Radial Insights Analysis.
India's domestic tyre production reached 4.2 million metric tonnes in FY2024-25, and the industry has been growing at roughly 10 percent a year, a pace that NITI Aayog and The Energy and Resources Institute expect will more than double industry revenue between FY2022 and FY2032. Waste tyre volumes are scaling with it. In FY2024, India processed 3 million metric tonnes of waste tyres, 1.6 million tonnes generated domestically and 1.4 million tonnes drawn in as imported feedstock. Against that backdrop, the country's Extended Producer Responsibility regime for tyres has moved past its early phase-in years and is now running at full obligation. For a market growing this fast, the rules have stopped being a compliance footnote. They have become a capacity planning problem that touches procurement, plant investment, and highway construction all at once.
Figure 1. India's Tyre Industry Growth Trajectory, FY2022 to FY2032 (Actual and Projected)
The EPR Framework and Its Current Obligation Formula
The Ministry of Environment, Forest and Climate Change notified amendments to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules on July 21, 2022, inserting Schedule IX to govern the collection, recycling, and disposal of waste tyres. The Central Pollution Control Board built and now operates the online EPR portal where producers, recyclers, and retreaders must register. Producers meet their obligation by purchasing EPR certificates from registered recyclers rather than recycling material themselves, which has turned certificates into a tradable compliance instrument with its own supply and demand dynamics.
For established production units, the obligation from 2024-25 onward is set at 100 percent of the new tyres a producer manufactured or imported two years earlier, reduced by a 20 percent wear-and-tear discount factor built into the calculation. Waste tyre importers face a similar rule tied to the previous year's import volume.
Producers evaluating how this obligation fits into a broader compliance program can draw on Radial Insights' EPR Policy Navigation practice, which maps EPR obligations and compliance program design across India and other regulated markets.
Provision | Detail |
Legal instrument | Schedule IX, Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022 |
Effective date | July 21, 2022 |
Nodal ministry | Ministry of Environment, Forest and Climate Change |
Regulator and portal | Central Pollution Control Board, Waste Tyre EPR Portal (eprtyres.cpcb.gov.in) |
Obligation formula, established units | From 2024-25 (Year Y) onward, 100 percent of new tyres manufactured or imported in Year Y-2, net of a 20 percent wear-and-tear discount factor |
Obligation start, new units | Units established after April 1, 2022 begin their obligation two years after commissioning, on the same Y-2 basis |
Waste tyre importers | 100 percent of the tyre volume imported in Year Y-1 |
EPR certificate validity | 2 years from date of issue |
Maximum penalty | Imprisonment up to 5 years, fine up to Rs 1 lakh, or both |
Source: Ministry of Environment, Forest and Climate Change, Schedule IX; NITI Aayog and TERI, Enhancing Circular Economy of Waste Tyres in India, January 2026, Table 4. Compiled by Radial Insights.
The rules also carry real teeth. A producer who submits incorrect information, or a recycler who over-generates certificates beyond 5 percent of actual recycled volume, is punishable with imprisonment of up to five years, a fine of up to one lakh rupees, or both. Certificates themselves are valid for two years, which forces continuous sourcing rather than one-time stockpiling.
A Certificate Market That Is Already Ahead of Its Obligation
Cumulative CPCB portal data through September 1, 2025 shows the EPR obligation across all producer classifications since the rules took effect in 2022 stood at 6.20 million metric tonnes. Against that, registered recyclers had generated 9.20 million metric tonnes of EPR certificates, 6.64 million tonnes tied to domestic tyres and 2.56 million tonnes tied to imported tyres, of which 6.31 million tonnes had actually been traded or transferred to producers. Certificate generation running ahead of cumulative obligation points to a supply cushion building in the system, though the gap between certificates generated and certificates traded, roughly 2.9 million tonnes, suggests distribution and matching between recyclers and producers still has friction to work out.
Figure 2. India's Waste Tyre EPR Certificates, Cumulative 2022 to September 2025
Registration itself is still catching up. As of the same date, 711 recyclers had applied for CPCB registration and 552 had been granted it, alongside 194 waste tyre importers (164 granted) and 117 new tyre manufacturers and importers (84 granted). A meaningful share of applicants, particularly on the recycling side, remain in the pipeline rather than fully authorized.
Where Production Still Outruns Formal Recycling
The clearest sign of unfinished formalization is the gap between what gets manufactured and what gets recycled through authorized channels. The 2024 recycling obligation was set against 2.4 million metric tonnes of tyres manufactured domestically in 2022, including inner tubes and flaps. Yet only 1.6 million metric tonnes of domestic waste tyres were processed through formally authorized facilities in 2024, leaving roughly 0.8 million metric tonnes, about a third of the production base, unaccounted for. Even after applying a 22 percent wear factor to reflect rubber lost through normal use, close to 0.27 million metric tonnes still cannot be traced to registered recycling capacity.
That gap is mirrored in the recycler base itself. Of an estimated 851 total tyre recyclers operating in India as of September 2025, 552 hold formal authorization, 159 have applications pending, and roughly 140 are estimated to be operating informally, without registration. The informal segment alone accounts for an estimated 0.42 million metric tonnes of recycling capacity, and unauthorized capacity across both pending and informal operators together totals close to 0.90 million metric tonnes, capacity that sits outside CPCB oversight, environmental safeguards, and the EPR certificate system
Figure 3. India's Tyre Recycler Base, September 2025
The practical consequence for buyers of EPR certificates is that a meaningful share of nominal recycling capacity sits outside formal oversight. A certificate sourced from an unauthorized operator does not satisfy a producer's underlying obligation, so procurement teams that verify a recycler's CPCB registration status before signing multi-year sourcing agreements are better protected than those buying on the spot market.
Radial Insights' End-of-Life Tire (ELT) Management and Circular Design practice helps producers model these valorization pathways and vet counterparty registration status before committing to multi-year sourcing agreements.
How Tyre Makers Are Responding: What the Annual Reports Show
The clearest signal of how seriously Indian OEMs are treating this obligation comes from their own disclosures. Apollo Tyres' FY2024-25 Sustainability Report shows recycled raw material content at 4.8 percent of total production in FY2024, of which reclaimed rubber made up 42 percent, and the company has set a 2030 target of 40 percent sustainable raw material content across its tyres, split between a 30 percent bio-based share and a 10 percent recycled share. That is a roughly twofold increase in the recycled component alone within six years.
Figure 4. Apollo Tyres: Recycled Raw Material Content, FY2024 Actual vs FY2030 Target
CEAT Limited's investor commentary around its FY2024-25 results treats the EPR obligation as a direct addition to raw material cost rather than a side compliance line, noting that the obligation in any given year is linked to production sold in India two years earlier, which means EPR cost planning now sits inside the same forecasting cycle as natural rubber procurement. JK Tyre and Industries' Integrated Annual Report and Business Responsibility and Sustainability Report for FY2025-26 describes a zero waste to landfill policy across its operations and continued investment in radial tyre manufacturing capacity designed around reduce, reuse, and recycle principles. Taken together, the three disclosures show that EPR compliance has moved from a legal filing exercise into a line item that shows up in sustainability targets, cost guidance, and capital allocation.
Downstream Demand: Highways and a Quirk in the Credit System
Crumb rubber has a demand outlet well beyond tyre manufacturing itself. The Ministry of Road Transport and Highways recognizes crumb rubber modified bitumen for use in specified pavement layers on national and state highways, and recent circulars tie the use of polymer modified and crumb rubber modified bitumen to Bureau of Indian Standards service condition tables under IS:15462. Rubberized bitumen improves rutting resistance and fatigue life, both relevant given the heavy axle loads and monsoon exposure typical of Indian highway conditions.
Yet the EPR credit system does not currently reward that pathway in proportion to its policy backing. Under the CPCB's weightage and conversion methodology, crumb rubber modified bitumen carries the lowest EPR multiplier of any recycled product category, 0.22, compared with 4.59 for recovered carbon black usable in new tyre manufacture and 1.69 for reclaimed rubber. A tonne of waste tyre converted into CRMB earns a fraction of the certificate credit that the same tonne would earn if converted into reclaimed rubber or recovered carbon black, even though CRMB has an active, policy-backed highway offtake channel that many other recycled products lack. That mismatch, flagged directly in the NITI Aayog and TERI analysis, means the credit system and the demand-side policy are currently pulling in different directions for this particular material stream.
What This Means for Tyre Makers, Recyclers, and Investors
For OEMs, the near-term task is sourcing discipline. Certificate generation is currently running ahead of cumulative obligation, which should keep near-term certificate pricing in check, but the recycler base still has real gaps: nearly a third of domestic production is not reaching formally authorized recyclers, and roughly 0.90 million metric tonnes of recycling capacity sits outside CPCB registration. Producers that verify counterparty registration status, rather than buying certificates on price alone, carry less compliance risk as enforcement against unauthorized capacity continues.
For recyclers and pyrolysis operators, the opportunity is capital investment in registered, standards-aligned capacity that can absorb a production base projected to more than double in size by FY2032. For materials and infrastructure players, the mismatch between CRMB's low EPR multiplier and its strong highway policy backing is worth watching. A revision to the weightage methodology, which the NITI Aayog and TERI report explicitly recommends, could materially change the economics of crumb rubber destined for road construction relative to reclaimed rubber and recovered carbon black.
The direction of travel is not ambiguous. India's tyre industry is on a trajectory to more than double in size by the early 2030s, formal recycling capacity is still working through a meaningful backlog of unauthorized operators, and the credit system that is supposed to price different recycling pathways consistently still has acknowledged design gaps. Recyclers and OEMs that build documentation-ready, standards-compliant capacity now, and that track how the EPR weightage methodology evolves, will be better positioned than those treating today's certificate surplus as a permanent condition.
This analysis is part of Radial Insights' ongoing coverage of India's circular economy and industrial policy landscape.
Frequently Asked Questions
It is a regulatory framework under Schedule IX of the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022, notified by the Ministry of Environment, Forest and Climate Change on July 21, 2022. It requires tyre producers and importers to take responsibility for the collection, recycling, and disposal of waste tyres, tracked through the Central Pollution Control Board's online EPR portal. Radial Insights tracks this obligation cycle closely as part of its coverage of India's circular economy policy.
From 2024-25 onward, established production units must meet an obligation equal to 100 percent of the new tyres they manufactured or imported two years earlier, minus a 20 percent wear-and-tear discount factor. Waste tyre importers face a comparable obligation based on 100 percent of the previous year's import volume.
Producers purchase EPR certificates from registered recyclers instead of recycling the material themselves. This has created a tradable compliance market with its own certificate pricing, supply, and demand dynamics, and certificates are valid for two years from the date of issue.
Yes. As of September 2025, an estimated 140 of India's 851 tyre recyclers were operating informally without CPCB registration, and total unauthorized capacity, including pending applications, was close to 0.90 million metric tonnes. A certificate sourced from an unauthorized operator does not satisfy a producer's underlying obligation, so verifying a recycler's registration status before signing sourcing agreements matters.
Under the CPCB's current weightage methodology, crumb rubber modified bitumen (CRMB) carries an EPR multiplier of just 0.22, compared with 4.59 for recovered carbon black and 1.69 for reclaimed rubber, even though CRMB has active, policy-backed demand from national and state highway construction. NITI Aayog and TERI have flagged this mismatch and recommended a revision to the methodology.
Producers who submit incorrect information, or recyclers who over-generate certificates beyond 5 percent of actual recycled volume, face imprisonment of up to five years, a fine of up to Rs 1 lakh, or both.
This piece is part of Radial Insights' ongoing thought leadership series on India's tyre and rubber industry, covering EPR policy, recycling capacity, and circular economy trends. Check the Radial Insights Thought Leadership section for related analysis.