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In 2022, India added end-of-life tyres to the list of wastes that are covered by extended producer responsibility (EPR) rules. Since then, manufacturers of tyres in India have been required to buy EPR certificates issued by permitted recyclers of waste tyres to reflect the ‘polluter pays’ principle.
‘Polluter pays’
EPR schemes oblige manufacturers to pay for some of the costs of managing and recycling their products at end of life. The idea is to minimise environmental harms and drive up the overall rate of recycling, while shifting the burden of dealing with waste from taxpayers and local authorities to those that produce it. E-waste, waste plastic and waste oil are all now subject to Indian EPR regulations.
Government recycling targets
Underpinning EPR schemes are government targets for recycling that waste generators must meet. Producers buy EPR certificates at a level that corresponds to a set percentage of the goods they manufacture. In 2022-23, Indian tyre manufacturers were required by government to buy EPR certificates corresponding to 35% of the tyres they produced, which rose to 70% in 2023-24, and 100% in 2024-25.
How Indian EPR works in theory
According to India’s Hazardous and Other Wastes Amendment Rules, 2022, tyre producers, importers of new and scrap tyres, recyclers, and re-treaders are obliged to register on the Central Pollution Control Board’s EPR portal. This is where producers and importers are supposed to buy EPR certificates from recyclers to meet their obligations, rather than directly managing and recycling their own waste.
Certificates are generated by recyclers based on the quantities of tyres they re-process, with each recycling method carrying weightage points that determine the number of credits awarded. Tyre manufacturers and importers are also meant to provide facilities for collecting worn tyres and direct them to licensed recyclers or waste processors, along with fulfilling various new reporting requirements.
Implementation challenges
Some Indian tyre producers have not been buying EPR certificates, however, either because certificates are not available, or because they see the system as flawed and are prepared to risk a fine. The practical challenges of implementing and enforcing EPR across India are acknowledged to be formidable in view of the country’s large informal recycling sector, and growing quantities of imported whole tyres. The UK exported 350,000 metric tonnes of whole scrap tyres to India in 2023, attracting criticism from the UK’s Tyre Recovery Association due to the environmental risks involved, and the underutilisation of tyre re-processing capacity in the UK.
Importers of scrap tyres
Officially, imported shipments of waste tyres are only allowed into India if they are bound for re-processing at permitted plants, not for pyrolysis. In India, pyrolysis is classified as a category orange industry (second only to category red), based on its air pollution potential from combustion and fugitive emissions.
However, the shortage of EPR certificates issued by these permitted recycling plants, and data gathered by bodies such as India’s Automomotive Tyre Manufacturers’ Association (ATMA), suggest that most imports of whole scrap tyres either end up being re-used on vehicles, risking passenger safety, or illegally fuelling batch pyrolysis plants.