Tyre Waste EPR India: New Targets, Defaulter Lists and Why Brand Owners Are Scrambling

Updated: September 10, 2026 · 15 min read

India placed roughly 1.7 lakh tonnes of end-of-life tyres into the recycling system in FY 2024-25 — yet independent estimates suggest actual waste tyre generation runs closer to 12 lakh tonnes per annum. That gap is not an administrative oversight. It is the fault line that the Central Pollution Control Board (CPCB) is now actively targeting through its tyre EPR portal, escalating annual targets, and a publicly visible defaulter list that carries real commercial consequences. For tyre producers, importers, and the automotive OEMs who sit above them in the supply chain, 2026 is the year that tyre EPR in India stops being a registration formality and starts being an enforcement story.

The Regulatory Spine: Which Rules Actually Govern Tyre EPR in India

Waste tyre management in India sits within the framework of the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 — often abbreviated to the HWM Rules, 2016. Tyres are classified as “Other Waste” under Schedule VI of these rules, which triggers the extended producer responsibility obligations on any entity that manufactures or imports tyres for sale in India. The foundational obligation — that producers bear responsibility for the end-of-life management of the materials they bring to market — flows from this classification.

The HWM Rules, 2016 were significantly amended in 2022, when the Ministry of Environment, Forest and Climate Change (MoEFCC) notified the EPR framework specifically for waste tyres. That amendment introduced annual EPR targets, a centralised portal for registration and certificate trading, and — critically — the mechanism for Environmental Compensation in cases of shortfall. Producers were required to register on the CPCB tyre EPR portal, declare their market volumes, and procure EPR certificates from authorised recyclers to demonstrate compliance.

A second relevant regulation is the Environment (Protection) Act, 1986, the parent statute under which MoEFCC derives the authority to notify waste management rules and direct CPCB to implement them. Penalty provisions under Section 15 of the Act — which allow for fines and imprisonment for contraventions — underpin the enforcement teeth that CPCB now wields through its defaulter mechanism. Separately, producers who are listed companies must also reckon with SEBI’s BRSR Core framework (notified via SEBI circular dated 12 July 2023), under which supply-chain environmental disclosures are mandatory for the top 150 listed companies from FY 2024-25 onwards, with the threshold expanding progressively.

The Numbers That Matter: EPR Targets by Year and the FY 2026-27 Cliff

The stepwise EPR targets under the HWM Rules (as amended in 2022) are not static. They were designed to escalate annually, forcing producers to build genuine collection and recycling infrastructure rather than paper-compliance arrangements. The trajectory is as follows:

Financial Year	EPR Target (% of market volume placed in market)	Environmental Compensation (indicative rate per tonne shortfall)
FY 2023-24	40%	₹8,000 – ₹12,000 per tonne
FY 2024-25	60%	₹10,000 – ₹15,000 per tonne
FY 2025-26	70%	₹12,000 – ₹18,000 per tonne
FY 2026-27 (current)	70% (sustained; potential revision under review)	₹15,000 – ₹20,000 per tonne (revised slab)
FY 2027-28 (notified trajectory)	80%	To be notified

For a mid-sized tyre importer placing, say, 5,000 tonnes of product into the Indian market per annum, a 30% shortfall against a 70% target means 1,500 unrecycled tonnes — and an Environmental Compensation bill potentially exceeding ₹2.25 crore at current indicative rates. That is before any reputational damage from a defaulter list entry. Large domestic producers such as tyre majors with annual volumes measured in hundreds of thousands of tonnes face proportionally catastrophic exposures if their recycling infrastructure does not keep pace with escalating targets.

Compliance certificate procurement from authorised recyclers has also tightened. As more producers scramble for EPR certificates to demonstrate recycling, the certificate market has shown periodic supply crunches, particularly in southern India, where large tyre manufacturing capacity is concentrated in Tamil Nadu and Andhra Pradesh but authorised recycler density remains uneven.

CPCB’s Defaulter List: How It Works and What Getting Named Costs You

The CPCB tyre EPR portal introduced a defaulter publication mechanism as part of its enforcement architecture. Producers and importers who fail to submit annual returns by the deadline — typically 30 June each year for the preceding financial year — or who submit returns reflecting a shortfall against the EPR target without corresponding Environmental Compensation deposits, are listed publicly as defaulters. This is not a minor administrative inconvenience.

Being named on the defaulter list has at least three immediate commercial consequences. First, State Pollution Control Boards in Maharashtra, Tamil Nadu, Gujarat, and Karnataka have begun treating CPCB defaulter status as grounds to delay or deny renewal of Consent to Operate authorisations for manufacturing facilities. Second, several large automotive OEMs have updated their supplier qualification questionnaires to explicitly screen for tyre EPR defaulter status — a development that was practically absent in FY 2023-24 but has become standard in procurement audits during FY 2025-26. Third, listed companies subject to BRSR Core reporting cannot silently absorb a supplier’s defaulter status: it must be disclosed as a supply-chain environmental risk, which has downstream implications for ESG ratings and credit assessments.

The CPCB also retains the authority under the HWM Rules, 2016 to direct the closure of production or import operations for persistent non-compliance — a power it has used sparingly but increasingly telegraphed in show-cause notices issued during the second half of FY 2025-26. Producers who assumed that paying Environmental Compensation would neutralise all consequences are finding that regulators treat repeated shortfalls as evidence of structural non-compliance, not merely a fee-for-service arrangement.

What the 2022 Amendment Actually Changed for Brand Owners and Importers

Before the 2022 amendment to the HWM Rules, 2016, tyre waste management obligations were diffuse. Responsibilities were shared loosely between producers, State Pollution Control Boards, and municipal bodies, with no centralised tracking. The 2022 amendment concentrated accountability sharply onto producers and importers through three structural changes.

First, it introduced mandatory registration on the CPCB’s centralised tyre EPR portal — a prerequisite for any producer or importer placing tyres on the Indian market. Any entity that manufactured or imported tyres before registration was complete was technically in breach from the notification date. Second, the amendment created the EPR certificate trading system, modelled on the plastic waste EPR framework under the Plastic Waste Management Rules, 2016 (as amended). Certificates are generated by authorised recyclers upon processing waste tyres and are transferred to producers to demonstrate EPR compliance — but the certificates must be matched against declared market volumes, and discrepancies trigger Environmental Compensation demands.

Third — and most consequentially for importers — the amendment explicitly captured importers of vehicles containing tyres (including CBU vehicle importers) within the EPR net. Previously, tyre EPR was interpreted as applying primarily to standalone tyre manufacturers. The 2022 clarification meant that automotive OEMs importing CBU vehicles into India now have a separate EPR obligation for the tyres those vehicles carry, distinct from any obligation borne by the tyre manufacturer. This created a genuinely new compliance surface for OEM import desks that few had adequately mapped by the time the first annual return cycle arrived.

The OEM Blind Spot: Upstream Supplier Non-Compliance and BRSR Exposure

For automotive OEMs — whether domestic manufacturers or foreign entities with Indian operations — tyre EPR non-compliance by a Tier-1 supplier is no longer a supplier’s problem alone. The linkage runs through two channels: direct regulatory exposure and disclosure-based reputational risk.

On direct exposure: where an OEM specifies a particular tyre brand for fitment on its vehicles and that brand’s parent entity is registered as a tyre producer under the HWM Rules, 2016, the OEM has a due-diligence obligation to verify that its tyre supplier holds current EPR registration and is not on the CPCB defaulter list. Several environmental legal practitioners have argued — and some CPCB correspondence supports — that OEMs who knowingly source from defaulting producers could, in principle, be treated as accessories to EPR non-compliance, particularly where the OEM-supplier contract does not include EPR compliance warranties.

On disclosure-based risk: SEBI’s BRSR Core framework requires disclosures on “supply chain sustainability” for in-scope listed companies. A tyre supplier defaulter listing is precisely the kind of upstream environmental risk that BRSR Core is designed to surface. Companies that omit this from their disclosures face SEBI scrutiny; those that include it face uncomfortable questions from ESG rating agencies and institutional investors. Neither option is comfortable. The only clean path is to ensure that supplier EPR compliance is verified before the disclosure obligation crystallises — which means quarterly, not annual, checks against the CPCB defaulter list.

For OEM compliance teams, the practical implication is clear: tyre EPR status checks should be embedded into supplier onboarding, annual supplier audits, and the supply-chain data collection process for BRSR reporting. Our post on Scope 3 emissions disclosures and BRSR covers the broader framework within which tyre EPR supplier risk now sits.

Registered Recyclers, Authorised Processors and Why the Choice of Partner Matters

Not every recycler who accepts waste tyres can generate EPR certificates. The CPCB maintains a register of authorised tyre recyclers — entities that hold valid authorisation under the HWM Rules, 2016 and are enrolled on the tyre EPR portal as certificate-generating processors. Using a non-authorised recycler may remove a physical tonne of tyre from your facility, but it generates no EPR credit and provides no protection against a shortfall determination.

The processing methods that the rules recognise include pyrolysis (producing recovered carbon black, pyrolysis oil, and steel wire), crumb rubber manufacturing, and co-processing in cement kilns (where the tyre’s calorific value substitutes for fossil fuel). Each method has different recovery rates and different certificate yields per tonne processed. Producers seeking maximum EPR credit per tonne of recycler spend should understand these differentials rather than treating all authorised recyclers as interchangeable.

Geography matters too. A tyre producer in Pune whose only authorised recycler relationship is in Hyderabad faces logistics costs — and logistics documentation complexity — that a producer with a Mumbai-proximate recycler partner avoids. For fleet operators in Delhi-NCR disposing of high volumes of truck tyres, proximity to authorised recyclers in Haryana or western Uttar Pradesh materially affects the economics of used tyre disposal compliance. The NITI Aayog’s circular economy framework has advocated for a denser network of authorised processors, but the ground reality in FY 2026 is that recycler density remains highest in Maharashtra, Gujarat, and Tamil Nadu, with significant gaps in eastern and north-eastern states.

The 7-Step Tyre EPR Compliance Checklist for FY 2026-27

For compliance officers at tyre producers, importers, or automotive OEMs, the following checklist covers the minimum defensible position for the current financial year. Each step should be completed and evidenced before 31 March 2027 — though steps 1 through 4 are time-sensitive now, in Q2 FY 2026-27.

1. Confirm EPR portal registration is current. Log into the CPCB tyre EPR portal and verify that your producer registration is active, that your entity name matches the current MCA records, and that your designated EPR contact is still employed and has portal access.
2. Declare accurate market volumes for FY 2026-27. EPR targets are calculated against the volume of tyres placed on the market — misreporting this figure (upward or downward) carries its own compliance risk. Cross-check dispatch records, GST e-way bill data, and import bill-of-entry records for completeness.
3. Map your authorised recycler contracts and certificate pipeline. Identify which authorised recyclers you have active agreements with, confirm their CPCB authorisation is current, and project the volume of EPR certificates they can generate for you by 31 March 2027. If that volume falls short of your 70% target obligation, begin remediation now — not in February.
4. Run a CPCB defaulter list check on all tyre suppliers (for OEMs). This is a quarterly action, not an annual one. Download the current defaulter list from the CPCB portal and cross-reference against your approved supplier register. Document the check with a date-stamped record for BRSR purposes.
5. Calculate your Environmental Compensation exposure if targets are missed. Use the indicative rate of ₹15,000–₹20,000 per unrecycled tonne for FY 2026-27 to model a worst-case liability. Brief your CFO on this number before the Q3 board cycle, not after the fact.
6. File your FY 2025-26 annual return if not already done. Annual returns for the preceding financial year are due by 30 June. If your FY 2025-26 return is overdue, file it immediately with any applicable Environmental Compensation deposit — delayed self-disclosure is treated more leniently than a defaulter list entry discovered by CPCB independently.
7. Integrate tyre EPR certificate records into your BRSR data collection system. For listed entities, EPR certificates are material evidence of supply-chain environmental performance. Ensure certificates are retained for a minimum of 5 years and are accessible to your sustainability reporting team in a format that your BRSR auditor can verify.

Frequently Asked Questions

Who is required to register for tyre EPR in India?

Any entity that manufactures tyres in India for domestic sale, or imports tyres (including tyres fitted on imported vehicles) for placement on the Indian market, is required to register as a producer under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 (as amended in 2022). Registration is completed through the CPCB’s tyre EPR portal. Fleet operators who purchase tyres do not have a direct EPR registration obligation, but they are affected by the rules through used tyre disposal requirements.

What is the EPR target for tyre producers in FY 2026-27?

The EPR target for FY 2026-27 is 70% of the total volume of tyres placed on the market by the producer in that financial year. This means that for every 100 tonnes of tyres sold or imported, 70 tonnes must be demonstrably collected and processed by an authorised recycler, evidenced through EPR certificates uploaded to the CPCB portal. The target is expected to rise to 80% for FY 2027-28 under the notified escalation schedule.

What happens if a producer misses its EPR target?

Producers who fail to meet their EPR target face Environmental Compensation calculated on the shortfall tonnage. Indicative rates for FY 2026-27 range from ₹15,000 to ₹20,000 per unrecycled tonne. Beyond financial liability, persistent shortfalls can result in inclusion on CPCB’s public defaulter list, delays in State Pollution Control Board authorisation renewals, and — for listed companies — mandatory disclosure under SEBI’s BRSR Core framework.

Can an OEM be held liable for its tyre supplier’s EPR non-compliance?

Direct liability under the HWM Rules, 2016 rests with the registered producer or importer. However, OEMs face indirect exposure through BRSR Core supply-chain disclosures (SEBI circular dated 12 July 2023), supplier qualification obligations, and potential Consent to Operate complications where an OEM’s facility is co-implicated in a supplier’s non-compliance. OEM procurement teams should treat tyre EPR status checks as a standard supplier audit item from FY 2026-27 onwards.

How do EPR certificates for tyre recycling work, and who can generate them?

EPR certificates are generated by CPCB-authorised tyre recyclers upon processing verified quantities of waste tyres using recognised methods — pyrolysis, crumb rubber production, or cement kiln co-processing. Each certificate represents a specific tonnage of processed material and is uploaded to the CPCB portal, where it can be transferred to a registered producer’s EPR account. Only recyclers with current HWM Rules, 2016 authorisation and tyre EPR portal enrolment can generate valid certificates. Using an unlisted recycler generates no EPR credit.

Work With The National Recycling Corporation

The National Recycling Corporation (NRC) operates a pan-India network of collection, logistics, and authorised recycling partnerships that covers tyre EPR compliance from first-mile pickup through to certificate issuance. Whether you are a tyre producer seeking to close a target gap in FY 2026-27, a fleet operator in Maharashtra looking for compliant used tyre disposal, or an automotive OEM that needs BRSR-grade documentation for supply-chain reporting, NRC can structure the right solution.

Our documentation package for every tyre EPR engagement includes GST-compliant tax invoices, EPR-portal-linked certificates of recycling, weight-slip records, and a compliance summary formatted for your BRSR Core disclosure. All recycling partners in our network hold current CPCB authorisation under the HWM Rules, 2016. We also provide fair-market pricing indexed to commodity benchmarks, ensuring that your recycling arrangements do not subsidise disposal at the expense of recoverable value.

• Pan-India collection: Scheduled pickups from manufacturing plants, warehouses, fleet depots, and port storage across Maharashtra, Gujarat, Delhi-NCR, Tamil Nadu, Karnataka, and Telangana.
• CPCB-authorised disposal partners: All processing facilities in our network are authorised under the HWM Rules, 2016 and are enrolled on the CPCB tyre EPR portal as certificate-generating entities.
• GST-compliant invoicing: Full GST documentation with correct HSN codes for each waste stream, ready for your accounts payable and audit records.
• Certificate of recycling and destruction: Issued per consignment, formatted for BRSR Core and SEBI compliance reporting, and retained in our system for 5 years.
• BRSR-grade reporting support: We can provide periodic data summaries covering volumes processed, EPR certificates generated, and CO₂-equivalent diversion metrics for your sustainability report.

To discuss your tyre EPR requirements for the remainder of FY 2026-27, contact us directly. You can also read more about our broader EPR compliance services or explore our full range of scrap categories we manage for industrial clients across India.

Related Articles

• Maharashtra Pollution Control Board Notices in 2025: What Triggered Them and How to Avoid Them
• Scope 3 Emissions From Waste: The Carbon Disclosure Most Indian Companies Are Hiding
• ISO 14001 vs R2 vs NAID AAA: Which Recycler Certification Should You Actually Demand?

Sources and References

• CPCB — Hazardous and Other Wastes Management: Rules, Authorisation and EPR Portal
• Ministry of Environment, Forest and Climate Change (MoEFCC) — Waste Management Notifications
• Central Pollution Control Board (CPCB) — Tyre EPR Portal and Defaulter Register
• NITI Aayog — Circular Economy and Resource Efficiency Policy Framework
• CPCB Extended Producer Responsibility Portal — EPR Certificate Trading Reference
• SEBI — BRSR Core Framework: Circular dated 12 July 2023 on Supply-Chain Sustainability Disclosures
• Press reports: Economic Times, Business Standard — general coverage of tyre EPR enforcement developments in FY 2025-26 (cited as background; specific headlines not reproduced).