India generates a large quantity of waste tyres every year from cars, commercial vehicles, two-wheelers, industrial vehicles and other applications. If these tyres are dumped, burned or processed through unorganised facilities, they can create serious environmental and health problems.
To regulate the management of waste tyres, the Government of India introduced an Extended Producer Responsibility (EPR) framework for waste tyres under the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022.
Under this framework, tyre producers and certain importers are responsible for ensuring that waste tyres corresponding to their prescribed EPR obligations are properly recycled.
Businesses falling within the prescribed definition must therefore obtain EPR Registration for Tyre Waste in India through the Central Pollution Control Board’s centralized Waste Tyre EPR Portal.
This guide explains who requires tyre EPR registration, the documents required, registration process, EPR targets, certificates, returns and major compliance requirements.
What Is EPR Registration for Tyre Waste?
Extended Producer Responsibility (EPR) means that a producer remains responsible for the environmentally sound management of its product even after the product reaches the end of its useful life.
In the case of tyres, the producer is assigned an annual waste tyre recycling obligation based on the quantity of tyres manufactured or imported during the relevant base year.
The producer fulfils this obligation mainly through EPR Certificates generated by registered waste tyre recyclers and transferred through the CPCB online portal.
Therefore, EPR Registration is not simply a one-time certificate. It creates an ongoing responsibility involving:
- Registration with CPCB
- Reporting tyre manufacturing/import data
- Calculation of EPR obligations
- Procurement of eligible EPR Certificates
- Filing of applicable returns
- Maintaining supporting records
- Ensuring compliance with waste tyre management requirements
Legal Framework for Waste Tyre EPR in India
Waste tyre EPR is governed primarily through Schedule IX of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, introduced through the 2022 amendment.
The framework applies to stakeholders involved in activities relating to tyres and waste tyres, including producers, recyclers and retreaders.
The centralized Waste Tyre EPR Portal is operated by the Central Pollution Control Board (CPCB), and applicable stakeholders are required to register and carry out their EPR transactions through the online system.
Who Needs EPR Registration for Tyre Waste in India?
A major point businesses should understand is that tyre EPR is not limited only to companies physically manufacturing tyres. Under the Rules, a Producer can include different types of entities.
1. Domestic Tyre Manufacturers
A company manufacturing and selling new tyres in India falls within the producer category.
For example: a company manufactures truck tyres at its plant in India and sells them throughout the country. Such a company requires EPR registration as a producer.
2. Private-Label Tyre Brands
A company may get tyres manufactured by another manufacturer but sell them under its own brand. Such an entity can also fall within the producer definition.
3. Importers of New Tyres
An Indian company importing new tyres and selling them in the domestic market is covered under the EPR framework.
4. Importers of Vehicles Fitted With New Tyres
This category is particularly important for automobile importers. If a company imports cars, commercial vehicles or other vehicles already fitted with tyres, it can fall within the definition of producer for the tyres introduced into India.
5. Automobile Manufacturers Importing Tyres
An automobile manufacturer importing new tyres for use in vehicles that it manufactures and sells domestically is also covered.
6. Importers of Waste Tyres
Businesses importing used or waste tyres into India also have specific EPR obligations.
The official producer definition covers all six of these categories.
What Is Considered a Waste Tyre?
A waste tyre generally refers to a tyre that is no longer mounted on a vehicle and is no longer being used for its originally intended purpose.
The waste tyre framework also covers associated tyre components such as tubes and flaps within the applicable definition.
Examples include:
- Used car tyres
- Truck and bus tyres
- Two-wheeler tyres
- Commercial vehicle tyres
- Off-road vehicle tyres
- Damaged tyres
- End-of-life tyres
- Tyres rejected from further normal use
- Imported used/waste tyres
Why Is EPR Registration for Tyres Required?
Tyres are made from rubber, carbon black, steel, textile materials and various chemical compounds. Waste tyres can remain in the environment for a long period if they are not handled properly.
Improper tyre disposal may lead to:
- Illegal dumping
- Uncontrolled burning
- Air pollution
- Fire hazards
- Soil and water contamination
- Breeding of mosquitoes in accumulated water
- Loss of recoverable rubber and other materials
The EPR framework attempts to move waste tyres into authorised recycling and recovery channels instead of uncontrolled disposal.
For businesses, EPR Registration for Tyre Waste in India is therefore important both from a legal and environmental-compliance perspective.
Documents Required for EPR Registration for Tyre Waste
The CPCB Waste Tyre EPR Portal currently specifies several basic documents for producer registration.
Basic Company Documents
Generally, the following documents are required:
- Company PAN Card
- GST Registration Certificate
- IEC, in case of import
- CIN, where applicable
- Aadhaar Card of the authorised person
The CPCB portal expressly lists PAN, GST, IEC for importers, CIN and Aadhaar of the authorised person among its producer registration requirements.
Additional Documents and Formats
The portal also provides prescribed formats for:
- Covering Letter
- Undertaking
- Tyre Composition
- Plant-wise manufacturing data
The covering letter and undertaking are generally required on the company’s letterhead and should be signed by the authorised person in accordance with the portal instructions.
Company and Authorised Person Details
Applicants should also keep the following information ready before starting the registration:
- Company name
- Registered/head office address
- Mobile number
- Official email address
- PAN
- GSTIN
- IEC
- CIN
- Date/year of establishment
- Type of business
- Name of authorised person
- Designation
- Mobile number
- Email address
- PAN/Aadhaar details of authorised person
Production and Import Data
Existing businesses are also required to submit historical manufacturing or import data.
The portal currently instructs producers established before FY 2019-20 to provide manufacturing/import quantities from FY 2019-20 onwards. Entities established in later years are required to provide information from the year of establishment.
A newly established producer that has not yet manufactured or imported tyres may report zero quantity as prescribed by the portal.
EPR Registration Process for Tyre Waste in India
The process can broadly be divided into the following steps.
Step 1: Determine Your Producer Category
Before filing, identify why your business falls within the producer definition. For example:
- Tyre manufacturer
- Own-brand seller
- New tyre importer
- Vehicle importer
- Automobile manufacturer importing tyres
- Waste tyre importer
A business carrying out more than one activity should select the applicable producer categories correctly.
Step 2: Collect the Required Documents
Prepare:
- PAN
- GST certificate
- CIN
- IEC, where applicable
- Authorised person Aadhaar
- Covering letter
- Undertaking
- Tyre composition details
- Production/import data
- Plant-wise manufacturing information, where applicable
Ensure that the business name and address appearing across the documents are consistent. CPCB specifically advises applicants to maintain uniform address details in the documents and the online application.
Step 3: Sign Up on the Waste Tyre EPR Portal
Create an account on the CPCB Waste Tyre EPR Portal. The applicant provides initial company and authorised-person details to obtain login credentials.
Step 4: Complete the Online Registration Form
After login, the applicant completes the producer registration form. The information generally includes:
- Company details
- Producer category
- Manufacturing/import details
- Tyre composition
- Plant information
- Supporting documents
Step 5: Submit Historical Tyre Data
Manufacturing or import quantities must be entered carefully because these figures are used for determining the company’s EPR obligation. Incorrect quantity data can create significant compliance issues later.
Step 6: Upload Required Documents
Upload all prescribed documents in the appropriate portal sections. The covering letter, undertaking and other prescribed declarations should follow the CPCB formats wherever specified.
Step 7: Pay the Applicable Registration Fee
The applicable CPCB portal fee is paid online as part of the registration process.
Step 8: Submit the Application
After reviewing the information and supporting documents, submit the application to CPCB. The CPCB portal states that the completed registration application should be submitted within the specified period after signup.
Step 9: CPCB Scrutiny
CPCB examines the information and documents. If there are deficiencies, clarification or additional documents may be sought through the portal. Applicants should respond to the query accurately and within the prescribed time.
Step 10: EPR Registration Number
Once the application is found complete and compliant, CPCB grants registration and issues the registration number. CPCB’s current instructions state that, for a complete application, registration may be issued within 15 days of receipt of the complete form.
Validity of Waste Tyre EPR Registration
As per the current CPCB portal instructions, the registration is valid for two years. The producer is required to renew the registration after the validity period.
Therefore, businesses should maintain a renewal calendar instead of treating EPR registration as a permanent approval.
EPR Targets for Waste Tyres
The most important part of tyre EPR compliance begins after registration. The EPR obligation is calculated primarily on the basis of the quantity of tyres manufactured or imported in earlier years.
Initial EPR Targets
The framework initially provided:
| Financial Year | EPR Recycling Target |
|---|---|
| 2022-23 | 35% of new tyres manufactured/imported in FY 2020-21 |
| 2023-24 | 70% of new tyres manufactured/imported in FY 2021-22 |
| 2024-25 | 100% of new tyres manufactured/imported in FY 2022-23 |
EPR Target From 2024-25 Onwards
After FY 2024-25, the general formula is:
EPR obligation in Year Y = 100% of the quantity of new tyres manufactured or imported in Year Y-2.
For example, if a producer manufactured or imported 1,000 tonnes of tyres in FY 2024-25, its gross EPR obligation for FY 2026-27 is linked to that quantity, subject to the applicable wear-and-tear adjustment prescribed by CPCB.
For units established after 1 April 2022, the obligation starts after two years and is based on 100% of the tyres manufactured or imported in Year Y-2.
Wear-and-Tear Adjustment
The Rules permit the producer’s EPR target to be reduced by a factor prescribed by CPCB to account for normal wear and tear of tyres during their useful life.
Current government analysis notes a wear-and-tear discount factor of 20% in the tyre EPR framework.
Businesses should nevertheless rely on the liability generated through the current CPCB portal when finalising their compliance quantity.
EPR Obligation for Waste Tyre Importers
Waste tyre importers are subject to a different formula. The EPR obligation in Year Y is 100% of the quantity of waste tyres imported in Year Y-1.
For example, if a company imports 500 tonnes of eligible waste tyres during FY 2025-26, the applicable obligation for FY 2026-27 would generally be based on 100% of that quantity under the prescribed framework.
The Rules also prohibit the import of waste tyres for the purpose of producing pyrolysis oil or char.
What Is an EPR Certificate for Waste Tyres?
This is another area where registration and compliance are often confused.
An EPR Registration Certificate shows that the producer is registered with CPCB. An EPR Certificate/Credit, on the other hand, is generated through recycling activities performed by registered recyclers.
The producer purchases/transfers the required EPR certificates through the portal to fulfil its annual EPR obligation.
Therefore, registration is the permission and compliance identity of the producer, while an EPR Certificate is the evidence used to fulfil the producer’s recycling obligation.
How Are Waste Tyre EPR Certificates Generated?
Registered recyclers process waste tyres and produce permitted recycled products.
The eligible quantity of EPR certificates is calculated through the prescribed CPCB mechanism taking into account factors such as:
- Quantity of end product
- Conversion factor
- Weightage assigned to the end product
Recognised waste-tyre recycling outputs include products such as:
- Reclaimed rubber
- Recovered carbon black
- Crumb rubber
- Crumb Rubber Modified Bitumen
- Permitted pyrolysis outputs under applicable conditions
Different end products receive different regulatory weightages for EPR certificate generation.
Can Retreading Be Used for EPR Compliance?
Yes, retreading has a specific role in the waste tyre EPR system.
Retreading means renewing the tread and sidewall rubber of a worn tyre that still has suitable structural integrity. A retreader must register on the CPCB portal to generate eligible retreading certificates.
When a producer uses an eligible retreading certificate, the corresponding EPR obligation can be deferred by one year.
However, retreading does not permanently eliminate the recycling obligation. The obligation is ultimately extinguished only after the tyre reaches end of life and is processed through a registered recycler.
Responsibilities After Obtaining Tyre EPR Registration
Getting an EPR registration number is only the first step. A producer must continue to fulfil several obligations.
1. Calculate Annual EPR Liability
The producer should determine the quantity of waste tyre recycling obligation generated for each financial year.
2. Obtain EPR Certificates
The required EPR certificates should be obtained from registered recyclers through the prescribed online system.
3. File Quarterly Returns
Producers are required to report the relevant EPR compliance information through the portal in the prescribed returns.
4. File Annual Returns
Annual returns must also be filed through the centralized portal within the applicable regulatory timeline.
CPCB may issue deadline extensions from time to time, so businesses should check the live portal for the current filing date rather than relying on an old deadline.
5. Maintain Records
Maintain proper records relating to:
- Tyres manufactured
- Tyres imported
- Waste tyres imported
- Sales
- EPR obligation
- EPR certificates purchased/transferred
- Retreading certificates
- Quarterly returns
- Annual returns
6. Deal Only With Registered Stakeholders
Businesses should verify registration before entering into EPR transactions with recyclers or retreaders.
CPCB’s FAQs specifically state that producers, recyclers and retreaders are required to register on the Waste Tyre EPR Portal and cannot carry out applicable business without registration.
Producer vs Recycler vs Retreader
These three categories should not be confused.
| Stakeholder | Main Role |
|---|---|
| Producer | Introduces tyres into the market and fulfils EPR obligations |
| Recycler | Processes waste tyres and generates eligible recycled outputs/EPR certificates |
| Retreader | Extends the usable life of suitable worn tyres through retreading |
If one company carries out more than one of these activities, separate registrations may be required for the respective stakeholder categories. CPCB specifically instructs entities falling under multiple stakeholder categories to register separately under those categories.
Common Mistakes During Tyre EPR Registration
Businesses can avoid unnecessary CPCB queries by paying attention to some common mistakes.
Incorrect Producer Category
An importer of vehicles may wrongly assume that tyre EPR only applies to tyre importers. However, vehicles imported with fitted tyres can also fall within the producer definition.
Mismatch in Address
The address appearing on GST, PAN, IEC and the application should be checked carefully. CPCB specifically requires consistency in the address submitted with registration documents.
Wrong Historical Data
EPR obligations depend heavily on historical manufacturing and import data. Incorrect quantities can lead to incorrect EPR liability.
Ignoring Tyres Fitted to Imported Vehicles
Importing a complete vehicle does not automatically remove the tyre-related EPR requirement.
Treating Registration as Final Compliance
Registration does not fulfil the recycling target. EPR certificates and prescribed returns must also be handled separately.
Buying Credits From Unregistered Sources
EPR obligations should be fulfilled through the CPCB portal using eligible certificates generated by registered entities.
Missing Renewal
The registration currently has a two-year validity period and must be renewed accordingly.
Penalty for Non-Compliance
Failure to comply with waste tyre EPR requirements may lead to regulatory action, including imposition of Environmental Compensation under the applicable EPR framework.
Non-compliance may arise from situations such as:
- Operating without mandatory registration
- Failure to meet EPR targets
- Failure to submit returns
- Providing incorrect or false information
- Dealing through unauthorised channels
- Improper waste tyre processing
- Other violations of the applicable Rules
Businesses should therefore maintain documentation supporting the quantities reported on the portal and their EPR certificate transactions.
Benefits of Proper Waste Tyre EPR Compliance
Proper EPR compliance provides several benefits. It helps businesses:
- Remain compliant with environmental regulations
- Reduce regulatory risk
- Create traceability of waste tyres
- Promote authorised recycling
- Avoid unorganised waste disposal
- Maintain records for regulatory verification
- Build stronger sustainability credentials
- Improve environmental and ESG performance
For tyre manufacturers, automobile companies and importers, EPR should therefore be integrated into routine regulatory compliance rather than handled only at the end of the financial year.
How ELT Corporate Can Assist With Tyre EPR Registration
The actual registration form may appear straightforward, but EPR liability depends on correctly identifying the producer category and accurately reporting manufacturing/import quantities.
ELT Corporate can assist businesses with:
- EPR applicability assessment
- Producer category identification
- CPCB Waste Tyre EPR Registration
- Documentation preparation
- Covering letter and undertaking
- Tyre composition documentation
- Plant-wise production data preparation
- Import data review
- CPCB query handling
- Registration renewal
- EPR target calculation
- EPR certificate compliance
- Quarterly and annual return support
- Ongoing waste tyre EPR compliance
Whether you are a tyre manufacturer, tyre importer, automobile importer, private-label tyre brand or waste tyre importer, it is advisable to determine your EPR liability before commencing or expanding operations in India.
Conclusion
EPR Registration for Tyre Waste in India is an important compliance requirement for tyre producers and specified importers operating in the Indian market.
The process does not end after obtaining the CPCB registration number. Businesses must also understand their annual EPR obligations, maintain accurate manufacturing/import data, obtain eligible EPR certificates, file prescribed returns and renew their registration on time.
Since the EPR obligation can depend on tyre quantities from earlier financial years, maintaining accurate records from the beginning is especially important.
A properly planned EPR system can help businesses meet their legal obligations while also ensuring that end-of-life tyres are recycled and managed through environmentally sound channels.
Frequently Asked Questions
Tyre manufacturers, private-label tyre sellers, importers of new tyres, importers of vehicles fitted with tyres, automobile manufacturers importing tyres and waste tyre importers can fall within the producer definition.
Yes. Importers selling imported new tyres in India fall within the prescribed producer definition and are subject to the applicable EPR framework.
Yes, the producer definition specifically includes entities importing vehicles fitted with new tyres, subject to the applicable Rules.
The Central Pollution Control Board administers registration through its centralized Waste Tyre EPR Portal.
According to the current CPCB portal instructions, producer registration is valid for two years and must thereafter be renewed.
After FY 2024-25, the general EPR obligation in Year Y is 100% of the quantity of new tyres manufactured or imported in Year Y-2, subject to applicable adjustments including the CPCB-prescribed wear-and-tear factor.
For a waste tyre importer, the EPR obligation in Year Y is 100% of the waste tyres imported in Year Y-1.
The Rules specifically prohibit import of waste tyres for the purpose of producing pyrolysis oil or char.
No. Retreading extends the usable life of a suitable tyre. An eligible retreading certificate can defer the corresponding EPR obligation for one year, but final end-of-life recycling through a registered recycler is still required.
No. Registration is only one part of compliance. Producers also need to fulfil applicable EPR targets, obtain eligible certificates, maintain records and file prescribed returns.
EPR obligations are fulfilled through eligible EPR certificates generated by registered recyclers and transferred through the prescribed CPCB portal mechanism.
For units established after 1 April 2022, the prescribed EPR obligation begins after two years and is generally 100% of the new tyres manufactured/imported in Year Y-2.
Yes. Producers, recyclers and retreaders are separately required to register on the centralized Waste Tyre EPR Portal for their respective activities.
Non-compliance can attract Environmental Compensation and other action under the applicable environmental regulatory framework.