Overview of the Registration under EPR for Waste Tyres
India discards approximately 275,000 tyres each year; over and above this number, about 3 million waste tyres are imported for recycling. To deal with tyre waste Management, the government implemented the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, in 2016. It laid down the responsibilities of producers of tyres, as well as the recyclers and re-treaters. After many subsequent amendments, the MoEF&CC notified the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022, in July 2022. which made a compulsion of Extended Producer Responsibility (EPR) for Waste Tyres.
Producers must register on the CPCB’s centralized EPR portal mandatory for producers, recyclers and re-treaters. The 2022 amendment also had provision for the utilization and management of waste tyres through the Extended Producers Responsibility regime w.r.t waste tyres as per schedule-IX of the 2022 Rules. The centralized portal for the waste tyre management system, which is an online portal, has become active. All the stakeholders, like producers, recyclers and re-treaters, must register to continue operations in the country. The present EPR obligation module is limited to online submission of information related to quantities of tyres introduced into the market by producers and generation of EPR obligation.
Obligations of Producer under EPR for Waste Tyres
As defined in paragraph 1(e) of the 2022 Rules, EPR applies to producers, that includes the manufacturers as well as the importers and brand Owners (PIBOs) that deal in
-
- Manufactures and sells new tyres domestically; or
- Sells domestically under its brand, new tyres manufactured by other manufacturers or suppliers
- Sells imported new tyre
- Imports vehicles fitted with new tyres
- Automobile manufacturers importing new tyres for use in new vehicles sold domestically.
- Imports waste tyre
As defined in paragraph 1(f), of the 2022 Rules, ‘‘recycling’’ is the conversion of the waste tyre into end products in an environmentally sound manner and possessing facilities as elaborated in the SOP as specified by the CPCB.
-
- Reclaimed Rubber
- Crumb Rubber
- Crumb Rubber Modified Bitumen (CRMB)
- Recovered Carbon Black
- Pyrolysis Oil or Char
After the amendment of the rules in 2022, the responsibilities of producers, recyclers and retreaders w.r.t EPR for Waste Tyres were fixed. Producers have been assigned the responsibility to recycle waste tyres equivalent to the weight of new tyres that they had manufactured or imported in the previous year. For importers of waste tyres, the EPR obligation will amount to 100 % of the waste tyres they imported in the previous year. The entities will have to submit their manufacturing data as per the following directions.
| Businesses established before FY 2019-20 | Businesses established in FY 2020-21 | New Producers |
| manufactured quantity/import quantity is to be provided from FY2019-20 onwards | manufactured quantity/import quantity is to be provided from the year of their establishment onwards. | Those businesses that have not carried out any manufactured quantity/import so far mention should mention “0 (Zero)” in the manufacturing data submission table. |
Note: After the year 2024-2025 (year Y), the extended producer responsibility obligation shall be 100% of the quantity of new tyres manufactured or imported in the year (Y-2). Also, Units established after the 1st of April 2022, the extended producer responsibility obligation shall start after two years (Y) and should be 100% of the new tyres manufactured or imported in the year (Y-2).
Role of Recyclers in the EPR Regime
Further, as per provisions of paragraph 7 of Schedule —IX, the above entities are required to fulfil their EPR obligation through the online purchase of EPR Credits or retreading credits through registered recyclers and retreaders of the waste tyre. The EPR obligation for the producers of new tyres has been fixed as follows.
Note: The extended producer responsibility obligation for waste tyre importers and recyclers in the year (Y) will be 100% of the tyre imported in the year (Y-1). The import of waste tyres to produce pyrolysis oil or char is prohibited.
General Instruction for all Entities
Applicants can opt for multiple categories of producers based on their business. The applicant has to upload a cover letter making a formal request to CPCB for registration at the online portal. The cover letter should be on the company’s letterhead and has to be signed by the authorized person, and should have the company’s seal. The scanned cover letter copy must be uploaded on the portal. He must, however, Specify the category of producers as per business activities carried out by him on the application.
The documents uploaded in the application should have a uniform address and match the address mentioned in the registration form. Applicant to provide accurate and verified data w.r.t its manufacturing & import. Documents in support of submission should be available in the producer’s office and can be verified by officials of CPCB/SPCB at any time.
How we are helping clients?
Our team of professionals can provide a solution for evaluation, applying for registration, assisting in representing before the authorities, including for resolution of ambiguity and assisting in annual filings.