An Overview of the EPR Compliance for Tyre Waste

• Environmental Protection: EPR compliance minimally helps to reduce the effects of tyre waste on ecosystem and human health.
• Resource Efficiency: Retreading and recycling of tyres save the natural resources and decrease the existing demand for materials.
• Economic Opportunities: The tyre recycling industry provides employment opportunities and boosts economic expansion by opening up new uses for recycled tyres.
• Corporate Responsibility: The ever increasing implementation of EPR ensures that an organization displays corporate social responsibility, which in turn improves the image of the company and the trust of the customers.

Applicability of Provisions-

The provisions of this rules and regulations shall be applicable to the following entities, namely: A retreader is also professionally known as the (i) producer; (ii) recycler of waste tyre; and (iii) re-treader.

1. Producer refers to any person or company who – (i) produces and distributes new tyre for domestic consumption; (ii) distributes domestically new tyre bearing its own label and brand even if produced by other manufacturers or suppliers; (iii) distributes imported new tyre; (iv) imports vehicles fitted with new tyres; (v) automobile manufacturers importing new tyre for use in new cars sold domestically; (vi) imports waste tyre.
2. Any person or entity involved in ‘recycling’ by any of the following activities is referred to as: Recycler of waste tyres-(i) reclaimed rubber; (ii) crumb rubber; (iii) crumb rubber modified bitumen (CRMB); (iv) recovered carbon black, for use in manufacture of new tyre; (v) pyrolysis oil or Char, fuels only and not as raw material for new tyre.
3. Retreader- Who involves in process of renewal of tread and side wall rubber of a worn out tyre having a good structural quality;

Registration. –

• The entities referred in Applicability i.e producer, recycler of waste tyre and re-treader shall register on the portal.
• No entity shall carry out any business without registration.
• The entities registered under sub-paragraph (1) shall not deal with any unregistered producer or recycler
• In case, any registered entity furnishes false information or willfully conceals information for getting registration or return or report or information required to be provided or furnished under this Schedule or in case of any irregularity, the registration of such entity may be revoked by the Central Pollution Control Board for a period up to three years after giving an opportunity of being heard and in addition, environmental compensation charges may also be levied in such cases.
• In case any entity is covered in more than one category under paragraph 3, then the said entity shall register under those categories separately.
• The Central Pollution Control Board may charge such registration fees from the applicants as may be specified from time to time with the approval of the steering committee.

Responsibilities of the producer-

• The producer shall be responsible for fulfillment of extended producer responsibility by purchasing extended producer responsibility certificates from registered recyclers only.
• The producer shall be responsible to file annual and quarterly returns in the forms as specified by the Central Pollution Control Board on the portal on or before the end of the month succeeding the quarter to which the return relates and each registered entity shall have to file the quarterly return.

Responsibilities of the recycler-

• All the recycler shall submit on monthly basis the information regarding quantity of waste tyres used and end product produced, extended producer responsibility certificate sold and such other relevant information on the portal.
• All the recycler 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.

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.

• Covering letter with an undertaking regarding the submission of authentic data
• Tyre Composition
• PAN Card of the company
• GST Number of the company
• Submission of plantwise manufacturing data

1. Volume of new tyres produced within the country.

2. Volume of new tyres sourced domestically.

3. Volume of new tyres brought in from abroad.

4. Volume of tyres imported alongside foreign vehicles.

5. Volume of new tyres imported specifically for domestically manufactured vehicles.

6, Volume of imported waste tyres.

• IEC number of the company (Only in case of import)
• CIN number of the company
• Aadhar Card of the Authorized Person
• Address of the head office of the company in the country.
• Environmental approvals, also known as NOCs, from the relevant authorities are required.
• Detailed information regarding the proposed EPR strategy, which encompasses the collection, storage, transportation, processing, and disposal of waste tyres, is provided.

The EPR compliance can be done on the Central Pollution Control Board (CPCB)’s centralized portal which can help in the following steps:

• Stakeholder registration
• Creation of Extended Producer Responsibility (EPR) credits
• Exchange and issuance of EPR certificates
• Submission of EPR obligations

1. Stakeholder Registration

• Identify your stakeholder category: Producer, Recycler, Retreader
• Gather required documents:
• Access the CPCB EPR portal.
• Complete the registration form with accurate information.
• Submit the form along with required documents.
• Await verification and approval from CPCB.

2. Creation of EPR Credits

• For Recyclers and Retreaders:
• Log into the EPR portal.
• Submit monthly information on:
• Quantity of waste tyres processed
• End products produced
• The system will generate EPR credits based on the quantity of waste tyres recycled or retreaded.
• Credits are issued in denominations of 100, 200, 500, and 1000 metric tonnes.
• Each credit receives a unique identifier containing:

1. Year of generation

2. Code of end product

3. Recycler code

4. Unique serial number

3. Exchange and Issuance of EPR Certificates

• Producers log into the EPR portal.
• View available EPR credits from registered recyclers.
• Purchase required EPR credits to meet obligations:
• Can buy up to current year's liability + leftover from previous years + 10% of current year's liability
• System generates EPR certificates for purchased credits.
• Recyclers receive payment for sold credits.

4. Submission of EPR Obligation

• Producers log into the EPR portal.
• File quarterly returns by the end of the month following each quarter.
• Submit annual returns.
• Report the quantity of new tyres manufactured, imported, or sold.
• System calculates EPR obligation based on reported quantities:

1. 2022-2023: 35% of 2020-2021 quantity

2. 2023-2024: 70% of 2021-2022 quantity

3. 2024-2025 onwards: 100% of quantity from two years prior

4. Upload purchased EPR certificates to fulfill the calculated obligation.

• System automatically adjusts and cancels used EPR credits.
• Ensure proportionate quarterly fulfillment of EPR obligation.

Penalties for Non-Compliance of EPR Rules

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.

Whizseed could offer a comprehensive service to assist companies in navigating the EPR Compliance process for tyre waste management. Specifically, we could:

• Provide an easy-to-use online platform for companies to register for EPR Compliance, guiding them through the application process step-by-step.
• Offer document preparation services, helping companies gather and organize all required documents for registration, such as PAN cards, GST numbers, environmental approvals, and detailed EPR strategies.
• Provide up-to-date information and guidance on the latest EPR regulations and requirements, ensuring companies stay compliant.
• Assist in preparing and filing the required quarterly and annual returns on the Central Pollution Control Board (CPCB) portal.
• Offer consulting services to help companies develop effective EPR strategies for collection, storage, transportation, processing, and disposal of waste tyres.
• Provide reminders for certificate renewal, as EPR registration certificates are valid for 2 years.
• Offer compliance monitoring tools to help companies track their progress towards meeting EPR objectives and avoid penalties.
• Provide educational resources about the benefits of EPR compliance, including environmental protection, resource efficiency, and corporate responsibility.
• Facilitate connections between producers and registered recyclers for purchasing EPR certificates.
• Offer support in case of compliance issues, including assistance with responding to notices or preparing for hearings.