EPR for Tyre Waste

The term EPR (Extended Producer Responsibility) is a fundamental concept in environmental policy, holding the producer responsible for the entire life cycle of their product, particularly its take-back, recycling, and final disposal.

What is EPR for Tyre Waste?

EPR for tyre waste is defined under the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022. These rules enforce a mechanism where every Producer and Importer of tyres must ensure that a mandated percentage of the tyres they introduce into the market are collected and channeled through registered recyclers for environmentally sound processing.

To put it simply, about EPR for tyres, it’s a legal obligation that requires you to manage the post-consumer waste generated by your product. This is critical because tyres are non-biodegradable and, if mismanaged, can become breeding grounds for disease or be illegally burned, releasing toxic pollutants.

The Regulatory Authority

The compliance framework is governed and implemented by the Central Pollution Control Board (CPCB), an apex body under the MoEFCC. The CPCB manages the centralized online EPR website, which is the single platform for registration, target setting, reporting, and transaction of EPR Certificates. Understanding how to use the CPCB’s EPR website is essential for any obligated entity.

Key Objectives of EPR

The policy on EPR for tyre waste serves several vital purposes:

• Environmental Protection: Diverting millions of waste tyres from landfills and illegal dumping sites.
• Resource Efficiency: Promoting the recovery of valuable materials (e.g., rubber, carbon black) and reducing the need for virgin resources.
• Formalizing the Sector: Shifting the historically informal and often unscientific recycling processes into an organized, regulated framework.
• Principle of ‘Polluter Pays’: Ensuring the entities responsible for introducing the product bear the cost of its end-of-life management.

The EPR rules explicitly define the entities classified as ‘Producers’ who must mandatorily obtain authorization and meet their EPR for tyre waste obligations.

Entities Requiring CPCB Registration (Producers)

A ‘Producer’ is legally defined as any person or entity who:

1. Manufactures and sells new tyres domestically.
2. Sells new tyres domestically under their own brand, which are manufactured by other suppliers.
3. Sells imported new tyres.
4. Imports vehicles fitted with new tyres (Automobile Manufacturers).
5. Imports waste tyres (scrap tyres).

Any entity falling under one or more of these categories must be registered on the EPR website of the CPCB before commencing operations.

Other Registered Stakeholders

The efficiency of the EPR for tyre waste mechanism relies on a network of certified entities who also must register on the CPCB EPR website:

• Recyclers: Entities engaged in converting waste tyres into specified end products (reclaimed rubber, crumb rubber, recovered carbon black, etc.). They are the only entities authorized to generate and sell EPR Certificates to Producers.
• Retreaders: Entities engaged in the process of renewing the tread and sidewall rubber of a worn-out tyre. They generate Retreading Certificates, which can defer a Producer’s EPR obligation for one year.

The core of your responsibility under the EPR for tyre waste regime is meeting specific recycling targets. This information on about EPR compliance is crucial for annual planning.

Extended Producer Responsibility (EPR) Targets for New Tyres

The CPCB has laid out a clear, escalating target schedule to ensure compliance reaches 100% rapidly. These targets are based on the quantity of tyres manufactured or imported two years prior (Y-2).

Financial Year (Y)	EPR Obligation Target	Based on Quantity (Q) of New Tyres
2022-2023	35%	Manufactured/Imported in 2020-2021
2023-2024	70%	Manufactured/Imported in 2021-2022
2024-2025	100%	Manufactured/Imported in 2022-2023
2025-2026 (and subsequent years)	100%	Manufactured/Imported in 2023-2024 (Y-2)

Special Provisions:

• New Units: Manufacturers/Importers established after April 1, 2022, have a two-year exemption before their obligation starts, achieving 100% in the third year (Y).
• Waste Tyre Importers: Their obligation is a flat 100% of the quantity imported in the preceding year (Y-1).

The EPR Certificate Mechanism

A Producer fulfills their EPR obligation not by directly recycling the tyres, but by purchasing EPR Certificates from registered Recyclers.

• EPR Certificate Generation: Registered Recyclers process waste tyres and then generate certificates on the CPCB EPR website. The amount of credit generated depends on the end product produced (e.g., reclaimed rubber, crumb rubber), which is standardized using CPCB-defined conversion factors and weightage factors.
• Fulfillment: Producers purchase the required quantity of EPR Certificates (in tonnes) from Recyclers through the centralized platform. These certificates are then adjusted against the Producer’s annual target.
• Validity: EPR Certificates are typically valid for two years from the end of the financial year in which they were generated.

Instacertify plays a crucial role here, advising you on the optimal time and price point for purchasing these certificates, ensuring you have sufficient credits to meet your liability under the EPR for tyre waste rules.

Securing CPCB registration for EPR for tyre waste compliance requires the accurate preparation and submission of both statutory business proofs and technical documents, all uploaded to the CPCB EPR website.

I. Statutory and Business Documents

1. PAN Card of the Company/Entity.
2. GST Registration Certificate (Goods and Services Tax).
3. CIN Number (Corporate Identification Number) for registered companies.
4. IEC Number (Import-Export Code) for Importers of new or waste tyres.
5. Aadhaar Card of the Authorized Signatory (Director/Partner/Proprietor).
6. Board Resolution/Authorization Letter designating the Authorized Signatory.

II. Technical and Compliance Documents

1. Covering Letter (Formal request to CPCB, as per the prescribed format).
2. Undertaking (Self-declaration on submission of authentic data, as per CPCB format).
3. Tyre Composition Details (Annexure detailing the composition of the tyres introduced).
4. Plant-wise Manufacturing/Import Data: Quantity (in metric tonnes) of tyres manufactured or imported over the last three financial years (or since establishment).
5. EPR Plan: A detailed, CPCB-compliant action plan for meeting the EPR obligation, including proposed channelization strategy.
6. MoU/Agreement with CPCB-registered Recyclers to fulfill the recycling targets.

Obtaining CPCB authorization is a meticulous process that requires precision in documentation and application filing on the EPR website. Instacertify breaks down the journey into manageable steps.

Step 1: Pre-Audit and Documentation Preparation

Before applying on the CPCB EPR website, comprehensive preparation is required. Instacertify manages the collection and drafting of all necessary documents:

• Mandatory Business Documents: Company Incorporation Certificate (CIN), PAN Card, GST Registration, and Udyam/DIC Registration.
• Authorization Documents: CTO/CCA (Consent to Operate/Establish) from the relevant State Pollution Control Board (SPCB) or Pollution Control Committee (PCC), if applicable.
• EPR Plan: A detailed, CPCB-compliant action plan outlining your strategy for collecting, channelizing, and managing EPR for tyre waste.
• Technical Documentation: Details of the quantity of new tyres manufactured/imported over the last three financial years (for calculating targets).
• Tie-Ups (Crucial): Formal agreements/Memorandum of Understanding (MoU) with registered Recyclers and Waste Tyre Processors to manage your obligation. Instacertify assists in identifying and establishing compliant partnerships.

Step 2: Online Registration on the CPCB EPR Website

The entire application process for EPR for tyre waste authorization is carried out on the Centralized CPCB EPR website.

• We handle the creation of your account, ensuring correct classification (Producer/Importer) and accurate data entry.
• All prepared documents are digitally signed and uploaded to the portal.
• The applicable Government fees are calculated and paid through the online portal.

Step 3: Application Scrutiny and CPCB Approval

• The CPCB scrutinizes the application and the submitted EPR Plan.
• Any queries or deficiencies raised by the CPCB are promptly addressed by our expert team.
• Once satisfied with the compliance plan and documentation, the CPCB grants the EPR for tyre waste Registration/Authorization.

Step 4: Post-Authorization Compliance (Returns and Targets)

Registration is only the first part. The ongoing compliance is managed entirely through the EPR website.

• Quarterly Returns: Producers must file quarterly returns detailing their progress towards the EPR target and the certificates purchased.
• Annual Returns: An annual report summarizing all activities, including the total quantity of tyres introduced and the actual EPR obligation fulfilled.
• Certificate Purchase: Continuous advisory on market rates and purchase of EPR Certificates throughout the year to ensure the target is met by the deadline.

Instacertify handles the quarterly and annual filing on your behalf, ensuring zero compliance gaps and timely fulfillment of your EPR for tyre waste target.

One of the most common questions about EPR is regarding the financial and time investment. Costs associated with EPR for tyre waste are generally broken into three parts: Government Fees, Consultancy Fees, and EPR Certificate Costs.

EPR Tyre Waste Timeline (Approximate)

The timeline for certification is largely dependent on the accuracy of the submitted documents and the CPCB’s current backlog.

Phase	Estimated Time (Instacertify Support)	Notes
Documentation & Tie-Up Preparation	7 – 10 Working Days	Depends on client’s readiness of basic documents.
Online Application Filing	1 Working Day	Completed on the CPCB EPR website.
CPCB Processing & Approval	50 – 60 Days	Statutory timeline for the CPCB to review and approve the application.
Total Authorization Timeline	~60 – 70 Days	We push for the quickest possible clearance through meticulous compliance.

EPR Tyre Waste Cost Breakdown

Cost Component	Details & Estimate (For Reference)
CPCB Government Fees (Producer/Importer)	Application Fee: (Varies by quantity of tyre handled). For a Producer handling >10,000 TPA, the fee is approximately ₹50,000 for new registration + variable processing fees based on TPA (Tonnes Per Annum).
Instacertify Consultancy Fees	This is a fixed, comprehensive fee covering document preparation, application filing on the EPR website, technical advice on EPR plan development, and deficiency follow-up. (Contact us for a tailored quote).
EPR Certificate Purchase Cost	Variable. This is the largest and most dynamic cost. It depends entirely on your annual EPR target (in tonnes) and the prevailing market price of the EPR Certificates (set by recyclers). Instacertify advises on minimizing this cost through strategic purchase timing.

Note: The variable CPCB fees and the market price of EPR Certificates are subject to change based on regulatory updates and market dynamics. We provide the latest fee structure upon consultation.

Ignoring or failing to fulfill your targets under the EPR for tyre waste rules carries a significant financial risk. The CPCB is authorized to levy Environmental Compensation (EC) on non-complying Producers.

How EC is Calculated

The EC is calculated based on the quantity of unfulfilled EPR obligation (in tonnes). The guidelines for EC calculation are laid down by the CPCB. Key features of the penalty framework include:

1. Levy: EC is initially imposed based on the shortfall in your EPR target.
2. Escalation: The compensation amount increases the longer the obligation remains unfulfilled.
3. Refund: A portion of the EC may be refunded if the shortfall is addressed within a stipulated timeframe (e.g., 85% refund if addressed in the first year, 60% in the second year), but no refund is provided if the obligation remains unfulfilled after three years.

By partnering with Instacertify, you effectively mitigate the risk of attracting EC, ensuring that your compliance efforts are proactive and verifiable on the CPCB EPR website.

The complexity of navigating the CPCB EPR website, calculating accurate targets, finding registered partners, and ensuring timely filing requires specialized expertise. This is where Instacertify excels.

Our Comprehensive EPR for Tyre Waste Services

Service Feature	Instacertify’s Solution	Your Benefit
Documentation Management	Preparation of the compliant EPR Plan and collection of all technical documents.	Time Saving: No time wasted on drafting complex technical reports.
CPCB Portal Management	Complete handling of the online application, submission, and follow-up on the CPCB EPR website.	Guaranteed Accuracy: Zero application errors leading to faster approval.
Obligation Calculation	Precise calculation of your annual EPR for tyre waste target (in tonnes) for current and future years.	Clarity & Planning: Know exactly how many certificates you need to purchase.
Recycler Vetting & Tie-Ups	Assistance in finding, vetting, and securing legally compliant MoUs with registered recyclers.	Risk Reduction: Ensure your partners are CPCB-authorized, protecting your compliance.
EPR Certificate Advisory	Strategic consultation on the best market price and timing for purchasing certificates.	Cost Optimization: Minimize the largest variable compliance cost.
Return Filing	Timely filing of all mandatory quarterly and annual returns on the EPR website.	Seamless Compliance: Complete peace of mind against EC penalties.

Your Partner in Sustainability

The EPR for tyre waste framework is more than just a regulatory hurdle; it’s an opportunity to solidify your company’s commitment to environmental sustainability. By working with Instacertify, you gain not just a certification but a strategic partner dedicated to ensuring your entire EPR journey is efficient, transparent, and fully compliant.

Whether you are seeking your initial registration or need expert guidance on fulfilling your 100% target in the coming years, Instacertify is your trusted resource.

Ready to Secure Your CPCB EPR Tyre Waste Authorization?

Don’t let regulatory complexity slow your business down. Partner with Instacertify today to ensure 100% compliance with the mandatory EPR for tyre waste rules and access the CPCB EPR website seamlessly.

Contact us now for a personalized consultation and a fixed-price quote.