Tyre EPR in India: Obligations for Producers, Importers and Retreaders

Updated: October 15, 2026 · 16 min read

India generates an estimated 1.5 to 2 lakh tonnes of waste tyres every year — a volume that has been growing at roughly 8–10% annually as vehicle registrations surge. Until the 2022 amendment to the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, enforcement of tyre EPR in India remained largely aspirational. That changed when the Ministry of Environment, Forest and Climate Change (MoEFCC) formalised EPR certificates, mandated portal-based tracking, and brought retreaders explicitly within the compliance net. With the first enforcement cycles now complete and CPCB scrutinising annual returns for FY 2025-26, producers and importers carrying outstanding recycling obligations face real legal exposure heading into FY 2026-27.

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

Tyre EPR in India sits at the intersection of two regulatory instruments. The primary framework is the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, notified by MoEFCC under the Environment (Protection) Act, 1986. Waste tyres are classified as “other wastes” under Schedule III of these Rules — a classification that triggers storage, handling, transport, and disposal obligations alongside the EPR provisions.

The substantive EPR mechanism was introduced through a dedicated amendment: the Hazardous and Other Wastes (Management & Transboundary Movement) Amendment Rules, 2022, which inserted provisions specifically addressing Extended Producer Responsibility for waste tyres. This amendment prescribed EPR targets, defined obligated entities, established the CPCB EPR portal as the single compliance window, and set out the certificate-based accounting system. Producers, importers, and retreaders who were previously expected to self-report under general hazardous waste provisions now have explicit, measurable, and auditable obligations.

A third layer of regulation applies to end-of-life tyre processing: the Environment (Protection) Act, 1986 itself, under which CPCB and State Pollution Control Boards (SPCBs) issue authorisations to recyclers and pyrolysis units. A recycler without a valid CPCB or SPCB authorisation under the Hazardous Waste Rules cannot generate EPR certificates — and an obligated entity that procures certificates from such a facility is exposed to the same enforcement action as one that has not met its targets at all. Understanding this chain of authorisation is the first step in building a defensible compliance programme.

Who Is Obligated: Producers, Importers, Retreaders — and the Grey Zones

The 2022 amendment defines three categories of obligated entities. Producers are manufacturers of new tyres — companies such as tyre OEMs supplying to vehicle manufacturers or the replacement market. Importers cover entities that bring new or retreaded tyres into India for sale. Retreaders are those who apply new tread to used tyre casings, effectively re-entering spent tyres into the supply chain — a sector that had historically operated with minimal formal compliance burden.

The grey zones are commercially significant. A vehicle manufacturer that imports tyres as part of a completely-built unit (CBU) may carry importer liability under certain readings of the Rules. Similarly, a company that distributes a foreign tyre brand in India under an exclusive arrangement may or may not qualify as an “importer” depending on whether title to the goods passes at the Indian port or overseas. Compliance heads at companies in these positions should obtain a formal legal opinion rather than default to the conservative or the convenient interpretation.

Brand owners who outsource manufacturing to contract tyre producers are not categorically exempt. MoEFCC has signalled — and CPCB’s EPR portal structure reinforces — that the brand owner who places a product on the Indian market bears the EPR obligation. If your brand name is on the tyre, the compliance obligation follows. This principle mirrors the approach taken under the Plastic Waste Management Rules, 2016 (as amended), where brand owner liability has been progressively tightened, and tyre EPR is tracking the same trajectory.

FY 2026-27 Targets: The Numbers That Determine Your Compliance Gap

The 2022 amendment introduced a phased target schedule, with recycling obligations expressed as a percentage of the waste tyre quantity attributable to each obligated entity. The targets escalate year on year. For FY 2026-27, producers, importers, and retreaders are required to ensure recycling or processing of 70% of their estimated waste tyre generation. This follows targets of 40% in FY 2023-24, 50% in FY 2024-25, and 60% in FY 2025-26.

The “waste tyre generation” baseline is calculated using a formula prescribed by CPCB — essentially the quantity of tyres placed on the market by the obligated entity in the relevant reference year, adjusted by an average tyre life factor. For passenger car tyres, the prescribed life factor differs from that applied to commercial vehicle tyres, which have significantly higher mass per unit. Heavy commercial vehicle tyres — which individually weigh 50–80 kg — skew the tonnage-based calculation materially compared to a unit-count approach. Obligated entities should reconcile their SKU-level sales data against the CPCB formula before submitting their EPR plan for the year.

Financial Year	EPR Recycling Target (% of waste tyre generation)	Portal Annual Return Deadline	Key Compliance Action
FY 2023-24	40%	30 June 2024	Baseline registration & first certificate acquisition
FY 2024-25	50%	30 June 2025	Annual return filed; shortfall notice risk
FY 2025-26	60%	30 June 2026	Certificate stockpile audit; SPCB inspections active
FY 2026-27	70%	30 June 2027	EPR plan submission; recycler contracts in place Q1
FY 2027-28 (indicative)	80%+	30 June 2028	Full-cycle traceability expected

The jump from 60% to 70% between FY 2025-26 and FY 2026-27 is the steepest single-year increment so far. Tyre producers who have been passively meeting prior targets by purchasing certificates from a single recycler partner may find that one facility’s annual throughput is no longer sufficient. Diversifying across multiple authorised recyclers — geographically spread to reduce logistics cost — is now a supply-side imperative, not merely a risk management exercise.

How EPR Certificates Are Generated, Transferred and Verified

The EPR certificate system for waste tyres mirrors the architecture established for plastic waste under the CPCB’s Extended Producer Responsibility portal. Authorised recyclers and pyrolysis units log actual waste tyre quantities received and processed on the portal. Upon verification, the portal generates EPR certificates in standardised units (typically per tonne of waste tyre processed). These certificates carry a unique identification number, the name of the generating facility, the processing date range, and the processing route (mechanical recycling, pyrolysis, or co-processing in cement kilns).

The obligated producer or importer then purchases or is allocated these certificates — the transaction is recorded on the portal and certificates are transferred digitally. The obligated entity’s annual return, filed on the same portal, must show that the total face value of certificates held equals or exceeds its target tonnage for the year. CPCB and the concerned SPCB can verify this in real time.

A critical procedural point: EPR certificates cannot be banked indefinitely. CPCB has indicated that certificates generated in one financial year must be applied against that year’s obligation or the immediately following year’s obligation. Stockpiling certificates across multiple years as a hedge against future shortfalls is not permitted under the current framework — a restriction that differs from some international EPR schemes and catches compliance teams by surprise. Obligated entities should plan their certificate acquisition on a near-current basis rather than attempting to build a multi-year buffer.

Pyrolysis Compliance: Why Not Every Facility Can Issue a Valid Certificate

Pyrolysis — the thermal decomposition of waste tyres in the absence of oxygen to yield tyre-derived oil (TDO), carbon black, and steel wire — is the dominant processing route for waste tyres in India. The sector has grown rapidly, with an estimated 300–400 pyrolysis units operating across Rajasthan, Gujarat, Punjab, and Andhra Pradesh. However, a large proportion of these units operate without valid authorisation under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, and are therefore incapable of generating legitimate EPR certificates.

CPCB has prescribed specific technical standards for pyrolysis units seeking authorisation: these include sealed reactor systems to prevent fugitive emissions, a flue gas treatment system capable of meeting the prescribed stack emission limits (particulate matter below 150 mg/Nm³, and sulphur dioxide limits tied to feed sulphur content), and a log of feedstock receipts and product dispatch maintained for a minimum of 3 years. Units that cannot demonstrate compliance with these norms during SPCB inspection will have their authorisation refused or revoked — and certificates they may have issued prior to revocation may be invalidated retroactively for EPR accounting purposes.

What to Check Before Contracting a Pyrolysis Unit

Before signing an EPR certificate supply agreement with any pyrolysis facility, obligated entities should independently verify: (a) the facility’s current authorisation status on the CPCB hazardous waste portal, (b) the validity date of the authorisation, (c) whether the unit is listed on the CPCB’s register of EPR-eligible processors for waste tyres, and (d) whether the facility’s annual processing capacity (in tonnes) is sufficient to generate the volume of certificates you require. A mismatch between contracted certificate volume and the facility’s authorised capacity is a red flag that CPCB’s verification process is increasingly catching.

Maharashtra-based obligated entities should also note that the Maharashtra Pollution Control Board (MPCB) has been conducting surprise inspections of pyrolysis units in the Pune and Nashik corridors following complaints about emissions and illegal feedstock sourcing. Certificates issued by units found non-compliant during these inspections have been flagged in several annual return audits, creating downstream liability for the producers who relied on them. Our EPR compliance services include pre-contract verification of recycler authorisation status to eliminate precisely this risk.

Enforcement in 2026: What CPCB and SPCBs Are Actually Scrutinising

Enforcement of tyre EPR obligations tightened meaningfully through FY 2025-26. CPCB issued show-cause notices to a number of producers and importers who had either failed to register on the EPR portal, filed incomplete annual returns, or whose certificate holdings did not match their declared waste tyre generation calculations. While CPCB has not publicly disclosed the full list of defaulting entities, recent CPCB enforcement actions — including those reported in industry trade press through mid-2026 — indicate that the regulator is no longer treating portal non-compliance as an administrative oversight. It is being treated as a substantive breach of the Hazardous Waste Rules.

The penalties available to CPCB under the Environment (Protection) Act, 1986 are significant. Section 15 of the Act prescribes a fine of up to ₹1 lakh per day for continuing contravention, in addition to imprisonment of up to five years — a provision that can be applied against the company and its responsible officers individually. For listed companies, CPCB non-compliance also carries a secondary SEBI risk: BRSR (Business Responsibility and Sustainability Reporting) disclosures now require companies to report environmental regulatory compliance, and a CPCB show-cause notice or direction creates a disclosure obligation that many legal teams are not yet fully prepared for.

SPCBs in Tamil Nadu, Telangana, and Rajasthan have independently stepped up inspections of end-of-life tyre storage yards — targeting informal aggregators who are feeding non-authorised pyrolysis units. Obligated entities whose collection programmes rely on these informal aggregators carry liability risk even if their certificates appear valid on the portal. CPCB’s verification audits are beginning to trace certificates back to source facilities and cross-check against those facilities’ authorised capacity and actual inspection records.

Your FY 2026-27 Compliance Checklist for Tyre EPR

With the financial year now underway, the following actions should be completed or initiated this quarter. Deferring any of these to Q3 or Q4 risks both a certificate supply crunch and a portal filing delay.

1. Confirm or update your CPCB EPR portal registration — check that your company’s legal name, authorised signatory, and category (producer / importer / retreader) are accurate and that your registration remains active for FY 2026-27.
2. Calculate your FY 2026-27 waste tyre generation baseline — apply the CPCB formula to your FY 2025-26 sales data by SKU and tyre category. Confirm the 70% EPR target tonnage. Document the calculation methodology for your annual return.
3. Verify authorisation status of every recycler or pyrolysis partner — check each facility’s current authorisation on the CPCB website and confirm they are listed as EPR-eligible processors. Do not rely solely on a certificate or letter from the facility itself.
4. Execute written supply agreements with authorised processors — agreements should specify monthly certificate delivery quantities, the processing route, and a clause requiring immediate notification if the processor’s authorisation is suspended or revoked.
5. Set up a monthly certificate reconciliation process — track certificates received against the portal balance every month. Do not wait until Q4 to discover a shortfall.
6. Review your collection infrastructure — if you rely on dealer take-back or retail collection points, confirm these are covered by your EPR plan filed with CPCB. Uncovered collection channels create traceability gaps.
7. Prepare your annual EPR report framework early — the annual return is due by 30 June 2027, but the underlying data (waste tyre quantities, certificate IDs, processing routes, recycler details) should be captured in a structured format throughout the year, not assembled retrospectively.
8. Check BRSR disclosure implications — if your company is a listed entity filing BRSR Core or extended BRSR, map tyre EPR compliance status to the relevant environmental compliance disclosures before your Q3 board review.

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Frequently Asked Questions

Who is required to register for tyre EPR in India?

Under the Hazardous and Other Wastes (Management & Transboundary Movement) Amendment Rules, 2022, registration on the CPCB EPR portal is mandatory for three categories: producers (manufacturers of new tyres sold in India), importers (entities placing imported tyres on the Indian market), and retreaders (entities that apply new tread to used tyre casings for resale). Brand owners who outsource tyre manufacturing are also considered producers if their brand name appears on the product placed on the market.

What is the EPR recycling target for tyres in FY 2026-27?

The prescribed EPR recycling target for waste tyres in FY 2026-27 is 70% of each obligated entity’s estimated waste tyre generation for the year. This is calculated using a CPCB-prescribed formula based on the entity’s sales volumes and tyre life factors by category. The target has risen from 60% in FY 2025-26 and will increase further in subsequent years. Annual returns demonstrating certificate fulfilment against this target must be filed on the CPCB portal by 30 June 2027.

Can any pyrolysis unit generate EPR certificates for waste tyres?

No. Only pyrolysis units holding a valid authorisation under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 — issued by CPCB or the relevant State Pollution Control Board — and separately listed on the CPCB’s EPR-eligible processor register can generate valid tyre EPR certificates. Units must meet CPCB’s prescribed emission norms (including a particulate matter limit of below 150 mg/Nm³) and maintain feedstock and product records for at least 3 years. Certificates from non-compliant or unauthorised units do not satisfy EPR obligations.

What are the penalties for failing to meet tyre EPR targets?

Penalties for non-compliance with tyre EPR obligations are enforced under the Environment (Protection) Act, 1986. Section 15 of the Act provides for fines of up to ₹1 lakh per day for continuing contraventions, alongside imprisonment of up to five years for responsible officers. Beyond financial penalties, CPCB can issue directions under Section 5 of the Act — including directing suspension of production or import activities — until compliance is restored. Listed companies also face BRSR disclosure obligations if they receive formal regulatory directions.

How long must EPR records and certificates be retained?

Obligated entities and their authorised processing partners are required to retain all EPR-related records — including certificate transfer documentation, recycler agreements, and annual return filings — for a minimum of 3 years from the date of filing. CPCB or State Pollution Control Boards may call for these records during inspections or in response to show-cause notices. Electronic copies stored on the CPCB portal are official, but companies should maintain supporting documentation (invoices, dispatch records, recycler authorisation copies) in their own compliance management systems.

Work With The National Recycling Corporation

Meeting a 70% waste tyre recycling obligation in FY 2026-27 requires more than a certificate purchased at year-end. It requires a traceable, documented chain from your tyre collection points to a CPCB-authorised processing facility — with GST-compliant invoicing, portal-recorded certificate transfers, and a compliance paper trail your auditors can follow without gaps. That is what The National Recycling Corporation provides for producers, importers, and retreaders across India.

We operate pan-India, with logistics networks covering Maharashtra (including Mumbai, Pune, Nashik, and Nagpur), Gujarat, Delhi-NCR, Tamil Nadu, Karnataka, and Telangana. Our EPR compliance services include pre-contract verification of processor authorisation status, monthly certificate reconciliation support, and documentation packages designed to satisfy both CPCB annual return requirements and BRSR-grade sustainability disclosures. Every transaction is backed by a certificate of recycling and a GST-compliant tax invoice — materials your compliance and finance teams can use directly.

Our industrial waste management division handles collection logistics for large-volume generators including tyre manufacturers, fleet operators, automobile dealerships, and vehicle scrapping centres. Whether your waste tyre volumes run to 10 tonnes a month or 500 tonnes a quarter, we structure the collection and processing programme to match. To discuss your FY 2026-27 tyre EPR obligation and get a compliance quote, contact us today.

• Pan-India tyre waste collection and logistics across 15+ states
• Processing through CPCB-authorised recyclers and pyrolysis units only
• Portal-traceable EPR certificate generation and transfer
• GST-compliant invoicing and certificate of recycling with every consignment
• BRSR-grade compliance documentation for listed entities
• Annual return support — data compilation, portal filing assistance, and recycler audit trails

Sources and References

• Central Pollution Control Board — Hazardous and Other Wastes Management Rules, 2016 (as amended)
• Ministry of Environment, Forest and Climate Change (MoEFCC) — Environmental legislation and notifications
• Central Pollution Control Board (CPCB) — EPR portal and waste tyre processor registry
• CPCB Extended Producer Responsibility Portal — EPR certificate framework reference
• NITI Aayog — Circular economy policy framework for India
• Bureau of Indian Standards (BIS) — Standards for tyre-derived products including carbon black and tyre pyrolysis oil
• CPCB — Plastic Waste Management Rules (for EPR framework comparison)
• Press reports (Business Standard, Economic Times) — Industry coverage of CPCB enforcement actions and tyre EPR implementation, FY 2025-26