Australian OTR Tire Disposal — Capability Brief

01 · THE AUSTRALIAN CONTEXTThe challenge for Australian mining operators

Australian mining fleets generate more end-of-life giant OTR tire material per year than the domestic recycling industry can absorb. The 2023 Federal whole-tire export ban tightened the path further. The 2027 ICMM and TSA review windows are tightening documentation expectations on Scope 3 waste streams. We've built a chain designed for exactly this moment.

Why this is structural, not cyclical

The capacity gap isn't a procurement preference — it's a physics problem. Australian recyclers built for passenger and truck tires can't process 63"+ giant OTR mining tires at the volume Pilbara generates. Roller mills, granulators, and shredders sized for passenger tires choke on a 5,300 kg 59/80R63 OTR. The 2-3 small-scale Australian operators that handle giant OTR run at fractional capacity vs the demand. Meanwhile, Tyre Stewardship Australia's accreditation focus has been (correctly) on the largest segment by tire count — passenger and commercial — not by tire mass.

The 2023 export-ban amendment makes the problem more acute. Operators previously routing whole baled tires to ambiguous overseas reuse now face a cut-or-cleanly-document choice. Cut-in-sections material destined for documented material or energy recovery (Basel Annex IX) is the lane that remains open — and that lane requires documentation discipline most operators haven't built.

What's coming in 2027

BHP's Climate Transition Action Plan and ICMM Mining Principles' Performance Expectations 6 (resource efficiency) and 8 (environmental performance) are scheduled for tightened audit treatment in the 2027 review cycle. ESG audit firms (KPMG, EY, Deloitte) are already pre-positioning their mining audit teams to ask harder questions about chain-of-custody documentation on waste streams. The audit-defensibility frame that's optional today is mandatory by then.

02 · WHAT WE BRINGAn audit-grade chain, multi-origin, designed for this moment

Americans Trades is a permitted scrap-tire disposal operator. We are actively bidding for first commercial flows in Chile under Ley REP, with locally-permitted yard infrastructure (20-acre Antofagasta partner facility, all certifications), South Asia industrial recovery offtake contracted, and a multi-country operating architecture that extends directly to Australian operations. We'd like to develop Australia in parallel — same architecture, same documentation discipline.

03 · PROCESSHow a typical shipment moves, end to end

From yard receipt to discharge at destination — every stage documented, photographed, weighed, certified. The architecture is the same regardless of origin jurisdiction.

04 · MULTI-ORIGIN ARCHITECTURESame chain, multiple sourcing jurisdictions

The operating architecture is jurisdiction-portable. Phase 1 in any new market validates the chain locally; Phase 2 scales to monthly cadence. Below: where the architecture is engineered or being commissioned today, and where it extends naturally.

Why a multi-origin architecture matters for an Australian operator

Mining majors run global operations. A single global supplier relationship that handles OTR disposal across multiple operating jurisdictions reduces vendor governance burden, simplifies audit consolidation across regions, and creates negotiation leverage on commercial terms. The same chain-of-custody dashboard, the same monthly audit pack, the same documentation discipline — across BHP Iron Ore Australia, BHP Olympic Dam, BHP Coal, and any future South American operations.

05 · THE DOCUMENTATION CHAINThis is the moat

Most disposal operators move material. We move material AND documentation. The documentation pack — generated at every stage and delivered to your audit team in real time — is what separates audit-defensible disposal from "we shipped it overseas."

06 · PHASE 1 — PROOF OF CONCEPTSeveral containers · validate end-to-end before scale

Phase 1 is a several-container proof-of-concept shipment from a single origin site, designed to validate every counterparty assumption — documentation, customs, ocean freight, destination acceptance, audit defensibility — before any larger commitment. Your team audits the result before any further conversation.

What Phase 1 looks like

What Phase 1 specifically validates

• Commercial: mining client signs and pays · destination buyer's NOC and import authorisation hold · pricing structure validated under real conditions (commercial terms tabled at MSA, not in this brief)
• Operational: excavator + shear cycle time per tire under your specific OTR mix · container stuffing density at 21 t/container target · cut-piece quality matches destination buyer's recovery-feedstock spec · yard logistics, receiving, weighing, and chain-of-custody flow under live operations
• Regulatory: Australian export documentation accepted by DCCEEW · WA DWER (or QLD DOEHP) licensing approach validated · destination Sindh EPA/MoCC NOC accepted on import · HS 4012.20 classification holds · Basel Annex IX (B3140) recovery designation accepted
• Audit: documentation chain measured against ICMM PE 6 + 8 by your internal audit team · documentation chain pre-reviewed by Big-4 ESG auditor · processing-loss reconciliation under 1%
• Financial / contracting: working-capital cycle measured precisely · FX exposure measured live · marine insurance, freight, port fees reconciled to budget · payment cycle end-to-end

What we'd ask of you for Phase 1

07 · PHASE 2 & BEYONDScale to monthly cadence; expand scope

Phase 2 commences after Phase 1 validation. The architecture moves from container scale to private-charter handysize bulk cadence. Phase 3 expands scope to additional sites and contractor fleets.

08 · REGULATORY FRAMEWORKThe codes we operate under

Regulatory fluency is part of the moat. Below: every code that touches the operation, on both sides of the trade.

Australian regulatory anchors

International & multi-origin anchors

09 · ICMM MAPPINGWhere our chain delivers against the Mining Principles

The ICMM Mining Principles aren't an afterthought in our model — they're the design specification. Our documentation chain is built specifically to deliver evidence against PE 6 and PE 8.

This mapping isn't theoretical. We've engineered the chain so that each piece of documentation it generates corresponds to a specific ICMM evidence requirement. Your sustainability team isn't translating our outputs into ICMM language — they're consuming ICMM-aligned outputs directly.

10 · INDIGENOUS ENGAGEMENTOur approach in the Australian operating context

WA Pilbara has Native Title Act and Indigenous Land Use Agreement implications. Queensland Coal has separate Indigenous engagement frameworks. Our default approach: zero new touch-points, active participation welcomed.

We approach Indigenous engagement as a value-add to the operating model, not a compliance overhead. The MSA can be structured to embed Indigenous business participation targets and cultural heritage commitments directly — making the arrangement defensible to BHP's community-relations and sustainability teams from the outset.

11 · WHY USWhat separates a serious operator from a first-time entrant

In a category where most operators are scaling up, here's what we bring that differentiates the offering.

12 · FREQUENTLY ASKED QUESTIONSAnticipated questions and how we'd answer them

13 · CONTACTLet's talk about Phase 1

If the architecture above fits a problem you're solving, the next step is a sustainability + procurement working session.