EPR Compliance for Waste Tyre

Table of Content

India annually discards approximately 275,000 tyres without a comprehensive disposal strategy, while an additional three million used tyre scraps are imported for recycling purposes. The National Green Tribunal (NGT) has instructed the Central Pollution Control Board (CPCB) to develop a comprehensive waste management plan for the proper handling and recycling of End-of-Life Tyres (ELTs) in response to issues related to inadequate management practices.

Effective management of tyre waste is now a pressing global concern amidst growing emphasis on environmental sustainability. The accumulation and disposal of used tyres pose significant threats to ecosystems and public health. Addressing these challenges, registration under Extended Producer Responsibility (EPR) for waste tyre management has emerged as a vital strategy to mitigate the environmental impact of tyre waste.

Introduction

"EPR for Waste Tyres" denotes the responsibility mandated for tyre manufacturers to ensure environmentally safe disposal of old tyres, preventing harm to human health and the environment. The Ministry of Environment, Forests, and Climate Change released the Hazardous and Other Wastes Amendment Rules, 2022 for EPR for Waste Tyre. Effective from July 21, 2022, this amendment introduces Schedule IX, detailing guidelines for the proper handling and utilization of discarded tyres by manufacturers, recyclers, and retreaders.

This article will comprehensively outline the registration process for all entities involved in tyre production and management, along with their respective responsibilities post-compliance on the unified CPCB portal.

Application Scope

The following parties are bound by the regulations outlined in Schedule IX:

1.Producer :refers to any individual or organization that

Manufacturers producing and selling new tyres domestically.
Retailers selling new tyres manufactured by others under their own brands (Brand Owners).
Retailers importing and selling new tyres (Importers).
Importers bringing in vehicles with new tyres.
Automakers importing new tyres for newly launched vehicles sold domestically.
Importers bringing in waste tyres.

2.Recycler : Any individual or organization engaged in the eco-friendly practice of transforming used tyres into the following products through recycling.

Reclaimed rubber
Crumb rubber
Crumb rubber modified bitumen (CRMB)
Recovered carbon black, suitable as raw material for producing new tyres
Pyrolysis oil or char is utilized solely as a fuel and is not employed as a raw material in the manufacturing of new tyres.

3.Retreader : Any individual or organization involved in renewing worn-out tyres by replacing the tread and sidewall rubber, ensuring strong structural integrity.

Advantages of EPR Certification for waste tyre management

Environmental Responsibility:EPR certification for waste tyre management promotes environmentally-friendly practices. Manufacturers are held accountable throughout the tyre lifecycle, encouraging proper recycling and disposal. This reduces illegal dumping and landfill waste.
Resource Conservation: EPR registration supports the recycling and recovery of valuable materials from tyres. This promotes a circular economy by reducing the need for new raw materials and extending resource use.
Energy Efficiency:Recycling tyres consumes less energy compared to manufacturing new ones from scratch. EPR encourages the establishment of tyre recycling facilities, where tyres can be processed into products like rubberized asphalt and building materials, reducing energy consumption and greenhouse gas emissions.
Economic Development:EPR initiatives for waste tyres stimulate economic growth by creating jobs in recycling facilities and related industries. Investments in tyre waste management contribute to local economies through roles in collection, sorting, processing, and manufacturing of recycled products.
Regulatory Compliance:EPR for waste tyre management ensures that tyre manufacturers meet their waste management responsibilities. It enforces proper handling of tyre waste, deters illegal dumping, and fosters a cleaner, sustainable waste management system by holding producers accountable.

Amendment for Extended Producer Responsibility (EPR) in waste tyre management

Producers, importers, and brand owners engaged in manufacturing and selling new tyres, along with importers handling used tyres, must adhere to EPR standards for waste tyre management. These guidelines involve establishing systems for collecting, transporting, recycling, or responsibly disposing of used tyres. This approach ensures responsible management of both imported and domestically produced used tyres. The updated regulations also extend to retreaders involved in renewing tyres by replacing worn-out tread with new tread.

Responsibility of Producers

Producers must procure EPR certificates for waste tyres exclusively from registered recyclers to fulfill their EPR obligations.
Producers are responsible for submitting quarterly and annual returns, as specified by the CPCB on the portal, by the end of the following month after each quarter. Every registered entity is required to file quarterly returns.

Responsibilities of recyclers

Each recycler must regularly submit monthly data to the portal, detailing quantities of used and generated waste tyres, sales of EPR certificates, and other relevant information.
Recyclers must submit their quarterly and annual returns on the designated Form on the website by the end of the month following each quarter or earlier.

Responsibilities of retreaders

Retreading of discarded tyres is now authorized, but retreaders must register on the CPCB portal to issue retreading certifications. The EPR obligation for retreaders has been postponed by one year (until 2023) upon submission of these certifications, contingent upon proper end-of-life disposal through a licensed recycler thereafter.

Essential aspects covered by EPR approval for waste tyres

Cancellation

Producers must achieve their EPR goals on schedule to avoid penalties or revocation of their waste tyre EPR authorization. However, registration can be revoked if inaccurate supporting documentation is found.
Failure to fulfill Extended Producer Responsibility (EPR) obligations may result in the CPCB imposing environmental fines on businesses and potentially suspending or terminating their waste tyre EPR.
Applicants will have an opportunity to present their case within 15 days of receiving notification before the CPCB considers cancelling or suspending their EPR registration.

Validity

Once issued, the tyre EPR certificate remains valid for a period of five years.

Renewal

The registration process may take between 50 to 60 business days to complete. Renewal requests can be submitted up to 60 days before the deadline.

Steps to obtain EPR registration for waste tyres

To obtain EPR certification for tyre waste, applicants must provide all required information. Our expert team will carefully review all documents for accuracy and completeness.
Once our specialists have reviewed the documentation, we will initiate the online application for EPR authorization for tyre waste with the relevant authorities.
The CPCB will evaluate the online application for waste tyre EPR registration. Any identified issues or discrepancies will be addressed promptly to ensure compliance.
The EPR certificate will be issued within 50-60 days of application submission. Upon receiving the certificate, producers must implement an EPR action plan to meet their objectives.

FEE STRUCTURE

User Type	Activity	Govt. Processing Fees	Service Charge
Producer	New Producer (1st time registration - Valid for two years)	Rs. 25,000/- + Rs. 0.625/MT for quantity of Tyre Manufactured/imported in the preceding two years (If applicable)	Rs. 50,000/- + 18% GST
	Renewal of registration fee (Every 3rd year)	Rs. 12,500/- + Rs. 0.375/MT for quantity of tyre manufactured/imported in the preceding two years	Rs. 15,000/- + 18% GST
	In case of any addendum	Rs. 7,500/-	Rs. 15,000/- + 18% GST

Documents Required for EPR For Tyre Waste

The following documents may be required as part of the process for registering EPR for waste tyre management:

Aadhar number of the authorised person
Pan card of the company
IEC number of the company (in case of import)
Covering letter, as per Annexure A
Undertaking, as per Annexure B
Tyre Composition, as per Annexure C
Submission of Plantwise manufacturing Data, as per Annexure D
GST number of the company
NOCs, or environmental approvals, from the appropriate authorities.
Proof of ownership or lease for the premises where waste tyre management operations will be conducted.
CIN number of the company
Details regarding the planned EPR strategy, including procedures for collecting, storing, transporting, processing, and disposing of waste tyres.

Consequences for failing to comply with EPR regulations

Environmental Compensation

Providing inaccurate information leading to the issuance of excessive EPR certificates—exceeding 5% of actual recycled waste—will result in registration cancellation and the imposition of nonrefundable environmental penalties.

The Central Pollution Control Board will define procedures for enforcing and collecting environmental penalties from producers, recyclers, or importers who fail to meet their obligations under this Schedule or misuse a falsified extended producer responsibility certificate. These guidelines must align with the provisions outlined in this Schedule and receive approval from both the Steering Committee and the Central Government before implementation. Unregistered manufacturers are also liable under these regulations.

Year in which shortfall is covered	Amount of refund applicable
Within the first year of the penalty imposed	85% of the environmental compensation
Within the second year of the penalty imposed	60% of the environmental compensation
Within the third year of the penalty imposed	30% of the environmental compensation
After the third year	No refund

WHY USE ABSOLUTE VERITAS (AV) FOR EPR CERTIFICATION?

Absolute Veritas is a prominent organisation from the private sector of India primarily dealing with the Inspection, Testing, Audits, Certification of products& consulting services to various industries in India and worldwide, ensuring compliance with regulatory standards and industry requirements. Offering a comprehensive range of services including product certification, testing, training, auditing, and compliance services, Absolute Veritas helps manufacturers and importers achieve higher production efficiency and quality standards.

Absolute Veritas (AV) will handle end to end pre-registration request, sample preparation, documentation, testing and application process for EPR Certification

For any questions regarding the most recent update on EPR registration licenses, please reach out to us via email at cs@absoluteveritas.com