Overview of the Registration under EPR for Waste Tyres

India discards roughly 275,000 tyres each year; over and above this number, about 3 million waste tyres are imported for recycling. To deal with tyre waste Management, the government came up with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules,2016. It laid down the responsibilities of producers of tyres, as well as the recyclers and retreaters. After many subsequent amendments, the MoEF&CC notified the Hazardous and Other Wastes (Management and Transboundary Movement)AmendmentRules,2022,in July 2022. which made the Extended Producer Responsibility orEPR for Waste Tyresmust for producers and registration on the CPCB’s centralized EPR portal mandatory for producers, recyclers and retreaters. The 2022 amendment also had provision for the utilization and management of waste tyres through Extended Producers Responsibility regime w.r.t waste tyres as per schedule-IX of the 2022 Rules. The centralized portal for the waste tyre management system, which is an online portal, has become active. All the stakeholders, like producers, recyclers and retreaters, must register themselves to continue operations in the country. The present EPR obligation module is limited to online submission of information related to quantities of tyres introduced into the market by producers and generation of EPR obligation.

Obligations of Producer under EPR for Waste Tyres

As defined in paragraph 1(e) of the 2022 Rules, EPR applies to producers, that includes the manufacturers as well as the importers and brand Owners (PIBOs) that deal in

• Manufactures and sells new tyres domestically; or
• Sells domestically under its brand, new tyres manufactured by other manufacturers or suppliers
• Sells imported new tyre
• Imports vehicles fitted with new tyres
• Automobile manufacturers importing new tyres for use in new vehicles sold domestically.
• Imports waste tyre

As defined in paragraph 1(f), of the 2022 Rules, ‘‘recycling’’ is the conversion of the waste tyre into end products in an environmentally sound manner and possessing facilities as elaborated in the SOP as specified by the CPCB.

• reclaimed rubber
• crumb rubber
• crumb rubber modified bitumen (CRMB)
• recovered carbon black and
• pyrolysis oil or char

After the amendment of the rules in 2022, the responsibilities of producers, recyclers and retreaders w.r.t EPR for Waste Tyreswere fixed.Producers have been assigned the responsibility to recycle waste tyres equivalent to the weight of new tyres that they had manufactured or imported in the previous year. For importers of waste tyres, the EPR obligation will amount to 100 % of the waste tyres they imported in the previous year. The entities will have to submit their manufacturing data as per the following directions.

Businesses established before FY 2019-20	Businesses established in FY 2020-21	New Producers
manufactured quantity/import quantity is to be provided from FY2019-20 onwards	manufactured quantity/import quantity is to be provided from the year of their establishment onwards.	Those businesses that have not carried out any manufactured quantity/import so far mention  should  mention "0 (Zero)" in the manufacturing data submission table.

Note: After the year 2024-2025 (year Y), the extended producer responsibility obligation shall be 100% of the quantity of new tyres manufactured or imported in the year (Y-2). Also, Units established after the 1st of April 2022, the extended producer responsibility obligation shall start after two years (Y) and should be 100% of the new tyres manufactured or imported in the year (Y-2).

Role of Recyclers in the EPR Regime

Further, as per provisions of paragraph 7 of Schedule —IX, the above entities are required to fulfil their EPR obligation through the online purchase of EPR Credits or retreading credits through registered recyclers and retreaders of the waste tyre. The EPR obligation for the producers of new tyres has been fixed as follows.

Year	Recycling Targets in Weight (Kilogram or Tons)
2022-23	35% of the quantity of new tyres manufactured or imported in the year 2020-2021
2023-24	70% of the quantity of new tyres manufactured or imported in  2021-2022
2024-25	100% of the quantity of new manufactured or imported in 2022-2023.

Note: The extended producer responsibility obligation for waste tyre importers and recyclers in the year (Y) will be 100% of the tyre imported in the year (Y-1). The import of waste tyres to produce pyrolysis oil or char is prohibited.

General Instruction for all Entities

Applicants can opt for multiple categories of producers based on their business. The applicant has to upload a cover letter making a formal request to CPCB for registration at the online portal. The cover letter should be on the company's letterhead and has to be signed by the authorized person, and should have the company's seal. The scanned cover letter copy must be uploaded on the portal. He must, however, Specify the category of producers as per business activities carried out by him on the application.

The documents uploaded in the application should have a uniform address and match the address mentioned in the registration form. Applicant to provide accurate and verified data w.r.t its manufacturing & import. Documents in support of submission should be available in the producer's office and can be verified by officials of CPCB/SPCB at any time.

Required Documents for Registration for EPR for Waste Tyres

The applicant must provide details of its manufacturing plant/plants per the format released by CPCB. At the time of registering, the applicant must have the following documents ready.

• Covering letter
• An undertaking regarding the submission of authentic data
• Tyre Composition (in Excel Format)
• Submission of plantwise manufacturing data (in Excel Format)
• PAN Card of the company
• GST Number of the company
• 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.

Stages in the Registration Process of EPR for Waste Tyres

Registration and Submission of Application   The applicant needs to sign-up in the portal to get login Credentials. Credentials will be shared at the company's email ID. Upon successful submission of registration from the application will be provided application number for future reference.

Scrutiny of Application and Query Resolution   CPCB will examine documents/submissions made by the applicant while seeking registration in the portal. Any shortcomings will be conveyed to the applicant through the portal along with an intimation email to the authorized person.

Final Registration for EPR for Waste Tyres   In case of submission of a complete registration form, the applicant will get registered in the portal, and CPCB will issue a registration number within 15 days of receipt of the completed form. The validity of registration is two years. Applicant to renew its registration after every two years based on the validity of its registration.

Note: If an applicant falls under multiple categories of stakeholders, i.e. Producers, recyclers and retreaders, then the applicant has to register separately for different categories of stakeholders. Ex. In case a producer is also a recycler, then it has to register at CPCB separately as Producer and Recycler.

Penalties for failing to register for EPR for Waste Tyres

The entities covered under the Hazardous Waste Management Amendment Rules, 2022, will be liable for prosecution u/s 15 of the Environment (P) Act if any incorrect information is provided to obtain EPR certificates or generate EPR certificates above 5% of the actual waste tyre recycled. Moreover, failing to cooperate in the verification and audit procedures will lead to prosecution under the Environment (Protection) Act.

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