India’s approach to waste management is increasingly focused on producer responsibility, recycling and a circular economy. For businesses dealing with tyres, this makes Extended Producer Responsibility (EPR) an important area of environmental compliance.
Under the waste-tyre framework, producers, waste-tyre recyclers and retreaders are required to register on the relevant CPCB portal, and entities covered under more than one category are required to register under those categories separately.
What Is Waste Tyre EPR?
Extended Producer Responsibility (EPR) places responsibility on producers for ensuring the environmentally sound management of waste tyres.
The waste-tyre framework covers businesses involved in activities such as manufacturing or selling new tyres, importing new or waste tyres, importing vehicles fitted with new tyres, and recycling waste tyres.
The objective is to create a structured system in which tyres reaching the end of their useful life can enter appropriate recycling and recovery channels instead of being improperly discarded.
Who Comes Under Waste Tyre EPR?
The applicable framework identifies three key categories:
1. Producers
This can include entities that:
- Manufacture and sell new tyres in India
- Sell new tyres under their own brand
- Sell imported new tyres
- Import vehicles fitted with new tyres
- Import new tyres for use in vehicles sold domestically
- Import waste tyres
2. Waste Tyre Recyclers
These are entities involved in recycling waste tyres into permitted end products through appropriate processes and facilities.
3. Retreaders
Retreaders are also covered by the waste-tyre EPR framework and have their own registration and compliance responsibilities.
EPR Obligations for Tyre Producers
One of the most important aspects of waste-tyre EPR is the recycling obligation.
For new tyres, the framework originally established a phased obligation and provides that, after 2024–25, the EPR obligation is generally 100% of the quantity of new tyres manufactured or imported in the year two years prior, subject to the applicable rules and category.
For businesses established after 1 April 2022, the framework provides for their EPR obligation to begin after two years, with the obligation based on the relevant two-year-prior quantity.
Important: Businesses should verify the latest CPCB requirements applicable to their specific category before calculating or filing an EPR obligation.
What About Imported Waste Tyres?
Waste-tyre importers also have specific EPR responsibilities.
CPCB's FAQ states that the EPR obligation for a waste-tyre importer in year Y is based on 100% of the tyre quantity imported in year Y-1. The same FAQ also states that import of waste tyres for producing pyrolysis oil or char is prohibited.
Therefore, importers should carefully assess their business activity before proceeding with waste-tyre imports.
EPR Certificates and Waste Tyre Recycling
EPR is not only about obtaining a registration certificate.
The system connects producers with registered recycling and retreading activities through the CPCB's EPR framework.
CPCB's EPR trading guidance identifies Producers, Recyclers and Retreaders as the relevant waste-tyre entities on the EPR trading platform. It also provides that waste-tyre EPR certificates can be transferred/traded from registered recyclers or retreaders to tyre producers through the prescribed platform.
This makes accurate records and transactions particularly important for businesses managing their EPR obligations.
Why Proper Documentation Matters
EPR compliance involves more than submitting an application.
Businesses should maintain appropriate records relating to their:
- Production quantities
- Import quantities
- Waste-tyre quantities
- Recycling activity
- EPR certificates
- Supporting invoices and records
- Applicable portal submissions
- Compliance reports
Accurate documentation helps create a clear trail of the company's EPR activities and can be important during regulatory review.
Common Mistakes in Waste Tyre EPR Compliance
Businesses can face avoidable problems when they:
❌ Choose the wrong registration category
A company should correctly identify whether it is acting as a producer, recycler, retreader or in multiple categories.
❌ Treat registration as a one-time formality
Obtaining registration does not eliminate ongoing EPR responsibilities.
❌ Maintain incomplete records
Production, import, recycling and certificate-related information should be properly documented.
❌ Work with unregistered entities
The applicable waste-tyre framework states that registered entities should not deal with unregistered producers or recyclers.
❌ Ignore changes in regulations
Environmental regulations and CPCB procedures can change. Businesses should monitor the latest official requirements rather than relying only on older guidance.
How BR & Associates Can Help
Managing environmental compliance can be complicated, particularly when a business is unfamiliar with EPR requirements.
BR & Associates provides professional assistance for businesses seeking support with waste-tyre EPR compliance.
Our support can include:
✔ EPR Registration Assistance
Guidance for the applicable registration category.
✔ Documentation Support
Help in organising information required for the application.
✔ Compliance Guidance
Understanding your responsibilities under the applicable waste-tyre framework.
✔ EPR Compliance Support
Assistance in understanding ongoing obligations and documentation requirements.
✔ Professional Regulatory Assistance
A structured approach to help businesses manage their environmental compliance requirements.
Turn Waste Tyres Into a Responsible Business Opportunity
Waste-tyre management is an important part of India's transition toward a more circular economy.
For tyre producers, importers, recyclers and retreaders, EPR provides a structured framework for connecting business activity with responsible waste management.
The right approach is to:
Understand your category → Register correctly → Maintain records → Fulfil EPR obligations → Work with appropriate registered entities → Maintain ongoing compliance.
By taking compliance seriously, businesses can reduce regulatory risk while contributing to responsible tyre recycling and environmental protection.
Be Compliant. Be Responsible. Build a Sustainable Future.
📞 Need Help With Waste Tyre EPR Registration?
BR & Associates
📱 +91-9310420570
📧 info@brassociates.co.in
🌐 www.brandassociates.co.in
