Overview of EPR Compliance for Tyre Waste in Assam

Tyres are widely used and cannot be deemed as mere accessories as they are an integrated part of modern transportation providing safety, efficiency and performance of vehicles globally. However, after the tyres have been of immense use, theryes become an environmental nuisance. Tyre waste remains a raw material that if not disposed of in the right manner, will pose significant threats to the environment and the inhabitants. Harmful effects of waste tyres can be minimized Through the Environmental policy strategy called Extended Producer Responsibility (EPR) on accountable for take back, reuse, recycling and disposal of product throughout their life cycle. In essence, the EPR model guarantees that the manufacturers of tyre waste are liable for the environmental consequences of the product post consumption.
The measures to minimise the adverse impacts of tyre waste have been taken at the governmental level in July 2022, in the form of an amendment to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, the addition of the IX schedule to define the provisions concerning the management of tyre waste and the implementation of the Extended Producer Responsibility (EPR). Now the producers, recyclers and retreader have to satisfy the yearly compliance with the objectives under these rules from the EPR Registration for Tyre Waste.

Advantages of EPR Compliance for Tyre Waste in Assam

• Environmental Protection: EPR compliance for tyre waste 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 in Assam

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.

• 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.
• 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.
• Retreader- Who involves in process of renewal of tread and side wall rubber of a worn out tyre having a good structural quality;

Registration in Assam

• 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 in Assam

• 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 in Assam

• 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 in Assam

• 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.

Required Documents for Registration for EPR for Waste Tyres in Assam

• 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
• 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.

Procedure to obtain EPR Registration for tyres waste in Assam

The EPR registration can be done on the Central Pollution Control Board (CPCB)’s centralized portal with the help of the following steps:The EPR registration can be done on the Central Pollution Control Board (CPCB)’s centralized portal with the help of the following steps:

• Head over to CPCB’s portal and log in to the portal using the credentials. If you are a first-time user of the services from the portal, then initially, setting up an account is necessary.
• However, an applicant must ensure to complete all the particulars of activity details and proposed EPR plan in the EPR online registration form / application after log-in.
• In addition to these details, you should also submit all the relevant papers including the papers proving the ownership of the property.
• Filling out the online form along with the attested documents and other relevant documents is mandatory within one month.
• It should be noted that within a span of fifteen days for the submission of the mentioned application, the same would be considered by the Central Pollution Control Board.
• After getting approval from CPCB, the certificate has a lifespan of 2 years following which technicians working under it need to renew it.
• The challenge of China’s EPR regime means that all the regulations have to be complied with, and reports on the management of waste tyres have to be submitted to CPCB periodically.

Penalties for Non-Compliance of EPR Rules in Assam

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.

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.

How can Whizseed help you in Assam?

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.