Overview of New Tyre Import License

For New Tyre Import License one has to first seek permission to undertake the Extended Producer Responsibility (EPR) from the CPCB. Schedule IX was added to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules (HOWM), on the 21st of July, 2022 by the Ministry of Environment, Forest and Climate Change. This amendment introduced the EPR regime solely to waste tyres. Consequently, in this regime, waste tyres management is the responsibility of the producers right from the importers of new tyres. This entails a gradual rising recycling rate which will rise from the agreed 35% of the imported or manufactured tyres in 2020-21 to 70% in the year 2023-24 and ultimately reach 100% in the financial year 2024-25.

Advantages of New Tyre Import License

• Access to High-Quality Tyres: Import licenses allow companies to bring in premium tyres that may not be manufactured domestically, ensuring that high-performance vehicles and specific applications requiring these tyres can maintain operational standards.
• Support for Automotive Industry: The license helps automobile manufacturers avoid production disruptions by ensuring a steady supply of necessary tyres, especially for models intended for export or requiring specialized tyres not available locally.
• Flexibility for Global Manufacturers: Global tyre companies can continue to serve the Indian market while meeting local regulatory requirements, allowing them to maintain market share and customer satisfaction.
• Promotion of Investment: By linking the import license to conditions such as investment in local manufacturing, the government encourages foreign companies to contribute to domestic industry growth, which benefits the economy.
• Compliance with Environmental Regulations: With the EPR obligations tied to import licenses, companies are compelled to manage tyre waste responsibly, promoting sustainability and helping India meet its environmental goals.
• Market Expansion: Import licenses enable businesses to explore and expand into niche markets within India that require specialized tyres, supporting diverse transportation needs.

Important terms defined under the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022

• Producer

 As per clause 1 (e) means any person or entity who (i) manufactures and sells new tyre domestically; or (ii) sells domestically under its own brand, new tyre manufactured by other manufacturers or suppliers; or (iii) sells imported new tyre; or (iv) imports vehicles fitted with new tyres; or (v) automobile manufacturers importing new tyre for use in new vehicles sold domestically; or (vi) imports waste tyre;

So it is clear that importer of New Tyres will be treated as producer.

• Responsibilities of the producer

(1) The producer shall be responsible for fulfillment of extended producer responsibility by purchasing extended producer responsibility certificates from registered recyclers only. (2) 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.

Key points about Extended Producer Responsibility (EPR) authorization for new tyre imports:

Importers of new tyres are considered "producers" under the EPR regime and have EPR obligations.

1) The EPR recycling targets for importers of new tyres are:

• 2022-2023: 35% of the quantity of new tyres imported in 2020-2021
• 2023-2024: 70% of the quantity imported in 2021-2022
• 2024-2025 onwards: 100% of the quantity imported two years prior

2) Importers must register on the EPR portal developed by the Central Pollution Control Board.

3) They need to fulfill their EPR obligation by purchasing EPR certificates from registered recyclers.

4) Quarterly returns must be filed on the portal regarding EPR certificate purchases and obligation fulfillment.

5) Annual returns are also required to be filed.

6) The EPR obligation can be met by proportionally purchasing EPR certificates on a quarterly basis.

7) Non-fulfillment of EPR obligations can result in environmental compensation charges.

8) Importers cannot deal with unregistered producers or recyclers.

9) The EPR system aims to ensure environmentally sound management of waste tyres through recycling targets for producers, including importers.

Documents Required for New Tyre Import License

• Company Information:
• Certificate of Incorporation for the Company
• CIN number of the company
• PAN card of the company
• GST number of the company
• Owner/Authorized Person Details:
• Details regarding the owner, proprietor, or sole proprietor
• Aadhar number of the authorized person
• Administrative Documents:
• Covering letter
• Undertaking
• Self-attestation by the Dismantlers and Recyclers
• Technical Information:
• Tyre Composition
• Submission of Plant wise manufacturing Data
• Statement of Compliance with the Reduction of Hazardous Substances (ROHS)
• Partnerships and Agreements:
• Letter of understanding (LOI) with recyclers, dismantlers, storage facilities, and disposal facilities (TSDFs), among others

Procedure for getting EPR Authorization for New Tyre Import License

• Step 1: Applicants are required to provide all pertinent information. Following this, their applications will be thoroughly examined.
• Step 2: Should the information be complete and accurate, a request will be submitted to the appropriate EPR authorities.
• Step 3: The provided information will be forwarded to the CPCB, which will evaluate all applicant details and accompanying documents. If the CPCB requires any clarifications or modifications, these must be supplied accordingly.
• Step 4: The certificate of authorization will be issued within 50 to 60 days after the application submission. Producers are obligated to implement an EPR action plan once the certificate has been granted to achieve the EPR objectives.

Extended producer responsibility certificate:

The Central Pollution Control Board will allocate extended producer responsibility (EPR) obligations to a manufacturer in accordance with the volume of tyres produced or imported by that manufacturer. In line with the assigned EPR obligations, the manufacturer is required to acquire EPR certificates from an authorized recycler. Additionally, the manufacturer has the option to obtain a retreading certificate from a certified retreader to postpone its EPR obligations.

Cancellation of EPR Authorization for New Tyre Import

The Central Pollution Control Board (CPCB) possesses the authority to revoke or suspend Extended Producer Responsibility (EPR) for waste tyres if the stipulated requirements are not fulfilled. Prior to any cancellation or suspension, the applicant must be afforded the opportunity to present their case at least 15 days before a final decision is made.

Why Whizseed can help you?

1) Registration and Documentation:

Securely store and manage all required documents, such as company information, owner details, and technical information.

2) Regulatory Updates:

• Keep users informed about changes in EPR regulations and requirements.
• Automatically adjust compliance processes based on regulatory updates.

3) Support and Guidance:

• Provide step-by-step guidance on fulfilling EPR obligations.
• Offer customer support for resolving compliance-related queries.

4) Reporting and Compliance:

• Helps in generation and filing of quarterly and annual returns on the CPCB portal.
• Maintain a comprehensive compliance calendar with reminders for important deadlines.