste tyres

The required infrastructure is a ring fence, a gate, a management building including

sanitary facilities, appropriate fire protection equipment, a parking area for deliverer, and a

sufficient area for the baling of tyres. For the normal operation, one person will sufficient to

operate the facility. Taking the availability into consideration, two employees are

considered for the cost calculations.

The central facility to collect and bale the waste tyres (in scenario 2) in Nairobi must be

sufficient to store the waste tyres at least for one month.

The rules for the proper storage of waste tyres which are obligatory in a number of

countries are drawn up by the International Association of Fire Chiefs and the Scrap Tyre

Management Council (USA). These rules are also adopted by Basel Convention

Technical Guidelines on the Identification and Management of Used Tyres (2008).



31

Accordingly the piles should be limited to 6 m height with a maximum perimeter of 76 m

by 13 m. the edges of the pile should be at least 15 m from the perimeter fence. Since

tyres tend to slide down from the sides of the pile and close off the fire breaks, all interior

fire breaks should be at least 18 m wide. An area extending 60 m from the outside

perimeter of the piles should be totally void of trees, plants or vegetation. All exposures,

including buildings, vehicles or flammable materials should be at least 60 m away from the

tyre stockpiles. Piles or storage racks should not be located near or below power lines.

The area should be clear of debris and vegetation.

4.4 Costs for the Collection and Transportation of Waste Tyres

Based on the logistical concept in chapter 4.3.2 the costs for collection and transportation

have been calculated for the two scenarios. Costs are calculated as annual costs,

assuming that own trucks for transportation are used and no synergies (i.e. utilization of

places for storage and collection for different purposes) are considered. Actual cost might,

indeed, be somewhat lower, if for example opportunities for backhaul are utilized or if

storage places can be combined with other uses.

As stated in chapter 4.2 it is assumed that most of the tyres will be delivered by the

informal sector. In order to motivate the informal sector to collect and deliver the tyre, a

price needs to be paid, which is competitive to revenues from open burning and marketing

of steel. Thus, it is assumed that for tyre acquisition a price will be paid, which is

equivalent to potential revenues from selling steel scrap after open burning of tyres.

As shown in the calculation in table 8 (chapter 4.2), costs of KES 45 for a small tyre (10

kg) are considered, resulting in a price of KES 4,500 per ton. In practise cost reductions

might be possible, if companies from the tyre, auto, or transportation sector deliver their

waste tyres free of costs.

In the following tables, costs for the two scenarios are summarized.



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Table 9 Cost calculation collection, storage and transport for scenario 1

Position Unit Quantity Unit Cost

(KES) Amount (KES/a)

1 Collection points 2,992,000

1.1 Lease of land annual lease 2 330,000 660,000

1.2 Construction costs annual cost 2 770,000 1,540,000

1.3 Workers annual salary 4 198,000 792,000

2 Transportation costs Nairobi 20,179,500

2.1 Truck (40 m³)

annual cost incl. maintenance and repair 2 2,200,000 4,400,000

2.2 Driver annual salary 3 264,000 792,000

2.3 Fuel liter 125000 120 14,987,500

3 Transportation costs Mombasa 2,447,500

3.1 Truck (20 m³)



3.3 Fuel liter 5000 120 599,500

4 Costs for purchase of waste tyres 27,000,000

4.1 6,000 tons of waste tyres delivered annual cost 6,000 4,500 27,000,000

5 Administration and others 13,154,750

5.1 Administration (15% of subtotal 1-4) annual cost lump sum 7,892,850

5.2 Contingencies (10% of subtotal 1-4) annual cost lump sum 5,261,900

Total cost per year 65,773,750

Cost per ton KES per ton 10,962

Cost per small tyre (10kg) KES per tyre 110

Cost per large tyre (50 kg) KES per tyre 548

According to this calculation costs for collection, storage, and transportation amount to

app. 11,000 KES per ton of waste tyres respectively 110 KES for a small tyre (10 kg) and

548 KES for a truck tyre (50 kg).



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Table 10 Cost calculation collection, storage and transport for scenario 2

Position Unit Quantity Unit Cost

(KES) Amount (KES/a)

1 Collection points 5,588,000

1.1 Lease of land lease 4 330,000 1,320,000

1.2 Construction costs annual cost 4 770,000 3,080,000

1.3 Workers annual salary 6 198,000 1,188,000

2 Central collection point Nairobi 10,890,000

2.1 Lease of land lease 1 660,000 660,000

2.2 Construction costs annual cost 1 1,540,000 1,540,000

2.3 Baler


2.4 Forklifter


2.5 Workers annual salary 5 198,000 990,000

3 Transportation costs Nairobi 38,329,500

3.1 Truck (40 m³)


3.2 Driver annual salary 5 264,000 1,320,000

3.3 Fuel liter 200,000 120 23,980,000

3.4 Truck (20 m³)



3.6 Fuel liter 25,000 120 2,997,500

4 Transportation costs Mombasa 4,631,000

4.1 Truck (20 m³)



4.3 Fuel liter 10,000 120 1,199,000

5 Costs for purchase of waste tyres 90,000,000

5.1 20,000 tons of waste tyres delivered annual cost 20,000 4,500 90,000,000

6 Administration and others 37,359,625

6.1 Administration (15% of subtotal 1-5) annual cost lump sum 22,415,775

6.2 Contingencies (10% of subtotal 1-5) annual cost lump sum 14,943,850

Total cost per year 186,798,125

Cost per ton KES per ton 9,340

Cost per small tyre (10kg) KES per tyre 93

Cost per large tyre (50 kg) KES per tyre 467



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In the second scenario, costs for collection, storage, and transportation amount to app.

9,300 KES per ton of waste tyres respectively 93 KES for a small tyre (10 kg) and 467

KES for a truck tyre (50 kg).

4.5 Cost Balance for Collection and Transportation versus Revenues from

Marketing of Waste Tyres

The costs for the acquisition of tyres, temporary storage, and transport, are presented in

the chapter above. The utilisation of waste tyres in the cement kilns most likely will result

in savings (respectively revenues from selling the waste tyres to the cement industry),

mainly due to the fact that coal can be replaced by tyre derived fuel (TDF - see report on

co-processing). In the table below costs and savings are summed up.

Table 11 Cost balance of the waste tyre management system (revenues from selling waste tyres to the cement industry are shown as negative costs)

Unit Scenario 1 Scenario 2

Cost

collection Cost co-

processing Cost

balance Cost

collection Cost co-

processing Cost

balance

Cost per ton KES per ton 10,962 -7,158 3,804 9,340 -7,542 1,798

Cost per small tyre (10kg)

KES per tyre 110 -72 38 93 -75 18

Cost per large tyre (50 kg)

KES per tyre 548 -358 190 467 -377 90

As shown in the table, in both scenarios there is a deficit, which amounts to 3,800 KES

per ton of waste tyres in Scenario 1 and 1,800 KES / ton in scenario 2.

Most likely, this deficit can be reduced or possibly even brought to zero if for example

tyres are delivered for free, or transportation costs can be substantially reduced through

back hauling opportunities. These arrangements could for example be negotiated

between Bamburi and companies from the tyre sector (which actually already is the case).

Thus, scenario 1, most likely can be implemented, without additional funding and by

utilizing cost saving opportunities.

A national waste tyre management system, which in a stepwise extension process would

collect 20,000 tons of waste tyres per year (scenario 2) and more, however, could not fully

rely on such opportunities. Although the financing gap based on specific costs in

scenario 2 is smaller, financial sustainability has to be secured before implementation. For

example, Bamburi, would not do the required investments into the kilns, if the delivery of

20,000 tons of waste tyres cannot be guaranteed.

Another factor, which has an important impact on the costs of the waste tyre management

system, is the price of coal. If coal prices go up, waste tyre utilisation becomes more



35

attractive, if prices go down, savings from fuel switch are reduced as well (see figure

below).

Figure 20 Impact of coal price on the costs of the waste tyre management system

5 Assessment of the Organisational Setup for WTMK

In general there are two different approaches for the organisational setup of the future

(national) waste tyre management system in Kenya:

- the system could either be implemented with shared responsibilities of the

private sector and the Kenyan government, and financed by a tax

- or, the system could be exclusively based and implemented on the principle of

(extended) producer responsibility

Advantages and disadvantages of both options have already intensively been discussed

with the different stakeholders in the scope of the Strategic Alliance. The National

Environment Management Authority (NEMA) is favoring “extended producer

responsibility” where tyre producers and traders design and implement the system. The

companies from the tyre sector, which are partners in the Strategic Alliance, have

especially stated the importance that with regard to waste tyre management there should

be equal responsibilities and duties for all companies in the sector.

The possible organisational setup for both options is presented in the figures below.

‐15000

‐10000

‐5000

0

5000

10000

15000

0 5,000 10,000 15,000 20,000

Cost of Waste Tyre M

anagement System

[KES/ ton of waste tyres]

Cost of Coal [KES/ton]

Impact of Coal Price

Cost balance scenario 1[KES/ton of waste tyres]

Cost balance scenario 2[KES/ton of waste tyres]



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Figure 21 Organisational setup for a waste tyre management system with shared responsibilities of the private sector and the Kenyan government

In this option the National Environmental Management Authority would have a central

role. Based on an amended legal framework NEMA would establish a fund for financing

the system. Financing is based on a levy for imported tyres (including tyres on imported

vehicles) collected by the Kenya Revenue Authority (KRA) and transferred to NEMA.

Furthermore, there would be an equivalent tax for tyres produced in the country. Then,

NEMA will contract a company for implementation of waste tyre collection, storage, pre-

processing and marketing. Contracting has to follow the Kenyan legal requirements and

will be based on tenders.

Similar schemes already have been developed in Kenya for other purposes - but still the

establishment of the legal basis for a government controlled waste tyre system might be

complicated and time consuming.

Alternatively, the tyre sector could organise the waste tyre management system

independently and exclusively financed by the companies in the sector.



37

Figure 22 Organisational setup for a waste tyre management system exclusively organized and financed by the companies in the tyre sector

In this option the Kenyan tyre sector would establish a company for collection and

marketing of tyres. NEMA would issue waste tyres regulations and license companies

based on defined criteria.

The tyre sector then would also be responsible for financing of the waste tyre

management scheme. As shown in the cost balance in Chapter 4.5, the costs for the

waste tyre collection system most likely cannot be fully financed from revenues from

marketing waste tyre products. Thus, the tyre sector would have to contribute to the

funding of the system.

However, most of the tyres being used in Kenya are not produced in the country but are

imported either as tyre or vehicle. As shown in chapter 2.2 of this report, in the last three

years, 1,182 different companies imported tyres to Kenya. Once the tyres are in the

country it seems to be very difficult if not impossible to address these companies with

regard to financial contributions for the waste tyre management system.

Most likely, new and used cars are imported by a large number of different companies

(and individuals) as well – thus the same challenges as with the import of tyres have to be

addressed.



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Unfortunately, as discussed in December 2011, KRA cannot collect levies / taxis on behalf

of a private entity. Thus, within the option of extended producer responsibility revenue

collection via KRA does not seem to be possible.

Certainly, the future Kenyan Waste Tyre Regulations could request all tyre importers and

tyre producers to participate in approved waste tyre mechanism. However, control and

enforcement of such regulations in the Kenyan context seems to be very difficult.

Thus, an organizational setup for a waste tyre management system with shared

responsibilities of the private sector and the Kenyan government seems to be the most

promising option.

6 Conclusions and next steps

In 2011 app. 50,000 tons of waste tyres were generated in Kenya; a future average

increase of 5% per year is expected (see chapter 2). Presently, the majority of waste tyres

are collected and burnt in an open space, for example in dumps or other selected

areas, to recover steel strap which is then sold off to metal dealers and industrial

manufacturers for a fee.

Burning of tyres is done discreetly as it is outlawed and perpetrators are sometimes

arrested and arraigned in court. Open air burning of these tyres results in emission of

hazardous gases like dioxins, mercury, hydrogen chloride, sulphuric acid, flourides and

particulates that can damage human health.

In chapter 3 different options for waste tyre utilization are briefly presented and assessed.

Advanced material recycling solutions are fairly expensive and don’t offer a realistic

solution for Kenya at the moment. Presently, the coprocessing of waste tyres in cement

kilns is recommended as the most economical solution in Kenya.

The Costs / revenues have been analysed for 2 scenarios (6,000 tons/a and 20,000

tons/a of waste tyres). Implementation of WMTK will start with scenario 1, whereas

scenario 2 requires a well-developed collection system, which might take several years to

be implemented. In both scenarios the costs of the system cannot be financed from

revenues; thus additional funding sources are needed.

Since most of the tyres in Kenya are imported, the best option to collect a levy on tyres

would be the involvement of Kenya Revenue Authority (KRA). Revenue collection by

KRA, however, requires amendment of existing laws and a key role of the National

Environmental Management Authority (NEMA). Based on an amended legal framework

NEMA would establish a fund for financing the system. Financing is based on a levy for



39

imported tyres (including tyres on imported vehicles) collected by the Kenya Revenue

Authority (KRA) and transferred to NEMA. Furthermore, there would be an equivalent tax

for tyres produced in the country. Then, NEMA will contract a company for implementation

of waste tyre collection, storage, pre-processing and marketing.

Based on the cost calculations presented in chapter 5 the following levies to cover the

financial gap are proposed:

5 KES per kg tyre or tyre material, resulting in

KES 50 for a small tyre

KES 250 for a truck tyre

Assuming a selling price between KES 10,000 for a small tyre and KES 50,000 for a truck

tyre the proposed levy would make up 0.5% of the selling price.

The next working steps to achieve the objective of phase 1 of the Strategic Alliance

(technical concept and regulatory framework for WTMK available) comprise:

- Detailing of the technical concept and modalities of contracting

- Securing backing of the proposed solution from Ministry of Environment and

Ministry of Finance

- Raising public awareness on waste tyres issues (especially negative impact of

open burning)

- Drafting of waste tyre regulations

Darmstadt, 25 March 2012

INFRASTRUKTUR & UMWELT

Professor Böhm und Partner

Dipl.-Ing. Gernod Dilewski

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