EPR Tyre Registration

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EPR for Tyre Waste:

The Extended Producer Responsibility (EPR) for Waste Tyres entails the obligation placed on tyre producers to ensure the environmentally responsible management of end-of-life tyres. Its purpose is to safeguard both public health and the environment from the potential negative impacts arising from waste tyres. This regulatory framework was introduced by the Ministry of Environment, Forest, and Climate Change through the Hazardous and Other Wastes Amendment Rules, 2022. Effective from July 21, 2022, this amendment includes a comprehensive Schedule IX that outlines provisions for the proper utilization and management of waste tyres by producers, recyclers, and retreaders. By adhering to these guidelines, the tyre industry contributes to a sustainable and eco-friendly waste management system.

The EPR for Waste Tyres regime imposes obligations on producers, importers, and brand owners involved in the manufacturing and sale of new tyres, as well as importers of waste tyres. They are required to comply with extended producer responsibilities, which involve establishing a network for collection, transport, recycling, or disposal of end-of-life tyres. This system aims to ensure that waste tyres generated or imported into the country are managed in an environmentally sound manner. The Amendment Rules also cover retreaders who replace worn treads with new ones. This guide provides comprehensive information for all entities in the tyre manufacturing and management sector regarding the registration process and their responsibilities in post-compliance on the centralised CPCB portal.

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Benefits of EPR Tyre Waste:

Indeed, the benefits of EPR extend beyond the mere requirement for obtaining certification or searching for EPR certificates for rubber/waste tyres. Let’s explore these benefits in detail:

Reduces reliance on other waste disposal methods

EPR reduces the dependence on traditional waste disposal methods like burial or burning. Instead, it promotes environmentally responsible practices such as recycling, refurbishment, and proper waste management.

Minimizes burden on local municipalities

By shifting the responsibility of waste management to producers, EPR relieves the burden on local municipalities. This reduces the physical and financial strain on these entities, allowing them to focus on other essential services.

Ensures proper recycling and refurbishment

EPR emphasizes the importance of proper recycling and refurbishment of products and their parts. This ensures that valuable materials are recovered and reused, reducing the need for extracting and processing new raw materials.

Facilitates easier and quicker disassembly

EPR encourages product designs that facilitate easier and quicker disassembly. This makes it easier to separate components and materials for recycling or refurbishment, improving overall resource efficiency.

Encourages conservation of natural resources

Through its focus on recycling and reuse, EPR promotes the conservation of natural resources. By extending the lifespan of products and reducing the demand for new materials, EPR contributes to the preservation of valuable resources.

Decreases the amount of waste generated

EPR aims to minimize waste generation by promoting responsible consumption, product design, and waste management practices. By reducing waste at the source, EPR helps in creating a more sustainable and circular economy.

Documents Required For EPR Tyre Registration

Business Registration Documents
  • GST Certificate
  • Import Export Code (IEC)
  • Certificate of Incorporation (COI)
  • PAN Card of the Company 
  • MSME Udyam Registration Certificate (Optional)
KYC Documents
  • Aadhaar Card/PAN Card/Email ID and Mobile no. of directors or of Authorized Signatory.
  • Designation of Authorized Signatory and Authorization.

(The Aadhar number of the authorized person is necessary for verifying the identity of the individual responsible for waste tyre management activities.)

Other Data
  • Covering letter – As per Annexure A (given in the official Instruction Sheet)
  • Undertaking – As per Annexure B (given in the official Instruction Sheet)

In addition to the mentioned requirements, the applicant must also provide the following documents for fulfilling EPR for Waste Tyres:

  1. Proof of ownership or lease agreement for the premises where waste tyre management activities will take place.

  2. Detailed information regarding the proposed EPR plan, including strategies for collection, storage, transportation, processing, and disposal of waste tyres.

  3. Environmental clearances or No Objection Certificates (NOCs) from the relevant environmental authorities, ensuring compliance with environmental regulations.

These documents are essential for the evaluation and approval of the EPR application for Waste Tyres.

Requirement for EPR Tyre Waste

The key requirements in the Amended Rules contain the following:

Entities seeking to comply with the Extended Producer Responsibility (EPR) for Waste Tyres must undergo registration on the CPCB portal before initiating or continuing their business activities. The EPR obligation under the Amended Rules is categorized based on registration status:

  1. Producers of New Tyres: For manufacturers or importers of new tyres, the EPR obligation is as follows:

    • In the first year of the Schedule’s enforcement (2022-2023), the EPR obligation is 35% of the quantity of new tyres manufactured or imported in 2020-2021.
    • In the following year (2023-2024), the EPR obligation increases to 70% of the weight of tyres manufactured/imported in 2021-2022.
    • In 2024-2025, the EPR obligation reaches 100% of the weight of new tyres manufactured/imported in 2022-2023.
    • From 2025 onwards, the EPR obligation remains at 100% of the weight of new tyres manufactured or imported two years prior (Y-2).
    • Units established after April 1, 2022, will have a deferred EPR obligation, which starts after two years, and will be 100% of the weight of new tyres manufactured/imported in the year (Y-2).
  2. Importers of Waste Tyres: Importers of waste tyres bear an EPR obligation equivalent to 100% of the tyres imported in the previous year (Y-1).

  3. Retreading: The EPR obligation for waste tyres that undergo retreading is deferred for one year.

Producer Responsibility under EPR Tyre Waste

Producer Responsibility under EPR for Waste Tyres encompasses various entities involved in the manufacturing, selling, and import of tyres. Here are the key points related to producer responsibility:

  1. Definition of a Producer: A “producer” refers to individuals or entities engaged in the following activities:

    • Manufacturing and domestic sale of new tyres.
    • Selling new tyres manufactured by other suppliers under their own brand domestically.
    • Domestic sale of imported new tyres.
    • Importing vehicles fitted with new tyres.
    • Automobile manufacturers importing new tyres for use in domestically sold vehicles.
    • Importing waste tyres.
  2. Fulfilling EPR Obligations: Producers are required to fulfill their EPR obligations by purchasing EPR certificates from registered recyclers and submitting them on the CPCB portal through quarterly returns (as per Rule 7 of the Amendment Rules).

  3. Composition Details of Tyres: Producers need to provide detailed information about the composition of the tyres, including average weight, materials used such as natural rubber, synthetic rubber, process oil, steel wire, textile fibers, carbon black, silica antioxidants, anti-ozonants, curing system, and other materials if applicable. The total weight of materials used should also be provided.

Responsibilities of Recyclers under EPR Tyre Waste:

  1. Role of Recyclers: Recyclers are responsible for converting waste tyres into environmentally friendly end products. These end products can include reclaimed rubber, crumb rubber modified bitumen, crumb rubber, recovered carbon black, and pyrolysis oil/char. Recyclers play a crucial role in ensuring proper waste tyre management and recycling.

Responsibilities of Retreaders:

  1. Retreaders’ Registration: Retreaders who engage in the retreading of waste tyres must first register on the CPCB portal to issue retreading certificates.
  2. EPR Obligation for Retreaders: The EPR obligation for retreaders has been deferred for one year (till 2023) upon providing the required certificates. However, the obligation is extinguished after the end-of-life disposal of retreaded tyres through a registered recycler.

Procedure of applying for EPR Tyre Waste

  1. Visit the designated portal and locate the application form.
  2. Fill in the required details, including personal information, activity details, and the proposed EPR plan.
  3. Gather all necessary documents, such as proof of ownership/lease of premises, details of the proposed EPR plan, and any environmental clearances or NOCs required.
  4. Attach the relevant documents to the online application form.
  5. Ensure that the application and supporting documents are submitted within the specified timeframe, typically 30 days.
  6. Once the application is received, the Central Pollution Control Board (CPCB) will review it.
  7. Within 15 days, CPCB will provide a registration number for the application.
  8. The authorized person must adhere to all EPR regulations and submit regular reports to CPCB to update them on the progress of waste tyre management activities.
  9. If the application is approved, the applicant will be issued an EPR authorization certificate, which will remain valid for a period of two years.

Transaction of extended producer responsibility certificates

In the transaction of Extended Producer Responsibility (EPR) certificates, producers have the following options:

  1. Purchase Limit: A producer can buy EPR certificates limited to its EPR liability for the current year (Year Y), including any remaining liability from previous years, and an additional 10% of the current year’s liability.

  2. Quarterly Purchase: Producers also have the flexibility to fulfill their EPR obligation by purchasing EPR certificates on a quarterly basis. This allows them to proportionately meet their liability throughout the year.

The availability, requirement, and other relevant details regarding EPR certificates will be regularly updated on the designated portal. Producers can refer to this information to determine the quantity and timing of their EPR certificate purchases to meet their obligations effectively.

Provision for Post Compliance and Inspection of Producers

The Central Pollution Control Board (CPCB) holds the authority to ensure compliance with extended producer responsibility (EPR) by producers and recyclers. To ensure adherence to EPR obligations, CPCB may conduct inspections and periodic audits as deemed necessary.

In case of violations or non-fulfillment of EPR targets, obligations, or responsibilities, appropriate actions will be taken by CPCB. These actions may include penalties, fines, or other measures as per the regulations and guidelines set by the CPCB and relevant authorities. The aim is to enforce EPR compliance and encourage responsible waste management practices among producers and recyclers.

Penalties for Non-Compliance

Entities that provide false information to obtain excess EPR certificates or deliberately violate provisions of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules may face prosecution and penalties in the form of Environmental Compensation. The Environment (Protection) Act holds producers, recyclers, and retreaders accountable for violations.

If a shortfall in EPR obligation is addressed within three years, the applicant may be entitled to a refund. However, payment of compensation does not absolve entities from fulfilling their EPR obligations or unfulfilled targets. The shortfall will be carried forward to subsequent years for up to three years.

Environmental compensation can be imposed on recyclers for providing false information or issuing false EPR certificates. Additionally, unregistered producers, recyclers, and entities aiding violators in violating the provisions may also be liable for compensation.

It’s important to note that refund criteria will be applicable for eligible cases, but the EPR obligation or unfulfilled targets must still be addressed.



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