Since July 2022, every producer and importer of tyres in India has been responsible for recycling what it sells. Most treat that as a cost: buy enough certificates, file the paperwork, move on. The producers who treat it as a supply strategy will end up with something more useful than a certificate.
How the rules work
The Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022 added Schedule IX on waste tyres, in force from 21 July 2022.
- Who is covered: tyre manufacturers and importers, brand owners, importers of vehicles fitted with new tyres, importers of waste tyres, recyclers and retreaders. All must register on the Central Pollution Control Board's portal.
- The obligation: recycling measured by weight against new tyres placed on the market. It stepped up from 35 per cent in 2022–23 to 70 per cent in 2023–24 and 100 per cent from 2024–25, each year measured against tyres sold two years earlier.
- The certificate: producers meet the obligation by buying EPR certificates from registered recyclers and submitting them in quarterly filings. Recyclers report monthly what they processed and produced.
- The consequences: producers and recyclers who fall short pay environmental compensation under CPCB guidelines. False information, or certificates more than 5 per cent above actual recycling, can bring prosecution.
Five end products, not one
The rules recognise five recycling outputs: reclaimed rubber, crumb rubber, crumb rubber modified bitumen, recovered carbon black, and pyrolysis oil or char. Pyrolysis oil and char count only when used as fuel, not as raw material for new tyres.
That distinction matters. Three of the five — reclaimed rubber, recovered carbon black and crumb rubber — are materials a tyre maker can use again.
From certificate to partnership
A producer buying certificates on the open market pays for recycling and gets nothing else. A producer that partners with recyclers can get more:
- Materials it can use. Recovered carbon black and reclaimed rubber from its own end-of-life tyres, to specifications it sets.
- A steadier supply of certificates, from recyclers it knows, rather than whoever has credits to sell that quarter.
- A story it can stand behind for customers and investors asking about recycled content.
The model already exists elsewhere. In 2024 Continental agreed a ten-year purchase of recovered carbon black from Pyrum Innovations, and supplies Pyrum with end-of-life tyres in turn. The same logic fits India's EPR system: the producer's obligation becomes the recycler's feedstock and the producer's raw material.
What it takes
- Choosing recyclers for their output and capacity, not only their certificate price.
- Agreeing specifications for the materials that come to you.
- Structuring contracts that cover both the obligation and the supply.
With targets now at 100 per cent, the obligation is permanent. Producers who turn it into a supply relationship early will have first choice of partners.
Related: Regulatory and EPR advisory.