Chile Strategic Action Plan — Displacing the Tire-Disposal Incumbent

VECTOR 1 · Direct mining-client engagement (the audit question)Highest leverage

The play. Walk into procurement and sustainability conversations at Codelco, BHP Escondida, Antofagasta Minerals, Anglo American Chile and Glencore Collahuasi with a single question: "Can your current tire-disposal vendor produce, in writing, the documented final destination of every ton you've paid to dispose of in the last 24 months?" Hand them the chain-of-custody self-audit one-pager (already built). Don't name the incumbent. Let the mine's own internal verification fail.

Sequence: Open with the question · hand the audit one-pager · calendar 30-day follow-up · let internal verification surface the gap · come back with the spot-test offer.

Proof-of-concept ask: 100-tire spot test (already modeled — 530 t · 25 containers · ~70-day cycle · ~$64K margin). Side-by-side: AT delivers the documented disposal under the SAME fee structure the incumbent is already collecting.

Target accounts (priority order): Codelco (state-owned, highest audit pressure) · BHP Escondida (CAT 798 fleet conversion creates one-time disposal pulse) · Antofagasta Minerals (London-listed, strict ESG KPIs) · Anglo American Chile · Glencore Collahuasi.

Risk: Mines may be politically aligned with the incumbent. Mitigation: lead with their auditors and sustainability functions, not procurement (which may have signed the original contract).

VECTOR 2 · Regulatory escalation (MMA Chile + Ley REP authority)Highest structural leverage

The play. File a discreet position paper with the MMA's Oficina de Economía Circular and the Ley REP authority (leyrep.cl) addressing a clarifying question: "Does material accumulated at a domestic vendor's yard, without documented onward processing or final destination, satisfy the Ley REP recycling-rate compliance requirement?" Frame it as a technical inquiry from a candidate compliance operator seeking guidance for our own program design — NOT as an accusation.

Why this matters: If the MMA clarifies that "stockpiling without documented downstream destination" does not satisfy compliance, every mine using the incumbent loses Ley REP coverage overnight. The market is forced. AT becomes the natural alternative they call.

The framing: AT is "a certified operator preparing to enter the market with full chain-of-custody documentation including export to permitted overseas processing facilities, and we want to confirm with the authority that this approach satisfies Ley REP." We are seeking validation, not casting blame.

Likely outcome: 60-90 days for MMA to respond. Even an informal verbal answer ("yes, you need documented downstream destination, not just receipt") is enough to use in mining-client conversations: "We confirmed with the MMA that documented disposal requires a verified final destination. Here's our approach. What does your current vendor's documentation look like?"

Risk: If the incumbent has political connections inside MMA, our inquiry could leak and trigger pre-emptive action by them. Mitigation: deliver via a Chilean lawyer (not direct), frame as candidate-operator guidance request, deliver to the technical team (Economía Circular technical staff) not the political appointees.

VECTOR 3 · Tire importer / OEM consortium (the people legally on the hook)High leverage

The play. Under Ley REP, tire importers (Michelin Chile, Bridgestone Chile, Goodyear Chile, Continental, Pirelli) are the legal producers responsible for ensuring tires they sell are recycled. They contract operators like Rembre to do this on their behalf — but the legal liability stays with them. Approach the importer consortium (CAMCHAL — Camara de Comercio Chileno-Alemana hosts importer working groups; or directly to each importer's compliance/sustainability lead) with the same chain-of-custody question.

Why this works: Tire importers face Ley REP fines that scale with non-compliance. They're the ones who write the compliance check to the operator. If they can't validate that the operator is actually disposing rather than stockpiling, they personally carry the audit liability — not the operator. They have the strongest motivation to switch.

Sequence: Compliance / regulatory leads at Michelin Chile and Bridgestone Chile first (they're already AT's familiar names from prior account analysis) · approach as a "compliance complement / backup capacity partner" rather than a Rembre replacement · let them quietly redirect volumes once we're approved.

Risk: Tire importers don't want to publicly distance themselves from incumbent vendors (no one wants to admit their compliance partner was inadequate). Mitigation: position as "expanding capacity," not "replacing failed vendor." Quiet redirection rather than public switch.