EPR Compliance for Tyre Waste

If you have used a vehicle before, you must have replaced the tyre of this vehicle at some point in time as they only run for a maximum of three to six years and require a replacement after that. Do you know what happened to the replaced piece - whether it was collected for recycling or dumped into the junkyard? Did it reach the recycling facility or never processed? If the latter is the case, it's gonna harm our environment badly. It can contaminate soil and pollute the atmosphere with the harmful chemicals and gases it releases over time during the process of degradation. EPR Compliance for Tyre Waste tries to resolve this problem to a great extent.

Considering the harmful effects of tyre waste and the prevention of the same, the government has introduced an amendment to the hazardous waste management rules of 2016 and added the ninth schedule to these rules which deals with the rules and regulations regarding tyre waste management. This schedule implements Extended Producer Responsibility (EPR) provisions for the tyre waste as well. Now, the producers of tyre waste who are circulating this kind of harmful waste into the market will need to fulfil the annual compliance requirements under these rules from the EPR Registration for Tyre Waste, Fulfilment of EPR Obligations to the Filing of Annual Returns.

Highlights of the Service-

• Fulfilment of Extended Producer Responsibility for Tyre Waste
• Purchasing EPR Credits for Tyre Waste to Complete EPR Obligations
• Filing of Annual Sale - Purchase Data and Report of Recycled Tyre Waste
• Extended Legal Support for any Legal Notice and CPCB Queries

What is Tyre Waste?

The Waste Tyre producers and importers must fulfil compliances as per the rules. However, without the definition of the waste tyre and the term producer, compliance requirements are unclear. Rule 1(m) of Schedule IX defines ‘Tyre Waste’ as the tyre, tubes, and flaps that manufacturers or importers have not installed in a vehicle or that users have discarded and are no longer in use for their intended purpose. These are mostly the tyres replaced after wear and tear.

Which Businesses Need to Comply with Tyre Waste Management Rules?

The following businesses need to comply with the tyre waste management rules including the producers, manufacturers and importers of waste tyres. The term ‘producer’ covers the following business entities that need to fulfil their EPR obligations for each financial year-

• Domestic Manufacturer of new tyres
• Domestic Sellers who sell new tyres under their own Brand Name
• Sellers of imported new tyres
• Importers of vehicles with installed new tyres
• Domestic automobile manufacturers and sellers
• Importers of waste tyres

Note: The importers of tyre waste cannot import waste tyres for the production of pyrolysis oil and char. This is to prevent the accumulation of excessive hazardous waste in the country as the government is still struggling to dispose of the current waste production of the country in an environmentally safe and sound manner.

If we manage waste tyres in an environmentally safe and sound manner as per the rules described in the amended of Hazardous Waste Management Rules, it provides various environmental benefits. Some of the major positive outcomes are as follows-

• It prevents pollution caused by harmful gases which the waste tyres release when not dealt with in an environmentally safe and sound manner.
• The compliance also prevents water pollution and soil degradation as the recyclers collect these waste tyres which minimises their exposure to the environment.
• These rules avert tyre waste from ending up in landfills as the recyclers and producers segregate them beforehand for recycling which is necessary to complete the EPR obligations.
• Recyclers earn profit by selling the end products generated by the recycling of these waste tyres.
• Manufacturers also reduce the cost of new tyres by using recycled products for the manufacturing process including carbon black as raw material and pyrolysis oil as fuel.
• The recycling of waste tyres provides Reclaimed Rubber, Crumb Rubber, Crumb Rubber Modified Bitumen, Recovered Carbon Black and Pyrolysis or Char.

If you fall under the definition of producer as described above then you need to get EPR authorisation for tyre waste and comply with the rules of tyre waste management and fulfil annual EPR compliance for tyre waste. All the producers and business entities dealing with tyre waste need to get EPR Registration from the CPCB Online Portal for Tyre Waste. Only after successful registration, you can undertake activities involving tyre waste. By the end of the current financial year, you also need to achieve your annual EPR target and fulfil the EPR obligation for the previous financial year. At the end of the year before the deadline, you also need to submit the details of the sale purchase and the amount of recycled waste to the Central Pollution Control Board for EPR Audit and the determination of the EPR Target for next year.

Annual EPR Compliance for Tyre Waste

The producers need to complete the EPR Compliance for Tyre Waste they have imported, manufactured or sold under their brand name in India. Such data about the production, import, sale and purchase needs to be submitted to the Central Pollution Control Board so that it can decide, track, manage and audit your annual EPR obligations. The reports of recycled tyre waste by the producers also need to be filed on the EPR portal on a quarterly and annual basis. Corpseed provides you with EPR authorisation for tyre waste and manages your EPR compliances, assists in fulfilling the EPR obligation for tyre waste and files annual returns on your EPR portal. We provide the following services to our clients for their EPR compliance management-

• EPR Obligation Fulfilment

Corpseed provides a facility to fulfil your EPR obligation by recycling tyre waste through its vast network of tyre waste recyclers. We also provide EPR Credits at the minimum price. Producers of tyre waste can utilise these EPR Credits to fulfil their leftover EPR liabilities. Once the EPR liability for the current year is fulfilled, we also provide an EPR plan for timely fulfilment of the EPR liability for subsequent years.

• EPR Portal Management and Annual Filings

Corpseed also manages your EPR portal and files annual returns for the sale and purchase data of your tyre production. Also, we do quarterly and annual recycling report submissions to CPCB through your EPR portal. Based on this data EPR obligation for the next year is concluded and liability for the present year is adjusted accordingly.

• Legal Assistance for Notices and CPCB Queries

If you have received any CPCB query in past which is pending a reply, you do not need to worry about that as our team of legal experts will deal with any legal hurdle that will be stopping you from fulfilling the annual EPR Compliance. They will reply to the notices and assist you with the process involved therein. We have thousands of satisfied customers so be assured that your compliance will be fulfilled on time with perfection.

These EPR Liabilities for the tyre waste producers are renewed after every financial year and the producers need to fulfil these before 30th June of each year. If a part of the EPR obligation is left unfulfilled in the present year then you need to fulfil it the next year along with the EPR liability of the next year. The targets are calculated as below-

Note: Y-2 means 2 years before the year in consideration. For units established after the 1st of April, 2022, the extended producer responsibility obligation shall start after two years (Y) and shall be 100% of the new tyres manufactured or imported in the year (Y-2).

The producers who do not fulfil their EPR obligation before the deadline, need to fulfil their EPR obligation in subsequent years. But if they still fail to meet the EPR obligations consecutively for multiple years, they need to pay the environmental compensation. Apart from the non-fulfilment of EPR obligations, there are some offences for which also environmental compensation will be levied from the Central Pollution Control Board. These offences are as follows-

• Non-Fulfilment of EPR Obligation
• Use of fake EPR Certificates by producers
• Issuance of fake EPR Certificates by the Recyclers
• Dealing with Tyre Waste without Prior Registration at CPCB

Even if the producer is punished with environmental compensation, he has to fulfil the leftover EPR liabilities as soon as possible and if he does so, a portion of environmental compensation is refunded to the producer.

Choose Corpseed for the fulfilment of your EPR Compliance for Tyre Waste as there is no better option than us for EPR Compliance management for the reasons stated below just to quote a few-

• Starting from registration, Corpseed takes care of every EPR compliance you need to fulfil.
• We provide EPR compliance management services for each kind of waste.
• Our recyclers’ network for each kind of waste ensures the availability of EPR Credit at the minimum price possible.
• Corpseed has fulfilled compliance for thousands of businesses and has years of experience in the same.
• We provide legal assistance as well. Our legal team is always ready to resolve any legal issue preventing you from fulfilling your EPR Compliance.
• We save costs for our clients in their EPR Compliance by implementing international best practices for waste management.