Waste Tyre Management through EPR Registration in India

India, grappling with the annual disposal of approximately 275,000 tyres and the import of 3 million used tyre scraps, is at a pivotal juncture in addressing the environmental and health hazards posed by inadequate waste tyre management. In response to this growing concern, the National Green Tribunal (NGT) has mandated the Central Pollution Control Board (CPCB) to formulate a robust plan. This directive has given rise to the implementation of the Extended Producer Responsibility (EPR) registration for waste tyre management.

A Closer Look at EPR for Waste Tyres

EPR for Waste Tyres is a vital initiative that places a substantial responsibility on tyre producers. The primary objective is to ensure the environmentally responsible disposal of old tyres, thereby mitigating potential harm to both human health and the ecosystem. The implementation of the Hazardous and Other Wastes Amendment Rules, 2022, effective from July 21, 2022, introduces Schedule IX. This schedule meticulously outlines the proper waste tyre management protocols to be adhered to by manufacturers, recyclers, and retreaders.

Entities in the EPR Landscape

Understanding the reach of EPR involves recognizing the entities subject to Schedule IX provisions:

1. Producers: Encompassing manufacturers, brand owners, importers of new tyres, and those importing automobiles with new tyres.

2. Recyclers: Encompassing individuals or organizations engaged in the intricate processes of tyre recycling.

3. Retreaders: Including entities that specialize in replacing tread and sidewall rubber in worn-out tyres.

Promise and Potential of EPR Certification

The multifaceted benefits of EPR for tyre waste management are poised to bring about transformative change:

• Sustainability: By encouraging accountability across a tyre's lifecycle, EPR significantly reduces the prevalence of illegal disposal.

• Resource Protection: EPR promotes tyre waste recycling, effectively reducing the demand for raw materials and contributing to the establishment of a circular economy.

• Energy Savings: The initiative supports the creation of tyre recycling plants, fostering energy efficiency and mitigating greenhouse gas emissions associated with the manufacture of new tyres.

• Economic Growth: The tyre recycling industry, propelled by EPR, serves as a catalyst for job creation in various facets of the recycling process, from collection to processing and product manufacturing.

• Compliance Enforcement: EPR ensures that tyre manufacturers meet their waste management obligations, monitors proper tyre waste handling, curtails illegal dumping, and promotes a cleaner, more sustainable waste management system.

Navigating EPR Obligations

The amended rules articulate specific obligations for various entities in the production and management of tyres:

Producers/Importers

• The recycling target incrementally rises each fiscal year, reaching 100% by FY 2024-2025.

• EPR obligations extend to new tyres produced or imported post-April 1, 2022.

Waste Tyre Importers

• The EPR obligation is pegged at 100% of tyres imported in the preceding year.

Retreaders

• EPR duty is deferred by a year upon providing certifications for retreading.

Shouldering Responsibilities: Producers, Recyclers, and Retreaders

Entities involved in EPR are entrusted with specific responsibilities:

• Producers: In addition to purchasing EPR certificates from registered recyclers, producers must diligently file quarterly returns.

• Recyclers: Monthly submission of data on waste tyres, EPR certificates, and quarterly returns is a crucial obligation.

• Retreaders: Registration, provision of retreading certifications, and full compliance with EPR duties are essential to fulfilling obligations.

Essential Elements under EPR Authorization

• Cancellation: Producers must meet EPR objectives, and non-compliance may lead to fines or cancellation.

• Validity: EPR certificates are valid for a period of five years.

• Renewal: Renewal requests can be submitted up to 60 days before the expiration date.

Navigating the EPR Registration Journey

The process involves meticulous steps, from the submission of necessary information to the assessment by the CPCB and eventual certificate issuance. Producers are urged to implement a proactive EPR action plan upon receiving certification.

Understanding the Fee Structure

Government fees are contingent upon waste collection targets, with additional service charges based on the type of producer and their specific activities.

Crucial Documentation for EPR Registration

Several essential documents are required for a seamless EPR registration process:

• Aadhar number, PAN card, IEC number, covering letter, undertaking, tyre composition details, plant-wise manufacturing data, GST number, NOCs, evidence of location ownership or lease, CIN number, and a comprehensive proposal outlining the proposed EPR strategy.

Ramifications of Non-Compliance

The repercussions for non-compliance under EPR rules are twofold:

• Environmental Compensation: Imposed for misleading information, with a refund system based on the year of compliance.

• Prosecution: The misuse of information or certificates may lead to legal prosecution under the EPR Certificates Act.

Conclusion: A Sustainable Future Beckons

In conclusion, the implementation of EPR registration for waste tyre management stands as a significant stride towards addressing the pressing environmental challenges posed by tyre waste. By instilling responsibility across the production and recycling continuum, India aspires to create a sustainable, circular approach to managing this critical environmental concern.