Extended  Producer Responsibility (EPR) for Tyre Waste Management

EPR REGISTRATION FOR WASTE TYRE MANAGEMENT

India discards roughly 275,000 tyres a year but has no plan in place for how to handle them. 3 million used tyre scraps are further imported for recycling. The NGT directed the Central Pollution Control Board (CPCB) to create a complete waste management plan for the disposal of waste tyres and their recycling in a case concerning the incorrect management of End-of-Life Tires/Waste Tyres (ELTs).

Managing tyre waste has become a crucial worldwide issue as the focus on environmental sustainability continues to increase. The buildup of used tyres and the subsequent disposal of these tyres pose major risks to ecosystems and human health. In order to address these challenges, (Extended Producer Responsibility) EPR registration for waste tyre management has emerged as a critical tactic in reducing the environmental consequences associated with tyre waste.

Overview of EPR for waste tyres

The term “EPR for Waste Tyres” refers to the obligation placed on tyre producers to ensure that old tyres are disposed of in an environmentally friendly way to avoid any potential harm to human health or the environment. The Hazardous and Other Wastes Amendment Rules, 2022 for EPR for Waste Tyre were released by the Ministry of Environment, Forests, and Climate Change. This amendment, which became effective on July 21, 2022, includes a new Schedule IX that outlines the proper use and management of discarded tyres by manufacturers, recyclers, and retreaders.

The registration procedure for all parties engaged in the production and administration of tyres will be described in detail in this article, as will each party’s responsibilities for post-compliance on the combined CPCB portal.

Its Applicability

The following entities are subject to the provisions of Schedule IX:

1. Producer: Means any person or entity who,-

• Manufacturers who produce and market new tyres locally
• Sells new tyres made by other suppliers or manufacturers locally under their own brands (Brand Owners)
• Sells imported new tyres (Importers)
• Imports automobiles with brand-new tyres
• New tyres are imported by automakers for use in newly released cars that are sold locally.
• Imports waste tyre

2. Recycler: Any individual or organization involved in recycling. Recycling is the ecologically responsible method of turning used tyres into the following products:

• Reclaimed rubber
• Crumb rubber
• Crumb rubber modified bitumen (CRMB)
• Recovered carbon black, which is usable as raw material for manufacture of new tyre
  Pyrolysis oil or Char, is used only as a fuel and not as raw material for manufacture of new tyre

The recycling target is the quantity of used tyres that must be recycled in accordance with Schedule IX’s rules.

3. Retreader: Any individual or organization engaged in the replacement of the tread and sidewall rubber in a worn-out tyre with excellent structural integrity.

Benefits of EPR Certification for waste tyre 

Following are the benefits of EPR for tyre waste–

1. Sustainability: Tyre trash management is environmentally friendly with EPR registration. Manufacturers are encouraged to be accountable throughout a product’s lifecycle, including recycling and disposal. The EPR process can dramatically reduce the amount of tyre trash thrown illegally or in landfills.
2. Protecting resources: Tyres contain valuable materials that can be collected and reused. EPR registration for tyre waste management promotes tyre waste recycling and recovery. This reduces the amount of raw material needed to make new tyres. Recycling and reusing tyres promote a circular economy.
3. Energy Savings: Recycled tyres use less energy than those made entirely from scratch. The creation of tyre recycling plants, where tyres can be shredded, granulated, and processed into different products like rubberized asphalt, sports surfaces, or building materials, is encouraged by the EPR for tyre waste. EPR encourages tyre recycling in order to conserve energy and reduce greenhouse gas emissions related to the manufacture of new tyres.
4. Economic Growth:  Tyre recycling facilities and related industries create jobs. EPR for waste tyres encourages recycling investment, leading to a sector focused on tyre waste management, with roles in collection, sorting, processing, and manufacturing recycled products, benefiting local economies.
5. Compliance Enforcement: EPR for waste tyre management ensures tyre manufacturers meet waste management obligations. It monitors proper tyre waste handling, prevents illegal dumping, and promotes a cleaner, sustainable waste system by holding producers accountable for responsible actions.

Amended rule requirement for EPR for waste tyre management

Producers, importers, and brand owners involved in the production and sale of new tyres, as well as importers who deal with old tyres, are required to abide by the EPR standards for waste tyres. These specifications include developing a system for accumulating, transporting, recycling, or properly discarding used tyres. This strategy was created to guarantee the responsible management of imported and domestically produced used tyres. The updated requirements also apply to retreaders who put fresh tread on tyres in place of worn-out tread.

Registration of entities under EPR for waste tyre

Before beginning or continuing their commercial operations, each of the aforementioned entities must register on the CPCB’s web portal.  These organizations are not allowed to work with any producers or recyclers who haven’t finished the registration process.

Obligations imposed on entities concerning EPR for tyre waste

•  For Producers or Importers of new tyres: 

	Year	Waste Tyre Recycling Target in Weight (Kilograms or Tons)
1.	FY 2022-2023 (The year in which this Schedule comes into force)	35% of the quantity of new tyres manufactured or imported in year 2020-2021
2.	FY 2023-2024	70% of the quantity of new tyres manufactured or imported in year 2021-2022
3.	FY 2024-2025	100% of the quantity of new tyres manufactured or imported in year 2022-2023.
4.	After the year 2024-2025	100% of the quantity of new tyres manufactured or imported in the year (Y-2)

5.	Units created after April 1, 2022, will be subject to an EPR obligation that will begin after two years (Y) and apply to 100% of all new tyres produced or imported in the year (Y-2) in question.

Note: Y-2 denotes two years prior to the year under discussion.

•  For waste tyre Importer: The importer of discarded tyres will have an EPR requirement in year (Y) equal to 100% of the tyres imported in year (Y-1)
•  For Retreaders: The EPR duty is postponed for a year upon presentation of retreading certifications.

Responsibilities of producers

• The producer must only purchase certificates for EPR for waste tyre from registered recyclers in order to complete their EPR obligations.
• On or before the end of the month following the quarter to which the return relates, the producer shall be responsible for filing annual and quarterly returns in the forms as specified by the CPCB on the portal, and each registered entity shall be required to file the quarterly return.

Responsibilities of recyclers

• Each recycler is required to send monthly data on the amount of used and generated waste tyres, EPR certificates sold, and other pertinent data to the portal.
• The end of the month following the quarter to which the return pertains, or earlier, is the deadline for all recyclers to submit their annual and quarterly returns in the Form prescribed on the site.

Responsibilities of retreaders

Retreading of scrap tyres is now permitted, however in order to issue retreading certifications, retreaders must first register on the CPCB portal. The EPR duty for the retreader was delayed by one year (until 2023) upon submission of these certifications, provided that the obligation is cancelled following end-of-life disposal through a licenced recycler.

Key points under EPR Authorization for waste tyres

 Cancellation

• To avoid fines or cancellation, producers must meet their EPR objectives on Schedule. Producers/Manufacturers are given EPR authorization for waste tyres ; however, this registration can be revoked at any time if it is discovered that the applicant’s supporting documentation is inaccurate.
• In the event that Extended Producer Responsibility (EPR) responsibilities are not met. The CPCB has the authority to levy environmental compensation on businesses as well as suspend and/or terminate the EPR for tyres waste.
• Before the CPCB considers the case for cancelling or suspending the EPR registration, the applicant will have a chance to be heard within 15 days of the day the notification was issued.

 Validity

After being issued, the tyre EPR certificate is good for five years.

Renewal

It might take up to 50 to 60 business days to complete the registration procedure.  A renewal request may be submitted 60 days before the deadline.

Procedure to obtain EPR Registration for tyres waste

Step 1: In order to receive their EPR for tyre waste certification, applicants must furnish all necessary information. Our skilled staff will examine all the information and paperwork for any inconsistencies.

Step 2: Once our team of specialists has examined all the papers. For online EPR Authorization for tyre waste, a request will be made to the relevant EPR authorities.

Step 3: The CPCB will assess the online application for registration of an EPR for waste tyre management . If any issues or discrepancies are discovered, the relevant changes will be made to remedy them.

Step 4: Within 50-60 days of the application being submitted, the certificate of authorization will be issued. Producers must put an EPR action plan into effect after the certificate has been granted in order to reach the EPR objective.

For further information regarding the procedure, contact us at +91-99992-53054 or email us your queries at support1@globalsolution.co.in

Fee Structure

Govt. Fee Applicable According to Tyre – waste Collection Target

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

Required Documents

The following documents may be needed as part of the procedure for EPR registration for waste tyre management:

1. Aadhar number of the authorised person
2. Pan card of the company
3. IEC number of the company (in case of import)
4. Covering letter, as per Annexure A
5. Undertaking, as per Annexure B
6. Tyre Composition, as per Annexure C
7. Submission of Plantwise manufacturing Data, as per Annexure D
8. GST number of the company
9. NOCs, or environmental approvals, from the appropriate authorities.
10. Evidence of the ownership or lease of the location where waste tyre management operations will take place.
11. CIN number of the company
12. Information about the proposed EPR strategy, including information on how waste tyres are collected, stored, transported, processed, and disposed of.

Penalties for Non-Compliance of EPR Rules

Environmental Compensation

Any misleading information that causes a recycler to generate too many EPR certificates—more than 5% of the real recycled waste—will result in the cancellation of their registration and the imposition of nonrefundable environmental compensation.

The Central Pollution Control Board shall establish guidelines for imposing and collecting environmental compensation from producers, recyclers, or importers in the event that those parties fail to comply with their obligations under this Schedule or use a false extended producer responsibility certificate. The said guidelines shall be in accordance with the provisions of this Schedule and shall be subject to approval by the Steering Committee and the Central Government before being put into effect.  Unregistered manufacturers are likewise subject to it.

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

Note: The payment of environmental compensation will not release the producers from their commitment to comply with the terms of this Schedule, and any unmet EPR obligations for one year will be carried over to the following year, and so on, for a maximum of three years.

Prosecution

Anyone who provides false information to obtain EPR for waste tyres, uses or permits to be used false or forged EPR certificates in any way, generates excessive amounts of EPR certificates (more than 5% of the actual waste recycled), willfully violates the instructions provided under the provisions of this Schedule, or refuses to cooperate in the verification and audit proceedings, may be prosecuted under the EPR Certificates Act.

How can Global Solution help your business obtain an EPR Certificate for Waste Tyre?

Global Solution offers comprehensive assistance to organizations throughout the process of EPR registration with the CPCB-

• This encompasses managing compliance tasks such as quarterly reporting and record-keeping to ensure adherence to EPR regulations.
• Global Solution facilitates the acquisition of EPR certificates from accredited recyclers, streamlining the certification process.
• The company also offers valuable insights regarding the necessary documentation for EPR certification for tyre waste and aids in its preparation.
• Global Solution advises on matters pertaining to penalties, compensation linked to non-compliance, and extends its expertise in EPR for waste tyre management.
• Their advisory services encompass a wide spectrum, including best practices, cost-efficiency strategies, and initiatives promoting environmental sustainability in EPR processes for waste tyre management.