EPR Compliance for Tyre Waste Management

Introduction

Extended Producer Responsibility (EPR) for waste tyres entails the obligation of tyre producers to ensure environmentally sound management of waste tyres. MOEFCC  issued a notification on 31 December 2021, amending the hazardous waste rules to include provisions for the utilization and management of waste tyres. The stakeholders involved in this framework include

• Producers of tyres
• Recyclers of waste tyres
• Retreaders of waste tyres

Are required to register themselves on the EPR portal developed by CPCB. whomsoever stakeholder involved in 

• production 
• manufacturing 
• Sales of new tyre 
• Import of new or waste tyre 
• Import of vehicle fitted with new tyre 
• Import of new tyres by automobile manufacturers for use in vehicles sold domestically 
• Recycling of waste tyres.

Stakeholders that come under the above-mentioned criteria are mandated to ensure environmentally sound management of waste tyres.

The EPR certificates are tangible evidence of the sustainable management of waste tyres. Producers can purchase retreading certificates to defer their EPR obligations, but they must still obtain recycling certificates to fulfill their obligations. This encourages the prioritisation of tyre recycling.

Process for EPR Compliance of waste tyre

The Central Pollution Control Board (CPCB) has developed a centralized EPR portal to simplify and streamline the process. This portal serves as a platform for stakeholders in waste tyre management, The portal enables them for 

• Registration of stakeholders 
• Generation of EPR credit 
• Trading/issuance of  EPR certificates. 
• Filing of EPR obligation 

Stakeholders file their EPR obligations using the portal, making the regulatory compliance process more accountable.

Non-compliance with EPR Compliance of waste tyre

In case, any registered stakeholder furnishes false information or willfully conceals information to get registration or return or report or information required to be provided or furnished under this schedule or in case of any irregularity,  CPCB may revoke the registration of such stakeholder for a period up to three years after giving an opportunity of being heard and environmental compensation charges may also be levied in such cases. 

Responsibility of stakeholders for EPR Compliance of waste tyre  

Responsibility of producer

 Producers means specified categories of stakeholders that include 

• manufacturers who sell new tyres domestically,
• sellers who sell domestically under their brand-new tyres
• sellers of imported new tyres
• importers of vehicles fitted with new tyres,
• automobile manufacturers who import new tyres for use in new vehicles sold domestically
• importers of waste tyres.                                   

Producers of waste tyres have an EPR obligation. To fulfill this obligation, producers must purchase EPR credit from registered recyclers, and the quantity of credits purchased will be adjusted against their EPR obligation. Producers can also acquire a retreading certificate to defer their EPR obligation, but recycling certificates must still be acquired for the obligation to be fulfilled.

Producers are issued a one-time registration on the EPR portal, and they submit quarterly and annual reports. The annual EPR obligation is assigned at the time of registration, and subsequent obligations are auto-generated based on sales quantity for the current financial year. Annual EPR obligations are assigned to producers based on domestic sales or the number of imported tyres. 

The producer shall be responsible for filing annual and quarterly returns in the form as specified by cpcb on the portal on or before the end of the month succeeding the quarter to which the return relates and each registered stakeholder shall have to file the quarterly return.

Documents  Required EPR compliance of waste tyre

Producer

The following documents are required to get registered as a producer of waste tyres –

1.  GST 
2.  Mobile Number 
3.  Company’s Email ID 
4.  PAN Number 
5.  IEC Number 
6. Corporate Office Address 
7. Country, State, City, Pin-Code 
8. CIN Number 

• Authorized Person Details

1.  Name 
2. Designation 
3. Mobile Number 
4. PAN, Aadhar Card Authorized Person Email ID 

• Select the Category under which the Producer Falls 

Producer(P1) – Quantity of new tyres manufactured domestically.

Producer(P2) – Quantity of new tyres procured domestically. 

Producer(P3) – Quantity of new tyres Imported. 

Producer(P3) – Quantity of tyres Imported along with imported vehicles. 

Producer(P3) – Quantity of new tyres imported exclusively for new vehicles manufactured domestically. 

Producer(P3) – Quantity of imported waste tyres.

Responsibility of recycler 

Recycling means any process or action of converting waste tyres into following end products in an environmentally sound manner and having facilities as addressed by CPCB –

• Reclaimed rubber 
• Crumb rubber 
• Crumb rubber bitumen (CRMB)
• Recovered carbon black (which is usable as raw material for the manufacture of new tyres)
• Pyrolysis oil (which is suitable for use only as a fuel )
• Pyrolysis char ( which is suitable for use as raw material for the manufacture of new tyres)

Recyclers and retreaders are responsible for generating and issuing EPR credit based on the quantity of waste tyres they recycle or retread.

All the recyclers shall submit monthly information regarding the quantity of waste tyres used end products produced, and EPR certificates sold.

All the recyclers shall file annual and quarterly returns in the form as specified on the portal on or before the end of the month succeeding the quarter to which the return relates.

Required document 

Recycler 

• Consent to establish ( CTE)
• Consent to operate (CTO)
• Authorization issued under hazardous and other waste rules, 2016 Issued by concerned spcb / PCC 
• Geotagged pictures of all machineries 
• Pollution control devices 
• Process flow chart 
• The annual return of the previous year 
• Layout of unit 
• The total area of a unit 
• Shed area along with geotagged video of the unit

Recyclers are inspected by official bodies such as SPCB/PCC and CPCB to verify their plant machinery within three months of registration. This inspection process ensures that facilities can generate a recycling certificate, making the regulatory compliance process more accountable.

Responsibility of waste tyre importers 

The EPR obligation for waste tyre importers in a year shall be 100 % of the tyres imported in a year.

Important 

The import of waste tyres to produce pyrolysis oil or char is prohibited.

EPR credit for compliance of waste tyre 

For the fulfilment of the EPR obligation, producers are required to acquire EPR credits from registered recyclers While producers may opt to purchase retreading certificates for the extension of EPR obligations, it is essential to note the fulfilment of obligations upon obtaining recycling certificates. This strategic mechanism encourages the prioritisation of tyre waste recycling. To streamline and facilitate these processes, a centralized EPR portal has been developed by the Central Pollution Control Board (CPCB). This portal serves as a legible platform for the implementation of various processes

  Registration of Stakeholders

• The portal facilitates the seamless registration of stakeholders involved in the life cycle of tyre management. This includes producers, recyclers, and retreaders.

• Generation of EPR Credit 
  • Stakeholders, particularly recyclers and retreaders, can utilize the portal to generate EPR credit, providing a transparent record of their tyre recycling and retreading activities.
• Trading/Issuance of Certificates
  • The portal serves as a marketplace for the trading and issuance of EPR certificates, enabling producers to fulfil their obligations by acquiring certificates from registered recyclers.
• Filing of EPR Obligations
  • Stakeholders can use the portal to file their EPR obligations, creating a streamlined and accountable process for regulatory compliance.

This regulatory framework, augmented by the EPR mechanism and the CPCB’s centralized portal, aims to fortify the responsible management of Tyre while ensuring compliance.

EPR credit for producer of waste tyre Compliance 

Producers shall fulfil their EPR obligation through the online purchase of an EPR credit from a registered recycler only and submit it online on the portal by filing the quarterly return. 

EPR  target of the producer shall be reduced by a factor laid down by the cpcb on account of wear and tear of tyres.

A producer can purchase an EPR credit limited to its EPR liability of the current year plus any leftover liability of preceding years plus 10 % of the current year’s liability.

The EPR obligation shall have to be fulfilled by the producer by proportionately purchasing the EPR certificate quarterly.

Exemption 

As soon as the producer purchases the EPR credit, it shall be automatically adjusted against its liability, priority in adjustment shall be given to earlier liability and the EPR credit so adjusted shall be automatically extinguished and cancelled.

Validity of EPR credit 

The validity of the EPR credit shall be two years from the end of the financial year in which it was generated. 

Description of credit  

Each EPR credit shall have a unique number containing the year of generation, code of end product , recycler code and a unique code.

The EPR  credit shall be in the denominations of 100, 200, 500 and 1000 metric tonnes as may be decided by CPCB.

Prosecution 

Any person who provides incorrect information for obtaining EPR credit uses or causes to be used false or forged EPR  credit in any manner over generates EPR credit above 5% of the actual waste recycled, wilfully violates the direction given under the provision of this schedule or fails to co-operate in the verification and audit proceedings, may be prosecuted and this prosection shall be in addition to the environmental compensation levied. 

Modalities of the EPR  regime for compliance of waste tyre

For manufacturers or importers of new tyres 

• Epr obligation of the year 2022 -2023 

Waste tyre recycling target in weight  35 % of the quantity of new manufactured or tyres imported in the year 2020-2021 

• Epr obligation of the year 2023 -2024  

Waste tyre recycling target in weight  70 % of the quantity of new manufactured or tyres imported in the year 2021-2022

• Epr obligation of the year 2024 -2025

Waste tyre recycling target in weight  100 % of the quantity of new manufactured or tyres imported in the year 2022 -2023 

• After the year 2024-2025, the EPR  obligation shall be 100 % of the quantity of new tyres manufactured or imported in the year [ y-2] 
• For units established after 1 April 2022, the EPR  responsibility obligation shall start after two years and shall be 100 % of the new tyre manufactured or imported in the year [ y-2 ]

Conclusion EPR compliance of waste tyre 

The waste tyre management framework promotes responsibility across producers, recyclers, and retreaders . These stakeholders need to fulfil their EPR obligation and target and update it on a centralized  EPR portal developed by cpcb that enhances transparency, making the entire process more accountable and supporting sustainable waste tyre management practices.