EPR for Waste Tyres and Used Oil

Tyres and lubricating oil have joined plastic, e-waste and batteries in India's extended producer responsibility system. Through amendments to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, the government made producers and importers of new tyres responsible for the environmentally sound management of waste tyres from 2022, and producers and importers of base oil and lubricating oil responsible for used oil from 1 April 2024. Both systems work through registration on the CPCB portal, yearly targets, and certificates generated by registered recyclers and re-refiners.

These regimes affect tyre manufacturers and importers, vehicle makers who import tyres, lubricant brands, base oil importers, and the businesses that recycle tyres into crumb rubber, reclaimed rubber and pyrolysis oil, or re-refine used oil. Pyrolysis of tyres has been the subject of NGT orders because of pollution from poorly run plants. This page explains who must register, how targets work, the role of recyclers, and how to deal with enforcement.

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Tyre and used oil EPR at a glance

Waste tyre EPR in detail

Under the tyre EPR framework added to the Hazardous and Other Wastes Rules in 2022, the obligation of a tyre producer is calculated with reference to the quantity of new tyres it produced or imported in an earlier year. The targets were phased in, starting with a partial share of that quantity and rising to cover the full quantity of tyres placed on the market two years earlier. Producers meet the obligation by buying certificates from registered recyclers who convert waste tyres into specified end products, such as reclaimed rubber, crumb rubber, crumb rubber modified bitumen, recovered carbon black and pyrolysis oil or char.

Retreading extends the life of tyres and is treated as a way to reduce waste, but it does not by itself generate EPR certificates in the same way as recycling. Exports of waste tyres for recycling abroad are restricted, and imports of waste tyres for pyrolysis are subject to tight controls.

Pyrolysis plants and the NGT

Tyre pyrolysis heats waste tyres in the absence of oxygen to produce oil, carbon char and gas. Poorly designed batch-type plants have caused serious air pollution and fire risks, and the NGT has directed boards to shut down units that do not meet the CPCB's standard operating procedures and to restrict new plants that do not use continuous, automated processes with proper controls. Several states have closed non-compliant pyrolysis units in recent years.

If you run or plan a pyrolysis plant, check the current CPCB guidelines on plant design, siting and emissions, ensure the plant holds consent and hazardous waste authorisation, and keep records of tyres received and outputs sold. Only compliant, registered plants can generate EPR certificates, and certificates from plants later found non-compliant may be cancelled.

How to register and comply

Used oil EPR

From 1 April 2024, producers of base oil and lubricating oil, including importers, have EPR obligations for used oil. The targets are linked to the quantities sold in earlier years and rise over time. Certificates are generated by registered re-refiners and recyclers who process used oil into re-refined base oil or other permitted products. Used oil itself remains a hazardous waste, so collection, storage and transport must follow the hazardous waste rules, with authorisation and manifests.

Lubricant brands that buy base oil from refiners and blend it should check how the obligation is allocated between the base oil producer and the brand, according to the rules and portal guidance, to avoid gaps or double counting. Workshops, fleet operators and factories that generate used oil must hand it over only to authorised collectors or re-refiners. See hazardous waste authorisation.

Choosing recyclers and re-refiners

As with other EPR systems, certificates have value, and there have been cases of certificates generated without real processing. Producers should check a recycler's registration, consent, authorisation and capacity, ask for evidence of inputs and outputs, and include warranties and indemnities in contracts. Unusually cheap certificates should prompt questions. If certificates are later cancelled, the producer's obligation is treated as unmet.

Time and typical cost

Our fees are agreed in writing at the start, stage by stage. They are not linked to the outcome.

End products that generate tyre certificates

Documents usually needed

Laws that apply

How we work

We are a litigation and advisory practice led by Advocate BK Singh, with offices in Dwarka (New Delhi) and Vaishali (Ghaziabad). This is what you can expect:

• Role and obligation mapped: for tyres and oil.
• Recycler due diligence: before certificates are bought.
• Pyrolysis units advised: on consent, siting and NGT orders.
• Notices answered: with reconciled data.
• Written fee terms: agreed stage by stage, never linked to the outcome.

Mistakes we see with tyre and oil EPR

Vehicle makers and importers

Tyre EPR does not apply only to tyre companies. A vehicle manufacturer that imports tyres to fit on vehicles it assembles, or an importer of completely built vehicles, brings new tyres into the Indian market and may have obligations as an importer of tyres under the rules. The same applies to importers of machinery and equipment fitted with tyres. Domestic tyres bought from an Indian manufacturer are normally accounted for by that manufacturer, but imported tyres are not.

If your business imports vehicles or tyred equipment, check how the rules and the portal treat tyres fitted on imported goods, and register if needed. Missing this is a common reason for notices to vehicle importers who never thought of themselves as tyre producers.

Workshops, fleets and factories

Used oil is generated wherever engines and machines are serviced: vehicle workshops, fleet operators, transport companies, factories, construction sites and DG set operators. Under the hazardous waste rules, generators must store used oil safely and hand it over only to authorised collectors, recyclers or re-refiners, with records. Selling used oil to informal buyers, who burn it as fuel or dump it, is an offence and has led to notices to generators traced through the oil.

The used oil EPR system relies on this oil reaching registered re-refiners. Generators who keep handover records protect themselves and help producers meet their targets. Fleet operators and workshop chains can often negotiate better terms with registered re-refiners for regular, segregated quantities.

Recycler registration and audits

Tyre recyclers and used oil re-refiners must hold consent to operate, hazardous waste authorisation where relevant, and registration on the CPCB portal to generate certificates. The CPCB verifies recyclers' capacity and records, and has suspended registrations and cancelled certificates where claimed output exceeded what a plant could produce or where inputs could not be traced. Recyclers should keep weighbridge records, purchase invoices, production logs and sales records for every end product, and be ready for audit at short notice. Your certificates are only as reliable as your records.