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iEnhancing Circular Economy
of Waste Tyres in India
Enhancing
Circular Economy
of Waste Tyres in India

Enhancing Circular Economy of Waste Tyres in India
Copyright @ NITI Aayog
Published: January 2026
NITI AAYOG
National Institute for Transforming India
Government of India
NITI Bhawan, Sansad Marg
New Delhi – 110001
DISCLAIMER
1. This document is not a statement of policy by the National Institution for Transforming India
(hereinafter referred to as NITI Aayog). It has been prepared by The Energy and Resources
Institute (TERI) pursuant to the support of NITI Aayog, for the purpose of independent
academic and policy-oriented research.
2. Unless otherwise stated, NITI Aayog, in this regard, has not made any representation or
warranty, express or implied, as to the completeness or reliability of the information, data,
findings, or methodology presented in this document. While due care has been taken by
the author(s) in the preparation of this publication, the content is based on independently
procured information and analysis available at the time of writing and may not reflect the
most current policy developments or datasets.
3. The assertions, interpretations, and conclusions expressed in this report are those of the
author(s) and do not necessarily reflect the views of NITI Aayog or the Government of
India, unless otherwise mentioned. As such, NITI Aayog does not endorse or validate any
of the specific views or policy suggestions made herein by the author(s).
4. NITI Aayog shall not be liable under any circumstances, in law or equity, for any loss,
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encouraged to independently verify the data and conduct their analysis before forming
conclusions or taking any policy, academic, or commercial decisions.

iiiEnhancing Circular Economy
of Waste Tyres in India
Enhancing
Circular Economy
of Waste Tyres
in India

Foreword

Acknowledgements
We thank Shri BVR Subrahmanyam, CEO, NITI Aayog, for his guidance and valuable
suggestions in the preparation of this report. We also thank the members of the Working
Group on Circular Economy of Tyres for their active participation and constructive inputs.
We thank our knowledge partner, The Energy and Resources Institute (TERI), the concerned
ministries and all stakeholders for their support in finalising the report.
CHAIRPERSON
Maj Gen K Narayanan
AVSM**, SM (Retd), Programme Director,
Security and Law, NITI Aayog
Chairperson, Working Group on Circular
Economy of Tyres
LEADERSHIP
Shri Suman K Bery
Vice Chairperson, NITI Aayog
Shri Rajiv Gauba
Member, NITI Aayog
Shri B.V.R. Subrahmanyam
CEO, NITI Aayog
Dr. Anshu Bharadwaj
Programme Director, Green Transition,
Climate and Environment (GTC&E), NITI
Aayog
Shri Surender Mehra
Advisor, GTC&E, NITI Aayog
Shri Amit Verma
Former Director, GTC&E, NITI Aayog
(Presently Joint Secretary, Department of
Commerce)
Shri Satyendra Kumar
Former Director, GTC&E, NITI Aayog
(Presently Inspector General, ACB, Rajasthan)
Shri Priyavrat Bhati
Programme Lead, GTC&E, NITI Aayog
AUTHORS
NITI AAYOG
Shri Amit Verma
Former Director, GTC&E, NITI Aayog
Ms. Prinshila Gandhi
Young Professional, GTC&E, NITI Aayog
Dr. Abhijeet Anand
Consultant, GTC&E, NITI Aayog
KNOWLEDGE PARTNERS
Dr Souvik Bhattacharya
Director and Senior Fellow, TERI
Mr. Arya Jash
Research Associate, TERI

viiiEnhancing Circular Economy
of Waste Tyres in India
WORKING GROUP COORDINATORS
Shri Amit Verma
Former Director, GTC&E, NITI Aayog
Ms. Prinshila Gandhi
Young Professional, GTC&E, NITI Aayog
WORKING GROUP MEMBERS
Sh. Sudhendu Jyoti Sinha,
Former Adviser (Infra & Connectivity),
NITI Aayog
Shri Vinod Singh
Director, MoEFCC
Shri KC Sharma
Advisor, MoRTH
Shri Ankit Duggar
Director, MoRTH
Shri Harsh Prabhakar
Executive Engineer (Transport), MoRTH
Ms. Vandana
Director (Petrochemicals), DCPC
Shri Dheeraj Kumar Meena
Under Secretary, DPIIT
Shri Anand Kumar
Former Additional Director, Central Pollution
Control Board (CPCB)
Ms. Youthika puri
Additional Director, CPCB
Shri Santosh Kumar
Assistant Director, MoMSME
Mr. Mrityunjay Kumar
Director, RCEICE, FICCI
Dr Praveen Kumar
Programme Head, WRI
Dr. Rinkel Jindal
Vice Chairman, ITTAC, Apollo
Mr Niteesh K Shukla
Director, ITTAC
Shri Sanjay Chatterjee
Assistant DG, ATMA
Mr. Gaurav Sekhri
Managing Director, Tinna Rubber
Mr. Sanjay Banati
Manager, Tinna Rubber
Mr. BK Jalan
Chairman, Tyromer Technology
Mr. Roopesh
CEAT
Mr. VK Mishra
JK Tyres
Shri Sreekumaran Nair
Deputy General Manager, MRF Tyres
Mr. Vijay Shrinivas
Indag Rubber
Mr. Harsh Gandhi
Director, Tyres, MRAI
Mr. Rahul Goyal
Director, Tyres, MRAI
Mr. Pramod Shinde
Head, Communication, MRAI

ixEnhancing Circular Economy
of Waste Tyres in India
Mr. Gaurav Kaul
H/o Government Relations, MRAI
Prof. Bineesha Payattati
MRAI
Mr. Vishesh Agrawal
Chairman, AIRTRA
Mr. Chetan Joshi
President, TRRAI
Mr. Paul Vannan
Senior Deputy Director, Indian Rubber
Materials Research Institute
Mr. Nitin Chitkara
CEO, Meta Materials Circular Market
(MMCM)
COLLABORATORS
Shri Tanmay Kumar
Secretary, MoEFCC
Shri Neelesh Kumar Sah
Joint Secretary, MoEF&CC
RESEARCH & NETWORKING (R&N) TEAM
Ms. Anna Roy
Programme Director, R&N, NITI Aayog
Ms. Banusri Velpandian
Senior Specialist, R&N, NITI Aayog
DESIGN TEAM
Ms. Keerti Tiwari
Director. Communication, NITI Aayog

iEnhancing Circular Economy
of Waste Tyres in India
Table of Contents
List of Figures............................................................................................................................iii
List of Abbreviations................................................................................................................iv
1. Introduction..............................................................................................................................1
1.1 Overview........................................................................................................................................... 1
1.2 Tyre Production in India............................................................................................................2
2. Waste Tyre Generation and Recycling............................................................................. 4
2.1 Waste Tyre Generation...............................................................................................................4
2.2 Material Flow of Waste Tyre Recycling in India ��9
2.3 Different Tyre Recycling Processes and Their Products �� 10
2.4 Extent of Pollution in the Tyre Recycling Industry �� 16
3. Regulatory Landscape for Waste Tyres.......................................................................... 17
3.1 Broad Policies Governing Waste Tyres Recycling �� 17
3.1.1 Ministry of Environment, Forest and Climate Change (MoEFCC)�� 17
3.1.2 Central Pollution Control Board (CPCB) �� 17
3.1.3 Directorate General of Foreign Trade (DGFT) �� 18
3.2 Extended Producer Responsibility (EPR) for Waste Tyres 18
4. An Analysis of EPR.............................................................................................................23
4.1 Understanding the EPR Multiplier Factors �� 23
4.2 The EPR’s Position on Tyre Pyrolysis................................................................................24
4.3 Key Challenges and Proposed Solutions �� 28
4.3.1 EPR Weightage System Rationalisation �� 28
4.3.2 Refining Regulation for Tyre Pyrolysis �� 29

iiEnhancing Circular Economy
of Waste Tyres in India
5. Informality and Traceability in ELT Processing �� 30
5.1 Production-Recycling Gap Due to Leakage to Informal Sector 30
5.2 Estimate of Unauthorised Recyclers..................................................................................31
5.3 Key Challenges and Proposed Solutions �� 31
5.3.1 Operation of unauthorised facilities leading to compliance concerns �� 31
5.3.2 GST complexity undermining waste tyre formalisation 32
5.3.3 Dedicated HSN Code for Tyre Recycling Sector �� 33
6. Recycled Material Standardisation.................................................................................34
6.1 Constraints for High-Value Export Products �� 34
6.2 Substitution Savings of Different Tyre Recycled Products 34
6.3 Key Challenges and Proposed Solutions �� 35
6.3.1 Production standards for TPO and rCB �� 35
6.3.2 Opportunity for export market.................................................................................35
6.3.3 Recycled products utilisation in high-value applications 36
7. Tyre Retreading....................................................................................................................37
7.1 What is Retreading?..................................................................................................................37
7.2 Market Share in Retreading across Vehicle Segments ��37
7.3 Issues Pertaining to Retreading...........................................................................................38
8. Conclusion – Summary of Recommendations �� 40
9. Annexure...............................................................................................................................43

iiiEnhancing Circular Economy
of Waste Tyres in India
List of Figures
Figure 1 Components of a Tyre 1
Figure 2 Tyre Production for FY 2024, in MMT 2
Figure 3 Segment-wise tyre production by volume for FY 2024 3
Figure 4 Waste Tyres Generation and Recycling in FY 2024 4
Figure 5 Batch Pyrolysis 5
Figure 6 Continuous Pyrolysis 6
Figure 7 Mechanical Crumbing 7
Figure 8 Devulcanisation (Chemical) 8
Figure 9 Estimated Material Flow of ELT Recycling in India 10
Figure 10 Plasma Pyrolysis Schematic Diagram 27
Figure 11 Gap between Production and Recycling 30
Figure 12 Authorised and Estimated Unauthorised Recyclers 31
Figure 13 Tyre Retreading 37

ivEnhancing Circular Economy
of Waste Tyres in India
List of Abbreviations
ABAP Advanced Batch Automated Pyrolysis
ATMA Automotive Tyre Manufacturers’ Association
BIS Bureau of Indian Standards
CPCB Central Pollution Control Board
CRMB Crumb Rubber Modified Bitumen
DGFT Directorate General of Foreign Trade
DPIIT Department of Promotion of Industry and Internal Trade
ELT End-of-Life Tyres
EPR Extended Producer Responsibility
MoEFCC Ministry of Environment, Forests and Climate Change
MoMSME Ministry of Micro, Small and Medium Enterprises
MoPNG Ministry of Petroleum and Natural Gas
MMT Million Metric Tonnes
MRAI Material Recycling Association of India
MRP Micronised Rubber Powder
OCEMS Online Continuous Effluent and Emission Monitoring System
OEM Original Equipment Manufacturer
rCB Recovered Carbon Black
SOP Standard Operating Procedure
SPCB State Pollution Control Board
TDP Tyre Derived Polymer
TPO Tyre Pyrolysis Oil

vEnhancing Circular Economy
of Waste Tyres in India

viEnhancing Circular Economy
of Waste Tyres in India
Executive Summary
India stands at a pivotal juncture in managing its growing volume of End-of-Life Tyres (ELTs)
1
,
driven by a fast-expanding automobile sector and increasing tyre consumption. With tyre
production projected to double in the coming decade, the challenge of sustainably managing
ELTs has assumed critical importance. At the same time, the recycling of tyres presents a
unique opportunity to advance circular economy objectives, reduce import dependence on
key raw materials, and create new avenues for green employment.
The current recycling ecosystem is fragmented, with critical gaps in traceability, standardisation,
and value recovery. Despite the presence of an Extended Producer Responsibility (EPR)
framework, inconsistencies in the weightage methodology, ambiguity in assigning values
to different recycled products, and an established informal sector limit the effectiveness of
waste tyre recycling.
High-value recycled products face limited uptake due to the lack of standards and market
mandates. This results in downcycling and missed opportunities for import substitution.
Additionally, tyre retreading—a well-established circular pathway—remains under-
incentivised, with the majority of retreaders operating informally and the practice excluded
mainly from EPR credits.
The report recommends a cohesive approach to unlock the circular potential of ELTs. The EPR
certificate generation may be revised to include a precise, auditable mechanism, supported
by a common conversion factor, to ensure adequate transparency into certificate availability,
environmental integrity, and market efficiency. Verification of materials produced from waste
tyre processing may be standardised through mass-flow mapping, and mandatory installation
of Online Continuous Emission Monitoring Systems (OCEMS) may be enforced for tyre pyrolysis
units. Tyre Pyrolysis Oil (TPO) may be restricted to refineries or select industrial applications,
and carbon char may be refined exclusively into recovered Carbon Black (rCB) to prevent
sub-optimal end uses and strengthen downstream material accountability. National standards
for TPO and rCB may be notified and guidelines for their use in value-added applications may
be issued to promote the uptake of recycled tyre materials and integration of recycled tyre
products into domestic procurement and supply chains.
Formalisation of the ELT recycling ecosystem is essential for effective implementation
of the EPR regime. All stakeholders across the ELT value chain to be integrated into the
EPR framework. Digital platforms such as the Udyam Assist Platform may be leveraged
to onboard unauthorised recyclers. Targeted financial support and a one-time waiver of
outstanding environmental liabilities may be extended to facilitate infrastructure upgrades
in non-compliant units, subject to formalisation and future compliance. GST rationalisation
for ELTs and recycled tyre products, along with separate HSN codes for crumb rubber and
micronised rubber powder, is recommended to improve market clarity and competitiveness.
These measures will help create a robust, transparent, and formalised ecosystem with
proper accounting of ELT material flows. Strengthening domestic markets for secondary raw
materials will generate multiple co-benefits: enhancing material recovery, reducing import
dependence, creating high-quality green jobs, and positioning India as a leader in sustainable
tyre recycling and advanced circular practices. Moreover, such interventions will support the
Government’s Make in India initiative, improve industrial competitiveness, and contribute to
broader national commitments on resource efficiency, and sustainable development.
1 Waste Tyres and End-of-Life Tyres (ELT) have been used interchangeably in this report.

1Enhancing Circular Economy
of Waste Tyres in India
1. Introduction
1.1 Overview
India’s rapid growth in the automobile sector has led to a corresponding rise in the demand
for tyres, and consequently, in the generation of waste tyres. Tyres, being a safety-critical
component, are subject to significant wear and tear and typically last only about one-fifth
the life of a vehicle. This accelerated turnover has resulted in a surge in End-of-Life Tyres
(ELTs), which, if not managed through responsible recycling, can pose serious environmental
hazards and economic inefficiencies.
Improper disposal or technologically inferior recycling of ELTs not only contributes to
pollution but also leads to the loss of valuable materials such as rubber, steel, and carbon
black—critical inputs for a range of downstream industries. As tyres are inherently material-
rich (Figure 1), their mismanagement represents a missed opportunity for resource recovery
and circularity. Unregulated recycling practices have led to poor compliance with emission
standards, which poses environmental risk, and low-value recovery of materials, weakening
the economic viability of the sector.
Figure 1: Components of a Tyre
This report examines the current landscape of waste tyre management in India, with a focus
on the Extended Producer Responsibility (EPR) framework, the structure of the recycling
ecosystem, and the challenges faced by waste tyre recyclers. It highlights the regulatory
inconsistencies, informality in operations, and lack of product standardisation that currently
limit the potential of India’s waste tyre economy. Drawing from global best practices and
domestic data, the report presents actionable recommendations to build a transparent,
standardised, and circular tyre recycling ecosystem that supports environmental sustainability
and industrial resilience.

2Enhancing Circular Economy
of Waste Tyres in India
1.2 Tyre Production in India
India’s tyre industry plays a crucial role in the global market, ranking 7
th
in global tyre
production with a 3% share. The industry has been witnessing steady growth at an annual
rate of 10%, driven by increasing demand from various vehicle segments and a focus on
expanding production capacity. For the financial year 2024-25 (FY 24), India’s total domestic
tyre production stands at 4.2 million metric tonnes (MMT). Of this, 2.5 MMT is absorbed for
the domestic market along with 0.2 MMT of inner tubes and flaps, while 1.5 MMT is exported,
showcasing India’s strong presence in the global tyre market. Import of new tyres remains
relatively low at just 0.07 MMT, indicating a self-sufficient industry with minimal reliance on
foreign supply. (Figure 2)
Figure 2: Tyre Production for FY 2024, in MMT (Values provided by ATMA)
The two and three-wheeler segment contributes the most to tyre production, accounting for
53% of total output. This dominance is driven by the high demand for two-wheelers in India,
particularly in urban and rural mobility. Other major contributors include passenger cars
(26%), followed by truck and bus tyres (11%), light commercial vehicles (5%), and agricultural
and farm tyres (4%). The remaining 1% of production serves miscellaneous vehicle categories.
(Figure 3)

3Enhancing Circular Economy
of Waste Tyres in India
Figure 3: Segment-wise tyre production by volume for FY 2024 (Source: ATMA)
Given this production landscape, India’s tyre industry continues to expand its export footprint
while meeting growing domestic demand. With sustained growth, increasing investment, and
advancements in technology, the sector is poised for further development within the next
ten years. A report on the Indian tyre industry
2
predicts that it has the potential to more
than double its revenue by FY 2032 compared to its revenue in FY 2022. The growth would
be driven by rising vehicle demand, sustained government investment in infrastructure, and
a robust replacement market supported by a large in-use vehicle base. Its share in India’s
manufacturing GDP is expected to rise from 2.2% to 3.4% over the same period, alongside
higher GST contributions, employment generation, and global trade share. However,
volatility in natural rubber and other raw material prices poses a risk to industry profitability.
Strengthening domestic recycling and advancing tyre circularity can help mitigate these risks
by reducing import dependence, stabilising input costs, and enhancing resource efficiency,
thereby supporting the sector’s long-term competitiveness.
2 “Tyre industry on a roll, driving towards doubling in size”, Crisil

4Enhancing Circular Economy
of Waste Tyres in India
2. Waste Tyre Generation and Recycling
2.1 Waste Tyre Generation
Waste tyre generation and recycling are critical aspects of sustainable waste management
and resource efficiency in the country. In FY 2024, the total waste tyres recycled in India
amounted to 3 MMT. Out of this, 1.6 MMT were generated domestically, while 1.4 MMT were
imported, highlighting the substantial level of imported waste tyres feeding into the domestic
tyre recycling feedstock. (Figure 4)
Figure 4: Waste Tyres Generation and Recycling in FY 2024
(all values in MMT) (Values provided by Industry)
Broadly, pyrolysis emerges as the dominant method of tyre recycling, accounting for 2.68
MMT. Out of which, 2.64 MMT goes to batch process and 0.04 MMT is recycled through the
continuous process. Concurrently, 0.27 MMT of reclaim/devulcanised rubber was generated
from waste tyres. While a lot of waste tyres are mechanically processed into crumb rubber,
it is largely used as an intermediate product in continuous pyrolysis and in the production of
reclaim rubber. This leaves about 0.05 MMT of crumb rubber which is used as raw material in
the rubber goods industry.

5Enhancing Circular Economy
of Waste Tyres in India
The different tyre recycling processes as mentioned above are discussed in Box 2.1.
Box 2.1 Different Tyre Recycling Processes
i) Batch Pyrolysis
Figure 5: Batch Pyrolysis
(Source: Gamboa, A. A., dos Santos, L. R., Martins, C. A., Rocha, A. M., Alvarado-Silva, C. A., &
de Carvalho Jr, J. A. (2023). Thermodynamic Evaluation of the Energy Self-Sufficiency of the
Tyre Pyrolysis Process. Energies, 16(24), 7932.)
Batch pyrolysis is a cyclic thermochemical process that decomposes waste tyres in
an oxygen-deficient reactor, one batch at a time. It uses manual or hydraulic feeders
that can directly accept whole tyres or small-sized materials. The process yields tyre
pyrolysis oil (TPO), carbon char, and steel.

6Enhancing Circular Economy
of Waste Tyres in India
Box 2.1 Different Tyre Recycling Processes (contd.)
ii) Continuous Pyrolysis

Figure 6: Continuous Pyrolysis
(Source: Radhe Group of Energy - Waste Tyre / Waste Plastic Recycling Pyrolysis Process )
Continuous pyrolysis is an automated process where rubber powder or blocks are
fed into a closed reactor through a fully automatic system. It allows for efficient heat
transfer, higher processing capacity, and improved energy efficiency compared to
batch systems.

7Enhancing Circular Economy
of Waste Tyres in India
Box 2.1 Different Tyre Recycling Processes (contd.)
iii) Mechanical Crumbing

Figure 7: Mechanical Crumbing
(Source: Bilema, M., Yuen, C. W., Alharthai, M., Al-Saffar, Z. H., Al-Sabaeei, A., & Yusoff, N.
I. M. (2023). A review of rubberised asphalt for flexible pavement applications: production,
content, performance, motivations and future directions. Sustainability, 15(19), 14481.)
Mechanical crumbing is a process in which waste tyres are physically ground into
fine rubber particles known as crumb rubber. The two primary technologies are
(i) ambient grinding, conducted at or above room temperature and widely used in
practice, and (ii) cryogenic grinding, which involves cooling tyres with liquid nitrogen
before processing. In India, ambient grinding is the prevalent practice due to relatively
lower capital investment as opposed to cryogenic grinding, which is markedly costlier.
This method enables material recovery for use in roads, sports surfaces, and rubber
products.

8Enhancing Circular Economy
of Waste Tyres in India
Box 2.1 Different Tyre Recycling Processes (contd.)
iv) Devulcanisation/ Reclaim Rubber

Figure 8: Devulcanisation (Chemical)
(Source: Saputra, R., Walvekar, R., Khalid, M., Mubarak, N. M., & Sillanpää, M. (2021). Current
progress in waste tire rubber devulcanisation. Chemosphere, 265, 129033.https://www.
sciencedirect.com/science/article/abs/pii/S0045653520332306)
Reclaim rubber is produced by selectively breaking sulfur-sulfur (S–S) and carbon-
sulfur (C–S) bonds in vulcanized rubber, with minimal degradation of the main
polymer chains, a process known as devulcanisation. This allows the rubber to regain
plasticity and be reused in various rubber products. Reclamation of rubber has
multiple methods, broadly divided into physical, chemical and biological methods.
Further divisions which find industry applications in physical reclaim include thermal
and thermo-mechanical devulcanisation. This material is used by the tyre industry
(upto 5%) for production of new tyres.

9Enhancing Circular Economy
of Waste Tyres in India
2.2 Material Flow of Waste Tyre Recycling in India
The recycling process is dominated by pyrolysis processes (Figure 9) accounting for 2.68
MMT of ELT recycling. Of this, batch pyrolysis accounts for recycling 2.64 MMT of ELT, and
only about 0.04 MMT ELT is processed through continuous pyrolysis systems. A sizeable
share of pyrolysis feedstock is likely to come from imported waste tyres which has first been
converted into crumb rubber.
The pyrolysis route results in the generation of 1.10 MMT of tyre pyrolysis oil (TPO), 0.80 MMT
of carbon char, and 0.3 MMT of steel wire, of which 0.05 MMT of carbon char is processed
into recovered carbon black (rCB), while a larger share (0.75 MMT) of carbon char is diverted
directly to industrial applications.
Crumbing and devulcanisation account for a smaller share of the recycling landscape. While
these processes primarily account for imported waste tyres recycling, a smaller share of
domestic tyres are also crumbed, chiefly to be used in other processes. Approximately 1.53
MMT of ELT are directed towards crumb rubber production, while 0.27 MMT undergo reclaiming
or devulcanisation. However, only 0.05 MMT of crumb rubber currently goes towards direct
applications and therefore it is largely considered to be an intermediary product. Micronised
Rubber Powder (MRP), a very fine crumb grade of 170 mesh is used directly in new tyres
demonstrating circularity in tyre sector. A major proportion of crumb rubber finds its way to
the pyrolysis industry – either as feedstock for continuous pyrolysis or as feedstock in batch
pyrolysis plants to meet processing capacity. Devulcanisation processes yield high-quality
substitutes for virgin rubber. Reclaim rubber finds application across both tyre and non-
tyre sectors. Within the tyre industry, it is used in approximately 0.06 MMT of production,
contributing to circularity, while in the non-tyre segment, its utilisation is split between the
automotive sector at around 0.02 MMT and non-automotive uses at nearly 0.10 MMT. Overall
demand is supported by both domestic and export markets, with exports accounting for
about 0.09 MMT.

10Enhancing Circular Economy
of Waste Tyres in India
The data underscores the heavy reliance on pyrolysis in India’s tyre recycling landscape. While
it provides an efficient way to recover valuable materials, a considerable portion (20-25%,
as per research and stakeholder interactions) of the current batch process plants operate
outside regulatory oversight. They do not comply with the standard operating procedure
(SOP) for Advanced Batch Automated Pyrolysis (ABAP) and continuous pyrolysis as laid
down by the Central Pollution Control Board (CPCB), creating material loss, environmental
degradation and environmental and health hazards.
Figure 9: Estimated Material Flow of ELT Recycling in India (Values in MMT) (Based on
industry data and in-house calculations)
2.3 Different Tyre Recycling Processes and Their Products
While different tyre recycling processes vary in their material recovery potential and
corresponding product applications, their adoption in India is often determined less by
recovery efficiency alone and more by operational parameters such as infrastructure and
capital cost, access to energy required for the respective processes, as well as the availability
of feedstock. These factors largely shape investment decisions and have influenced the
predominance of pyrolysis over other recycling methods. The different parameters for
different tyre recycling processes are summarised in Table 1.

11Enhancing Circular Economy
of Waste Tyres in India
Table 1: Comparison of Tyre Recycling Processes
Parameters Pyrolysis Devulcanisation Crumbing
Cost
Batch - Low-cost
Moderate to High Moderate
Continuous - High-cost
Feedstock Whole/Shredded tyres Shredded tyres Whole tyres
End product
Tyre pyrolysis oil (TPO)
Carbon Black
Steel wire
Reclaimed rubber Crumb rubber
Energy
requirement
Low High Moderate
The different end products of the different recycling processes and their respective uses are
explained in detail in Box 2.2.
Different tyre recycling processes vary considerably in terms of capital and energy
requirements, and the range of products they generate. Within pyrolysis, both batch and
continuous processes are practiced, with batch process forming most of the pyrolysis
practiced in the country. Each process is characterised by distinct operational efficiencies,
investment needs, and environmental performance. Table 2 provides a comparative overview
of these two pyrolysis pathways, underscoring their implications for scalability, compliance,
and circular economy outcomes.

12Enhancing Circular Economy
of Waste Tyres in India
Table 2: Differences between Batch and Continuous Pyrolysis
Parameters Batch Continuous
Feeding method Manual or simple hydraulic feeders.
Fully automatic closed feeding
system.
Material fed
Directly process whole tires and
small-sized materials.
Process small-sized materials such
as rubber powder and blocks.
Automation level
Semi-automatic and requires 3-4
people to operate.
High labour intensity and low
automation.
Can operate continuously and
requires 1-2 people.
High degree of automation and low
labour intensity.
Final Product
quality
Uses cyclic heating and cooling.
Difficult to ensure consistent
product quality.
Uses a continuous and stable
environment.
Stable final product quality.
Plant Cost Low investment and operating cost. High investment and operating cost.
Energy utilisation
Each operation requires reheating
and cooling.
Efficiency is low with high energy
consumption.
Fuel consumption low and saves
operating costs.
Higher efficiency with continuous
feeding and discharging system.

13Enhancing Circular Economy
of Waste Tyres in India
Box 2.2 Recycled Products from Different Processes and Their Applications
i) Pyrolysis
Results in two primary outputs: carbon char and Tyre Pyrolysis Oil (TPO); along with the
recovery of a small amount of steel wire. Carbon char, by itself is often used as a substitute
for pet coke by industries. When processed, it yields rCB—a fine black powder used as a
reinforcing filler in rubber products. While lower grade rCB is commonly used in products
like floor mats, moulded goods, and low-end footwear, high-quality rCB can replace a
portion of virgin carbon black in tyre manufacturing, particularly in sidewalls and non-
critical areas. This reduces dependence on imports. TPO is a waste-derived fuel that can
be used as an industrial heating oil in boilers, furnaces, or kilns, offering a substitute for
Light Diesel Oil (LDO) and Furnace Oil. When refined, TPO has potential applications in
blending with commercial fuels or as a feedstock for petrochemical industries. Pyrolysis
also generates syngas (non-condensable gases), which can be used to power the
pyrolysis plant itself, improving energy efficiency. The recovered steel is usually sold as
scrap and further processed and can go on to be used in concrete reinforcement and
manufacturing.

Tyre Pyrolysis Oil (TPO)
1
Carbon Char
2
Steel Wire Scrap
3
1 IndiaMart. indiamart.com/proddetail/tyre-pyrolysis-oil-20179300848.
2 Beston. bestonpyrolysisplant.com/carbon-black-tyre-pyrolysis/
3 IndiaMart. indiamart.com/proddetail/tyre-pyrolysis-steel-wire-scrap-23169282788.

14Enhancing Circular Economy
of Waste Tyres in India
Box 2.2 Recycled Products from Different Processes and Their Applications
(Contd.)
ii) Mechanical Crumbing
Crumb rubber is extensively used in sports and recreational infrastructure, such as
running tracks, synthetic turf infill, and children’s playground surfaces, where it provides
cushioning, shock absorption, and slip resistance. In civil construction, it is incorporated
into CRMB (Crumb Rubber Modified Bitumen) for building more durable and weather-
resistant roads with improved elasticity and reduced cracking. Crumb rubber is also
molded into rubber pipes, seals, and gaskets for non-critical industrial uses. It finds
applications in flooring tiles, speed bumps, noise barriers, and even as a component
in composite building materials when blended with plastics. In manufacturing, fine-
grade crumb rubber can be used to produce rubberized adhesives, coatings, and mats,
while ultra-fine grades serve in rubber-plastic composites or as additives in paints and
sealants. Crumb rubber can also serve as an intermediate feedstock for reclaiming or
further pyrolysis, supporting closed-loop recycling.

Crumb rubber
4
Crumb Rubber Modified Bitumen (CRMB)
5

Micronized Rubber Powder (MRP)
6
Tiles from crumb rubber
7
4 EcoMENA. ecomena.org/crumb-rubber-uses
5 PetroNaft. petronaftco.com/rubber-modified-bitumen
6 Tinna. tinna.in/rubber-products
7 Bullrock Fitness. bullrockfitness.com/crumb-rubber-tiles

15Enhancing Circular Economy
of Waste Tyres in India
Box 2.2 Recycled Products from Different Processes and Their Applications
(contd.)
iii) Devulcanisation
Reclaim rubber is widely used in the manufacture of roofing sheets, reclaimed rubber
mats, and tiles, which are durable and cost-effective options for building applications.
Its use in tyre manufacturing has been prevalent for decades, with around 5% of the
rubber being used by the tyre industry being reclaim rubber. In the automotive and
mechanical sectors, reclaimed rubber is used to produce rubber gaskets, hoses, belts,
and mud flaps, especially for aftermarket components. The material also supports
the creation of outdoor furniture, garden accessories, and footwear soles, offering
an alternative to virgin materials in consumer goods. Reclaimed rubber, due to its
soft texture and good bonding properties, is also blended with natural and synthetic
rubber to reduce production costs of rubber sheets, conveyor belts, and tubes. It
plays a crucial role in non-tyre rubber goods, including insulation panels, vibration
dampers, and soundproofing materials.

Reclaim rubber sheet
8
Conveyor belt
9

Rubber pipe
10
Rubber shoe soles
11
8 Tinna. tinna.in/rubber-products
9 IndiaMart. indiamart.com/rubber-conveyor-belt
10 Hongyun Recycled Rubber. en.hsxjw.com/dingjizsjbaike_1897.html
11 Hongyun Recycled Rubber en.hsxjw.com/rujiaozsjbaike_1983.html

16Enhancing Circular Economy
of Waste Tyres in India
2.4 Extent of Pollution in the Tyre Recycling Industry
CPCB classifies industrial sectors into Red, Orange, Green, and White categories based on
a Pollution Index (PI) framework. The tyre recycling industry
3
is classified as a red/orange
category by CPCB as shown in Table 3:
Table 3: Categorisation of Different Tyre Recycling Industries
S. No.Recycling Processes CPCB Pollution Categorisation
1
Advanced Batch Automated Process (ABAP)/
Continuous Pyrolysis
Orange
2 Mechanical Crumbing Orange
3 Rubber reclaim/ Devulcanisation Red
(Source: CPCB)
3 A detailed breakdown of pollutants emitted by different recycling processes is provided in Annexure B.

17Enhancing Circular Economy
of Waste Tyres in India
3. Regulatory Landscape for Waste Tyres
3.1 Broad Policies Governing Waste Tyres Recycling
The regulatory framework governing the recycling and management of waste tyres in India
spans multiple ministries, with responsibilities distributed across environmental protection,
pollution control and trade regulation. Key policy instruments are summarised below:
3.1.1 MINISTRY OF ENVIRONMENT, FOREST AND CLIMATE CHANGE
(MOEFCC)
The MoEFCC is the nodal authority for waste management regulation, including waste
tyres, under the broader umbrella of hazardous waste. The governing framework for ELT
management is currently codified under the Hazardous and Other Wastes (Management
and Transboundary Movement) Amendment Rules, 2022, which was an amendment
(Schedule IX) to the Hazardous and Other Wastes (Management and Transboundary
Movement) Rules, 2016, providing a dedicated framework within them. The Hazardous and
Other Wastes Rules ban the import of waste tyres for direct reuse and permit import of
waste tyres strictly for recycling, subject to compliance with operational guidelines. Further,
they cover the general principles of environmentally sound management, authorisation
for recyclers, proper handling, storage, and movement (including transboundary
movement). The Amendment notified in 2022 specifically introduces Extended Producer
Responsibility (EPR) for waste tyres, mandating producers to ensure environmentally
sound recycling of ELTs and prohibit the import of waste tyres for pyrolysis.
Earlier, the MoEFCC had issued an Office Memorandum (OM) dated 24 Nov 2015, to lay
down operational protocols for the import of waste tyres for recycling under special
permits and for procedural guidance to establish and operate tyre pyrolysis units.
3.1.2 CENTRAL POLLUTION CONTROL BOARD (CPCB)
In 2024, CPCB issued the Standard Operating Procedure (SOP) for the Recycling
of Waste Tyre Scrap for the Recovery of Tyre Pyrolysis Oil, Pyro Gas, and Char in
Tyre Pyrolysis Oil (TPO) Units. The SOP prescribes environmental safeguards and
infrastructure requirements for setting up and operating Advanced Batch Automated
Pyrolysis (ABAP) and Continuous Pyrolysis facilities. It aims to standardise operational
practices, improve environmental performance, and ensure regulatory compliance
across the sector, in accordance with National Green Tribunal (NGT) directives and in
consultation with NEERI (National Environment Engineering Research Institute) and IIT
Delhi. The SOP establishes differentiated guidelines for ABAP and continuous pyrolysis
units with the objective of minimizing environmental and safety risks associated with
the recycling of waste tyre scrap. It outlines criteria for plant sites, plant capacity,
pollution control infrastructure, and mandates stringent operational protocols.
The SOP prioritises compliance with emission, effluent, and hazardous waste standards
under the Hazardous Waste Rules, 2016, and promotes co-processing of char or its

18Enhancing Circular Economy
of Waste Tyres in India
upgrade to recovered carbon black (rCB). It prohibits the import of waste tyres for
pyrolysis, requiring the exclusive use of domestically generated ELTs. Furthermore, it
mandates units to register on the CPCB EPR portal, maintain detailed records of input
and output, submit annual reports, and adopt occupational health and safety practices.
3.1.3 DIRECTORATE GENERAL OF FOREIGN TRADE (DGFT)
The DGFT governs the import of waste tyres through the Notification on Restricted Items
for Imports (2019). Under this regulation, waste tyres are classified as ‘Import Restricted’
items and may be imported only against a valid permit. However, import of used rubber
tyres with one cut in the bead wire and used rubber tubes cut in two pieces are permitted.
3.2 Extended Producer Responsibility (EPR) for Waste Tyres
The primary policy governing recycling of waste tyres in the country is the Extended Producer
Responsibility (EPR) framework, notified as the Hazardous and Other Wastes (Management
and Transboundary Movement) Amendment Rules, 2022. It is designed to ensure sustainable
recycling and environmental responsibility. Under this framework, tyre manufacturers and
importers are mandated to manage the recycling of end-of-life tyres in proportion to their
production or imports from previous years. Waste tyres, as covered by the EPR, “means
any tyre, including tubes and flaps that is no longer mounted on a vehicle and is no longer
used for its intended purpose”. The norms for EPR obligations, for tyre producers, new tyre
importers, waste tyre importers and for the retreading of tyres are given in Table 4 and the
relative performance of the EPR over three years is given in Box 3.1.
Table 4: Details of EPR Obligation for Different Stakeholders
Compliance Period EPR Obligation
Producers and Tyre Importers
2024 – 2025 (Year Y) onwards
(for established units)
EPR obligation shall be 100% of new tyres manufactured or
imported in year (Y-2).
Production Units established
after 01 Apr 2022
EPR obligation shall start after 2 years (Y) and shall be 100%
of new tyres manufactured or imported in year (Y-2)
A wear and tear discount factor (currently, 20%) is applicable on total EPR obligation
Waste Tyre Importer
Since enforcement of EPR
EPR obligation in year (Y) shall be 100% of the tyre imported
in year (Y-1)
Note: Import of waste tyre for purpose of producing pyrolysis oil or char is prohibited (mentioned in EPR)
Tyre Retreading
Since enforcement of EPR
Retreading certificates defer EPR obligation by one year for
corresponding quantity of waste tyres generated
(Source: MoEFCC)

19Enhancing Circular Economy
of Waste Tyres in India
In the Waste Tyres EPR, the amount of EPR certificates generated is calculated according to
a formula which considers the end product from processing Waste Tyres. Different recycling
methods and products have been assigned weightage factors (determined by MoEFCC),
along with a conversion factor
4
(determined by CPCB). The weightages are assigned based
on the properties and reusability of the material recovered, and the conversion factor is
assigned based on the number of units of waste tyre required to produce one unit of recycled
product. The respective weights and factors for different products are listed in Table 7, and
the EPR formula is discussed in Box 3.2 along with an illustrative example.
Box 3.1 A Snapshot of Current EPR Scenario
The implementation of Waste Tyres EPR has been supported by the establishment
of a centralised digital registration system on the CPCB portal. Table 5 presents the
status of registration of different stakeholders in the country so far.
Table 5: Stakeholder Registration Data on CPCB Portal (As on 1 Sep 2025)
Category Applications Received EPR Registration Granted
Manufacturer and Importer of
New Tyre
117 84
Importer of Waste Tyre 194 164
Recycler 711 552
Retreader 11 1
To assess progress under the EPR regime, data on certificate generation and trading is
monitored through the CPCB portal. Table 6 provides a snapshot of cumulative waste
tyre processing outcomes under EPR from its inception in 2022 till date (data taken
from the CPCB portal as on 1 Sep 2025).
Table 6: Waste Tyre Processing Data on CPCB Portal (As on 1 Sep 2025)
Parameter Category Quantum (MMT)
EPR Obligation

(Cumulative [2022-2025])
Total (across all producer
classifications)
6.20
EPR Certificates Generated

(Cumulative [2022-2025])
For Domestic Tyre 6.64
For Imported Tyre 2.56
EPR Certificates Traded/
Transferred

(Cumulative [2022-2025])
For Domestic Tyre 4.67
For Imported Tyre 1.64
4 A discussion on the derivation of the conversion factors by CPCB is given in Annexure C

20Enhancing Circular Economy
of Waste Tyres in India
Table 7: EPR Weightage and Conversion Factors
Recycled Product EPR Weightage (W
P
)
Conversion Factor
(C
F
)
Reclaimed Rubber 1.3 1.298
Recovered Carbon Black usable as raw material
for manufacture of new tyre
1.25 3.676
Crumb rubber Modified Bitumen (CRMB) 1.1 0.2
Crumb rubber 1 1.333
Pyrolysis oil and char (usable as fuel only and not as raw material for manufacture of new tyre)
Extracted from continuous pyrolysis method 0.8 1.49
Extracted from batch pyrolysis method 0.5 1.49
(Source: CPCB)

21Enhancing Circular Economy
of Waste Tyres in India
Box 3.2 EPR Formula for Waste Tyres
The quantity of EPR certificates generated is calculated using the formula:
Q
EPR
= Q
P
x C
F
x W
P
Q
P
= Quantity of recycled product
C
F
= Conversion factor - units of waste tyre to produce 1 unit of recycled product
W
P
= EPR Weightage - weightage allotted to recycled product
C
F
is determined by CPCB, whereas W
P
determined by MoEFCC
For example,
If 10 tons of reclaimed rubber is produced, then the quantum of EPR certificates
generated for the same is calculated as follows:
Quantity of recycled product Q
P
= 10 metric tonnes (mt)
The EPR weightage (W
P
) of reclaimed rubber = 1.30
The Conversion Factor (C
F
) of reclaimed rubber = 1.298
Corresponding quantity of EPR certificates generated:
Q
EPR
= Q
P
x C
F
x W
P
Q
EPR
= 10 x 1.298 x 1.30
Q
EPR
= 16.874 mt

22Enhancing Circular Economy
of Waste Tyres in India
Enhancing Waste
Tyres Recycling
1. Improving Waste Tyres EPR
Framework
2. Integrating Informal Sector in ELT
Recycling
3. Strengthening Standards for
Valorisation of Recycled Products

23Enhancing Circular Economy
of Waste Tyres in India
4. An Analysis of EPR
4.1 Understanding the EPR Multiplier Factors
As outlined in Section 3.1 and illustrated in Box 3.2, the EPR framework for waste tyres
uses weightage factors to reflect circularity potential and conversion factors to account for
variations between tyres processed and recycled output, together determining the total EPR
multiplier factor as shown in the Table 8.
Table 8: EPR Multiplier calculated based on Weightage and Conversion Factor
Recycled Product EPR Weightage (WP) Conversion Factor (CF)EPR multiplier (WP* CF)
Reclaimed Rubber 1.3 1.298 1.69
Recovered Carbon Black
usable as raw material for
manufacture of new tyre
1.25 3.676 4.59
Crumb rubber Modified
Bitumen (CRMB)
1.1 0.2 0.22
Crumb rubber 1 1.333 1.33
Pyrolysis oil and char (usable as fuel only and not as raw material for manufacture of new tyre)
Extracted from continuous
pyrolysis method
0.8 1.49 1.19
Extracted from batch
pyrolysis method
0.5 1.49 0.74
(Source: CPCB)
For example, products such as CRMB have a reasonably high weightage (1.1), but given its
conversion factor
5
(0.2), is assigned the lowest multiplier value (0.22). Similarly, while it may
be the intention of the EPR weights to penalise the low circularity of products obtained
from pyrolysis (0.8/0.5), the conversion factor (1.49) ensures a more favourable outcome
(1.19/0.74) according to the overall EPR multiplier. This may lead to suboptimal compliance
incentives and may not fully capture the true environmental and resource recovery potential
of each pathway. The current mismatch between recycled product weight and the EPR credits
assigned can obscure the actual progress towards meeting mandated obligations, thereby
constraining the overall efficiency and transparency of the EPR framework.
Finally, the EPR weightage is assigned as a characteristic of recycled product (as in the case of
rCB, reclaim, crumb), a process (separate weight for pyrolysis products) as well as a specific
application (CRMB). This approach to use product, processes and application as a basis of
assigning conversion factor brings in an inconsistency in generation of EPR, where the initial
objective was to ensure a certain obligated weight of tyres are available for recycling.
5 The calculation of the conversion factor is discussed in further detail in Annexure C.

24Enhancing Circular Economy
of Waste Tyres in India
4.2 The EPR’s Position on Tyre Pyrolysis
The foregoing analysis underscores a key observation—that waste tyre pyrolysis has been
subjected to comparatively more stringent treatment under the EPR framework than other
recycling processes. An international comparison of pyrolysis regulations (Table 9) shows
that while India’s standards for tyre pyrolysis are broadly aligned with global benchmarks,
the industry’s enhancement is constrained by restrictive provisions—notably the prohibition
on processing imported ELTs. This ban also is counterintuitive to the push given to rCB with
its high weightage in the EPR as explained in Box 4.1 as rCB cannot be produced without
pyrolysis as an intermediate process.
Table 9: Tyre Pyrolysis Regulation - Global Comparison
Region
Predominant
Technology
Legality of Pyrolysis Key Regulatory Features
Europe
Continuous
Pyrolysis
Permitted under stringent
conditions
EPR, free market, government –
models across members Stringent
emission regulations and product
testing
USA
Mixed
(Batch &
Continuous)
Permitted with strict EPA
oversight
Stringent emission standards;
Dynamic regulatory environment
China
Batch
Pyrolysis
Domestic processing
permitted;
Import of ELT banned
Strict domestic waste management
laws
Comprehensive waste import ban
India
Batch
Pyrolysis
Advanced Batch permitted with
strict norms;
Processing of imports banned
SOP for Tyre Pyrolysis;
EPR obligations;
Import restrictions
Furthermore, India has instituted an SOP for ensuring environmental compliance in tyre
pyrolysis units—a framework not yet adopted by several leading nations adopting pyrolysis
as a mode of tyre waste management. This approach enables batch pyrolysis units to achieve
environmental compliance through technological upgradation to the Advanced Batch
Automated Pyrolysis (ABAP). The expansion of batch pyrolysis in India emphasises the need
for enhancing regulatory checks and promoting safe and environmentally friendly operations.
Globally comparable regulations already exist and would serve to effectively curtail
enviromentally harmful practices when applied to tyre pyrolysis units in the country.

25Enhancing Circular Economy
of Waste Tyres in India
India does not have specific emission standards for pyrolysis plants. However, a comparative
analysis has been carried out using European Union’s Industrial Emissions Directive (IED)
stack emission standards for waste incineration plants (which is the category European tyre
pyrolysis plants are evaluated under). A comparable Indian standard would be the waste
incineration stack emission standards for Online Continuous Effluent and Emission Monitoring
System (OCEMS) for waste incineration industries (pyrolysis has not been classified as an
OCEMS-mandated industry by CPCB as of now) (Table 11). The analysis shows that India’s
guidelines for pollutants such as total dust, SO
2
, NO
x
, and CO are broadly aligned with EU
norms.
Box 4.1 Implication of Import Ban on ELT for Pyrolysis
India’s regulatory framework currently prohibits the import of waste tyres for pyrolysis,
while permitting imports for other recycling processes such as devulcanisation and
crumbing. This stems primarily due to concerns about illegal on-road use of the
imported waste tyres. This policy however, alongside addressing this concern, also
creates a regulatory complexity pertaining to promoting rCB as a priority circular
product under the EPR. rCB is derived from the carbon char produced during the
pyrolysis of waste tyres—and the quality of rCB is dependent on the pyrolysis
feedstock. High-quality rCB is mostly derived from imported feedstock. Restricting
access to imported tyres for pyrolysis undermines the upstream value chain required
for producing high-quality rCB.
This poses challenges to optimising EPR policy outcomes and constrains the growth
potential of domestic rCB manufacturing, which depends on a reliable and scalable
supply of carbon char. Aligning policy provisions to ensure a consistent, high-quality
feedstock supply would strengthen the rCB value chain, reduce reliance on virgin
carbon black, and further the objectives of circularity in tyre manufacturing.
Table 10: Import Permissible based on Recycling Process
S.No. Recycling Process/ Product
Whether Import of Waste
Tyres Permitted
1 Reclaim rubber (Devulcanisation) Yes
2 Recovered Carbon Black [rCB] Ambiguous
3 Crumb Rubber (Mechanical Breakdown) Yes
4 Pyrolysis (Batch and Pyrolysis) No

26Enhancing Circular Economy
of Waste Tyres in India
Table 11: Emission Standards Comparison
Pollutant EU IED (mg/Nm
3
) Indian Guidelines for CEMS
Total dust 30 50
Gaseous and vaporous organic
substances, expressed as Total Organic
Carbon (TOC)
20 20
Hydrogen chloride (HCl) 60 50
Hydrogen fluoride (HF) 4 4
Sulphur dioxide (SO
2
) 200 200
Nitrogen monoxide (NO) + nitrogen
dioxide (NO
2
), expressed as NO
2
400 400
Carbon monoxide (CO) 100 100
(Source: EU IED and OCEMS Guidelines, CPCB)
Globally, pyrolysis is classified as a form of waste incineration, and policy formulation is
usually with this understanding. Developing emission norms tailored specifically to tyre
pyrolysis—accounting for the products recovered from the process and its distinct thermal
characteristics—will be important to ensure that environmental safeguards are upheld while
enabling tyre pyrolysis to contribute effectively to circular economy objectives.

27Enhancing Circular Economy
of Waste Tyres in India
Box 4.2 Plasma Pyrolysis
Plasma pyrolysis* is an advanced thermal treatment process that uses plasma—a
highly ionized gas with extremely high temperatures—to break down waste materials
into their basic components. This process is particularly effective for tyre recycling.
It is currently the Best Available Technology (BAT) for waste tyre pyrolysis globally.
Figure 10: Plasma Pyrolysis Schematic Diagram
(Source: Institute for Plasma Research, India)
While Plasma Pyrolysis is currently operational mainly in Singapore and Italy, it has a
high capital cost, energy intensity, and advanced machinery requirement, which has
rendered it commercially unviable at scale in countries as large as India. In addition
to the high initial investment, the process demands a consistent supply of high-grade
electricity and specialised technical expertise for operation and maintenance, further
increasing operational costs. The absence of established domestic manufacturing
capabilities for plasma pyrolysis equipment also contributes to dependence on
imported machinery, raising procurement lead times and costs. Consequently, despite
its potential for near-complete conversion of waste into energy with minimal emissions,
its uptake remains limited, with conventional pyrolysis or crumbing methods being
favoured due to their lower entry barriers and established market linkages.
* Source: Plasma Pyrolysis Technology Explained: Revolutionizing Tyre Recycling, Global Enviro

28Enhancing Circular Economy
of Waste Tyres in India
4.3 Key Challenges and Proposed Solutions
4.3.1 EPR WEIGHTAGE SYSTEM RATIONALISATION
The current EPR framework for waste tyres relies on a product-based weightage
system to determine how certificates are generated, as outlined in Section 4.1. Under
this approach, different recycled outputs—such as crumb rubber, reclaim rubber,
pyrolysis oil, or recovered carbon black—are assigned varying weights, which reflect
their presumed contribution to material recovery and circularity. However, the system
does not incorporate uniform conversion factors to link the quantity of tyres processed
with the volume of recycled product generated. It also does not adopt input-based
mass balance accounting, which would provide a clearer picture of how much waste
is actually being processed, or environmental performance criteria that distinguish
cleaner, more circular processes from less sustainable ones.
In the absence of such mechanisms, there is a risk of inconsistency in the issuance
of certificates, which in turn undermines transparency and investor confidence,
particularly in advanced recycling technologies such as devulcanisation and continuous
pyrolysis. To address these challenges, it is suggested that the framework should
have a more comprehensive, input based system—where the actual amount of waste
tyres fed into recycling is the primary basis for generating certificates. Standardised
conversion factors would then be applied to ensure adequacy and consistency of
certificates, while transparent mass-flow verification would strengthen accountability
and resource efficiency. The mix of recycled products chosen to be generated by
the recyclers would be based on the market, as long as the recyclers follow strictly
the guidelines issued by CPCB for environmental norms. Such a system would also
better align incentives with environmental performance, thereby encouraging industry
participation and supporting the transition towards a circular economy.
Key Action Points:
1. Refining the EPR Generation Formula
A new formula for EPR certificate generation with a transparent mechanism, based
not on the weightage of specific recycled products but on the total quantum of waste
tyres processed is proposed as follows :-
EPR
Q
= Q
p
x C
f
; where
EPR
Q
is the quantity of EPR certificate generated
Q
p
is the weight of ELT processed
C
f
is the common conversion factor
The purpose of the conversion factor is to ensure sufficient availability of EPR
certificates.
The above formula ensures that the quantum of EPR certificates will not depend on process
(Batch/continuous pyrolysis), intermediates (crumb rubber, rCB) or product (CRMB).

29Enhancing Circular Economy
of Waste Tyres in India
2. Mass Flow Verification by CPCB
CPCB may standardise verification of materials produced from waste tyre processing
through standardised mass-flow mapping across collection, processing, and output
streams. This will enable uniform tracking, reduce inconsistencies in reporting, and
strengthen overall regulatory oversight.
3. Market-Based Product Mix Determination
Product mix should be a function of the market, while following CPCB emission
norms. A capacity and investment-based approval framework for projects may be
adopted, ensuring that only projects with adequate scale, financial commitment,
and land availability are permitted. A suitable model can be drawn from the recently
established framework in the state of Gujarat, which mandates a minimum continuous
pyrolysis plant capacity of 60 tonnes per day.
4. Re-evaluating Emission Regulations for the Tyre Recycling Industry
CPCB may re-evaluate and categorise the reclaim rubber industry as an “orange”
industry instead of its current “Red” industry status, considering its circularity
potential.
4.3.2 REFINING REGULATION FOR TYRE PYROLYSIS
Key Action Points:
1. Emission Monitoring for Pyrolysis Units
CPCB may propose that the tyre pyrolysis industry be mandated to install Online
Continuous Emission Monitoring Systems (OCEMS).
2. Review of Import Restrictions
MoEFCC may reconsider the prohibition on importing ELTs for pyrolysis and review
the current ban, as the EPR framework emphasises rCB as a priority circular product.
3. Use of Imported Feedstock Products
CPCB may notify that TPO from imported ELT feedstock be used only in refineries or
select industries, and carbon char be refined into rCB, depending on infrastructure
or in a few select industries.

30Enhancing Circular Economy
of Waste Tyres in India
5. Informality and Traceability in ELT Processing
5.1 Production-Recycling Gap Due to Leakage to Informal Sector
Figure 11: Gap between Production and Recycling (all values in MMT)
A persistent structural challenge in India’s tyre recycling ecosystem is the pronounced
mismatch between domestic tyre production volumes and the quantities processed through
formal recycling channels, a gap attributable largely to leakages to the informal sector. Under
the provisions of the EPR framework, annual recycling obligations are calculated based on
tyre production from two years prior. For example, the recycling target for 2024 is derived
from the 2.4 million metric tonnes (MMT) of tyres manufactured domestically in 2022
(including inner tubes and flaps). Yet, in 2024, only 1.6 MMT of domestic waste tyres had been
processed in facilities operating under formal authorisation, leaving an unaccounted volume
of 0.8 MMT—equivalent to roughly 33% of total production. Even with the wear factor of 22%,
it still leaves close to 0.27 MMT of tyres unaccounted for, a significant amount considering
ELTs are a material-rich resource.
This discrepancy indicates that a considerable proportion of ELTs are being channelled into
informal or unregistered units that operate outside the ambit of regulatory oversight. Such
facilities often lack adequate environmental safeguards, emissions control technologies,
and occupational safety measures, resulting in heightened environmental and health risks.
Addressing this challenge will require enforcing mandatory registration of all processing
units and incentivising the transition of informal operators into the regulated sector.

31Enhancing Circular Economy
of Waste Tyres in India
5.2 Estimate of Unauthorised Recyclers
Figure 12: Authorised and Estimated Unauthorised Recyclers
(per CPCB data as on 01.09.2025)
Figure 12 highlights a considerable degree of informality within India’s tyre recycling sector.
Out of an estimated 851 total recyclers, 552 are authorized, with 159 recyclers pending
authorization, and around 140 identified as informal operators—constituting nearly 20% of the
recyclers . These informal recyclers account for an estimated 0.42 MMT of recycling capacity.
The two above categories combined give approximately 300 unauthorised recyclers, and the
total unauthorized capacity rises to about 0.90 MMT, revealing a significant portion of the
recycling landscape that operates outside regulatory oversight. Informal players often rely on
low-cost, non-compliant batch pyrolysis units that lack proper environmental safeguards. To
address this, there is a pressing need to identify, formalize, and integrate these recyclers into
the regulated ecosystem. Doing so would not only enhance environmental compliance and
safety but also minimize resource leakage and maximise the recovery of valuable materials,
thereby reinforcing the tyre sector’s transition towards a circular economy.
5.3 Key Challenges and Proposed Solutions
5.3.1 OPERATION OF UNAUTHORISED FACILITIES LEADING TO
COMPLIANCE CONCERNS
Despite steady growth in domestic tyre production, formal recycling figures continue to
reflect a sizeable shortfall. The unaccounted tyres are often disposed of in uncontrolled
environments, repurposed in low-value applications, or diverted to informal recycling
units.
Operational unauthorised tyre recycling facilities contribute to localised pollution,
pose fire and accident hazards, and undermine the competitive viability of compliant
facilities.

32Enhancing Circular Economy
of Waste Tyres in India
Key Action Points:
1) CPCB
i. May undertake an exercise to ensure informal recyclers in the ELT recycling
value chain are integrated into the EPR ecosystem within one year to ensure that
quantum of ELT processed is accurately recorded.
ii. All recyclers under EPR may be subject to checklist-specific audit for meeting
compliance requirements.
2) SPCBs
i. May identify and integrate unauthorised recyclers into the EPR ecosystem given
a fixed deadline.
ii. Udyam Assist Platform of Ministry of Micro, Small & Medium Enterprises
(MoMSME) may be utilised to help in onboarding of unauthorised recyclers.
iii. MoMSME’s MSE-SPICE
6
scheme may find application in providing financial
support to upgrade infrastructure in non-compliant tyre pyrolysis units.
3) State Governments
i. An incentive scheme may be designed by MoEFCC in conjunction with State
Governments to support the transition process. It may be done in conjunction
with registered entities on the Waste Tyres EPR portal.
ii. May provide a one-time waiver of outstanding environmental liabilities, thereby
enabling informal tyre recyclers to overcome initial financial and regulatory entry
barriers.
5.3.2 GST COMPLEXITY UNDERMINING WASTE TYRE FORMALISATION
Recycled products derived from ELTs are presently subjected to an 18% GST rate. The high
taxation structure places an undue burden on products that are vital to the ELT recycling
value chain, inadvertently reinforcing the persistence of informal practices. Rationalising and
revising these rates downwards would help streamline value chain operations, incentivise
formal sector participation, and foster greater alignment with national priorities of ease of
doing business and advancing circular economy objectives.
Key Action Points:
MoEFCC with representation from Ministry of Finance (MoF) may constitute a committee
to review GST rationalisation for ELTs and recycled products. It has been highlighted by
formal recyclers that reduction of GST from 18% to 5% on the waste streams will drastically
increase the informal-to-formal transition process. A uniform rate across all such similar
waste streams will reduce compliance burden and lower transaction costs.
6 Micro & Small Enterprises Scheme for Promotion and Investment in Circular Economy (2024) – One of the eligible
circular economy actors being rubber waste recycling plants.

33Enhancing Circular Economy
of Waste Tyres in India
5.3.3 DEDICATED HSN CODE FOR TYRE RECYCLING SECTOR
To further enhance the circularity in tyres, the ambiguity in HSN codes for waste tyres
and their recycled products may be removed to address issues of their classification
and accounting. Currently, crumb rubber and waste tyres are grouped under a common
HSN, which creates multiple challenges:
i. Import policy gaps, as differentiation between processed products and input
material is not possible. As a result, processed materials may be treated on par with
raw ELTs, which not only discourages transparency but also weakens monitoring
of recycling flows.
ii. Lack of incentive for formalization since value-added products like Crumb Rubber
are not distinctly recognized. It is often grouped together with other recycled
products or even raw ELTs. This limits its competitiveness and discourages
investment in formal recycling facilities. The absence of distinct classification
of value-added products from ELT undermines their potential role in import
substitution, industrial applications, and circular economy pathways.
Key Action Points:
MoF may introduce separate 6-digit HSN codes for crumb rubber and waste tyres
to help distinguish between the two. Similarly, a separate HSN code for Micronized
Rubber Powder (MRP) may also be created. Introducing distinct HSN codes will help
address the above mentioned challenges. With separate codes, regulatory authorities
will be able to track imports and domestic transactions with greater precision,
ensuring that only legitimate recycled products enter industrial supply chains. This
will also improve the traceability of recycled products, reduce the scope for informal
practices, and provide a stronger basis for targeted fiscal and trade incentives.

34Enhancing Circular Economy
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6. Recycled Material Standardisation
6.1 Constraints for High-Value Export Products
The absence of a clearly defined standards framework for Tyre Pyrolysis Oil (TPO) and
Recovered Carbon Black (rCB) continues to constrain the growth of India’s high-value tyre
recycling ecosystem. Currently, TPO lacks classification as a certified fuel under Bureau
of Indian Standards (BIS) or Ministry of Petroleum and Natural Gas (MoPNG) guidelines
7
,
despite its increasing use as a biogenic alternative to furnace oil or light diesel oil (LDO) in
several industrial applications. Notably, international interest in TPO is growing, with global
firms such as BASF (USA) (largest buyers of TPO from India) and H&R Group (Germany)
actively sourcing TPO as a low-emission feedstock. Without clear standards for fuel quality,
composition, and permissible contaminants, India risks losing valuable export opportunities
and forfeiting a leadership position in emerging green fuel markets.
Similarly, the lack of regulatory clarity regarding import permissions and performance-based
standards for rCB has led to underinvestment in scalable infrastructure. In the absence of
defined parameters for product quality, application grades, or acceptable contamination
levels, private sector actors face difficulty in securing financing and ensuring market uptake.
This regulatory vacuum also hinders the development of a domestic market for high-quality
rCB, which holds pivotal substitution potential for virgin carbon black in tyre and non-tyre
industrial applications. Establishing comprehensive standards for both TPO and rCB is
therefore critical not only to unlock export potential but also to reduce import dependence,
enhance investment viability, and strengthen India’s position in global circular economy
supply chains.
6.2 Substitution Savings of Different Tyre Recycled Products
Tyre recycling offers major potential for import substitution savings across various products
derived from waste tyres. These substitutes not only reduce dependency on imported
industrial inputs but also support domestic manufacturing competitiveness. However, the
uptake of these materials remains limited, and their import substitution potential remains
largely unrealised. As a result, despite the availability of functional substitutes, industries
continue to rely heavily on imported inputs. Table 12 outlines the key substitution pathways
and the corresponding economic savings potential arising from the use of rCB, TPO, and
reclaim rubber. This data underscores the strategic importance of scaling up the use of
recycled tyre products for economic and resource efficiency.
7 Recently, the Customs Authority for Advance Rulings (CAAR) in Mumbai classified TPO as industrial liquid fuel oil
under HS heading 27101990, distinguishing it from standard petroleum oils or biodiesel. This indicates a recognition
of TPO as a distinct fuel under the other petroleum oils (OPO) category

35Enhancing Circular Economy
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Table 12: Potential Savings from Import Substitution by Recycled Products
Product
Recovered
Carbon Black
Tyre Pyrolysis Oil Reclaim Rubber
Substituting
Virgin Carbon
Black (largely
imported)
Other Petroleum Oils;
Residual Fuel Oil; Light Diesel
Oil
Natural Rubber; Synthetic
Rubber
(largely imported)
Savings
(Import
Substitution)
~INR 425 Cr.
Other Petroleum Oils: ~INR
1,471 Cr.
Residual Fuel Oil: ~INR 10 Cr.
Light Diesel Oil: ~INR 39 Cr.
Natural Rubber: ~INR
2,565 Cr.
Synthetic Rubber: ~INR
3,186 Cr.
Aggregate Potential Savings from Substitution: ~ approx. INR 7,700 Cr.
Domestic substitution - similar savings as imports due to comparable prices and volumes
(Source: Recycling Industry figures and EXIM Data Bank, DGFT)
6.3 Key Challenges and Proposed Solutions
6.3.1 PRODUCTION STANDARDS FOR TPO AND RCB
Without formal specifications under regulatory frameworks, producers face difficulties
in achieving market acceptance, securing finance, and meeting compliance requirements
for high-value industrial applications. This regulatory vacuum discourages investment in
advanced processing technologies and prevents the sector from fully leveraging market
opportunities.
Key Action Points:
BIS may notify standards for TPO and rCB. BIS has previously notified standards for reclaim
rubber (IS 7490:2023) and standards for crumb rubber to be utilised in CRMB (IS 17079:2019).
6.3.2 OPPORTUNITY FOR EXPORT MARKET
Global demand for high-quality TPO is rising. In the absence of recognised national
standards, Indian producers are unable to tap into these export opportunities, resulting in a
loss of potential foreign exchange earnings and a missed opportunity to position India as a
competitive supplier in the global circular economy.
Key Action Points:
MoPNG may ensure uptake of TPO for value-added products based on standards notified by
BIS. The framework for this may be determined by the specifications
8
used in other countries
for uptake of TPO. To operationalise this, a fiscal mechanism could be instituted to address
the current tax disparity, wherein TPO falls within the ambit of GST while petroleum does
not. Aligning the tax treatment of TPO with conventional petroleum products, or providing
targeted GST offsets/credits for refineries procuring TPO, would create a level playing field
and incentivise its uptake.
8 Detailed specification is outlined in Annexure D.

36Enhancing Circular Economy
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6.3.3 RECYCLED PRODUCTS UTILISATION IN HIGH-VALUE APPLICATIONS
In the domestic market, recycled outputs are frequently diverted to low-value
applications rather than being used as substitutes for higher-value industrial products.
This is largely due to the low usage in premium segments, limited awareness of technical
equivalence, and absence of procurement in relevant industries. As a result, high-
quality recycled materials are underutilised in applications where they could deliver
greater economic and environmental benefits. India forgoes significant opportunities
to reduce imports of virgin carbon black, petroleum-based fuels, and rubber, natural
and synthetic.
Key Action Points:
DPIIT may prioritise the integration of recycled tyre products into automotive, rubber
goods, plastics, paints, inks, and energy substitution markets, where rCB, reclaim
rubber, and TPO can directly replace imported virgin inputs. To achieve this, DPIIT may
develop procurement guidelines for domestic industries, and encourage inclusion of
recycled content in select manufacturing value chains. Fiscal incentives or preferential
treatment for industries adopting recycled inputs could catalyse large-scale uptake.

37Enhancing Circular Economy
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7. Tyre Retreading
7.1 What is Retreading?
Tyre retreading is the process of refurbishing used tyres by replacing worn-out tread with new
rubber layers, thereby extending the functional lifespan of the original tyre casing. This process
reduces raw material consumption and environmental footprint compared to manufacturing
a new tyre, with each retreaded tyre resulting in consumption reduction of approximately 57
litres of oil, 44 kilograms of natural rubber, and 136 kilograms of CO
2
emissions when compared
to the production of a new tyre. Retreaded tyres can retain up to 50–70% of the original tyre’s
performance and durability, making them a cost-effective and resource-efficient alternative
in commercial and industrial transport applications. India currently retreads an estimated 10
million tyres annually, underscoring the critical role the sector plays in promoting resource
efficiency within the mobility ecosystem. The replacement-to-retreaded tyre demand ratio
stands at 62%, in commercial segments such as trucks and buses, highlighting considerable
dependence on retreaded tyres.
Figure 13: Tyre Retreading
(Source: Focus on the Circular Economy: Continental Celebrates more than 120 Years of
Retreading for Truck and Bus Tires: Continental AG)
Retreading
Process

38Enhancing Circular Economy
of Waste Tyres in India
7.2 Market Share in Retreading across Vehicle Segments
Table 13 presents an overview of the market share and potential cost savings for retreaded
tyres across key vehicle segments.
Table 13: Share of Tyre Retreading Market by Segment
Segment Share of total retreading market
Potential Savings on Retreaded Tyre
(in INR)
Trucks 65% 25,000
Bus 20% 15,000
Off-the-road (OTR) 12% 2,450
Passenger 3% 2,250
(Source: Review of relevant literature)
Retreading is widespread and offers substantial savings in the truck and bus segments, it is
much less impactful for the passenger and OTR segments. Thus, despite retreading guidelines
being notified by Ministry of Road Transport and Highways (MoRTH) in Automotive Industry
Standard (AIS) – 064 (Part 1 & 2) (2005), the combination of low awareness, safety concerns
and low savings means that it does not have the same acceptability and uptake in the
passenger vehicle segment.
7.3 Issues Pertaining to Retreading
Current regulations concerning retreading are limited to the standards for retreaded tyres
and a nominal provision enclosed in the EPR. According to data as of 01 Sep 2025 from
the CPCB Waste Tyres EPR portal; there have been only eleven applications received for
registering retreaders of which only one has been granted, and no record of retreading EPR
certificates being generated. The current EPR framework includes a provision for a one-
year deferment of EPR obligations as an incentive to promote tyre retreading. However,
this deferment does not offer adequate economic or operational benefits to industry
stakeholders to make retreading a financially attractive option. The EPR rules do not account
for the substantial environmental and economic benefits of retreading, nor do they promote
investment or formalisation of the sector. The sector remains largely unorganised, with
only around one-third of over 10,000 retreaders operating formally, further limiting quality
assurance despite the scale of operations. Moreover, there is a widespread lack of awareness
about the environmental and economic benefits of retreading, particularly in the passenger
vehicle segment where it is often overlooked. Strengthening policy support for retreading is
essential to unlock its full potential as a resource-efficient and low-emission solution within
the circular economy for tyres.

39Enhancing Circular Economy
of Waste Tyres in India
Key Action Points:
Retreading has been found to be practical exclusively in the truck and bus segment.
The following interventions are a few policy interventions that may be considered for
retreading by relevant government departments (MoRTH, MoEFCC, CPCB, SPCBs)
going forward:
1. Revisiting the EPR and doing away with the provision for retreading completely to
eliminate a layer of procedural complexity.
2. Work with stakeholders to establish retreader auditing and integrate retreaders
into a SPCB-regulated ecosystem.
3. Collaborative efforts by tyre OEMs and automotive workshops to enhance
retreading services.
4. Upgrade retreaded tyre marking system based on digital infrastructure for quality
assurance.
5. Increase awareness regarding retreading in the mainstream through public
awareness campaigns.

40Enhancing Circular Economy
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8. Conclusion – Summary of Recommendations
India’s waste tyre recycling ecosystem presents a unique opportunity to advance circular
economy objectives while addressing pressing environmental and industrial challenges. This
report has examined the sectoral landscape, mapped current material flows, and identified key
regulatory, infrastructural, and market gaps that hinder the full realisation of value from End-
of-Life Tyres (ELTs). Drawing on these insights, the following table outlines a comprehensive
set of policy recommendations designed to enhance resource efficiency, formalise operations,
and stimulate demand for high-quality recycled products across the value chain.
Table 14: Summary of Key Recommendations and Implementation Agency
Recommendations
Implementation
Agency
Improving Waste Tyres EPR system
1. Revise formula for EPR certificate generation with a transparent
mechanism.
2. Review ban on pyrolysis of imported ELT.
Timeline: Six months
MoEFCC
1. Determine common conversion factor to ensure availability of
sufficient EPR certificates in the market.
2. Standardise verification of materials produced from waste tyre
processing through standardised mass-flow mapping.
3. Consider changing pollution category of reclaim rubber industry
from red to orange.
4. Recommend a capacity- and investment-based approval
framework for pyrolysis units, ensuring that only projects with
adequate scale, financial commitment, and land availability are
permitted.
5. Propose tyre pyrolysis industry for online continuous emission
monitoring (OCEMS) mandate.
6. Notify that TPO made from imported ELT feedstock be used in
refineries or a few select industries.
7. Carbon char obtained from imported ELT feedstock may be
refined to only rCB, dependent on available infrastructure or a few
select industries.
Timeline: One year
CPCB

41Enhancing Circular Economy
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Recommendations
Implementation
Agency
Formalizing ELT Recycling
1. Undertake exercise to ensure all stakeholders pertinent to ELT
recycling value chain are integrated into EPR ecosystem within a
defined timeline.
2. Identify and integrate unauthorised recyclers into the EPR
ecosystem given a fixed deadline.
3. All recyclers under EPR may be subject to checklist-specific audit
for meeting compliance requirements.
Timeline: One year
SPCBs, CPCB
1. Udyam Assist Platform may be utilised to help in onboarding of
unauthorised recyclers.
2. MSE-SPICE scheme may find application in providing financial
support to upgrade infrastructure in non-compliant tyre pyrolysis
units.
Timeline: One year
MoMSME
1. A one-time waiver of outstanding environmental liabilities may be
provided to informal tyre recyclers to overcome initial financial and
regulatory entry barriers.
Timeline: One year
State governments
1. Constitute a committee to review GST rationalisation for waste
ELTs and recycled products to 5%.
Timeline: One year
MoEFCC, MoF
1. Introduce separate 6-digit HSN codes for crumb rubber and waste
tyres to help distinguish between the two. Similarly, a separate
HSN code for Micronized Rubber Powder (MRP) may also be
created.
Timeline: One year
MoF, DPIIT
Recycled Material Standardisation
1. Notify standards for TPO and rCB, similar to previously notified
standards for reclaim rubber (IS 7490:2023) and CRMB (IS
17079:2019).
Timeline: Eighteen months
BIS
1. Issue guidelines for uptake of TPO for value-added products based
on standards notified.
2. Framework to be determined by specifications by looking at global
best practices for uptake of TPO.
3. Align tax treatment of TPO with conventional petroleum products,
or provide targeted GST offsets/credits for refineries procuring
TPO to incentivise uptake.
Timeline: Two years
MoPNG, BIS

42Enhancing Circular Economy
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Recommendations
Implementation
Agency
1. Prioritise the integration of recycled tyre products into automotive,
rubber goods, plastics, paints, inks, and energy substitution
markets, where rCB, reclaim rubber, and TPO can directly replace
imported virgin inputs.
2. Develop procurement guidelines for domestic industries, and
encourage inclusion of recycled content in select manufacturing
value chains.
3. Devise fiscal incentives or preferential treatment for industries
adopting recycled inputs to catalyse large-scale uptake.
Timeline: Two years
DPIIT
Retreading
1. Revisit EPR and do away with the provision for retreading
completely.
Timeline: Six months
MoEFCC
1. Work with stakeholders to establish retreader auditing and
integrate retreaders into a SPCB-regulated ecosystem.
Timeline: Two years
CPCB, SPCBs
1. Take collaborative efforts with automotive workshops to enhance
retreading services.
Timeline: Two years
MoRTH, Retreaders
1. Upgrade retreaded tyre marking system based on digital
infrastructure for quality assurance.
2. Increase awareness regarding retreading in the mainstream
through public awareness campaigns.
Timeline: Two years
MoRTH, OEMs,
Retreaders

43Enhancing Circular Economy
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9. Annexure
A. Pollutants from Recycling Processes
The pollutants emitted by the different processes are listed subsequently:
9
Table A1: Pollutants Emitted by Different Tyre Recycling Processes
PollutantsBatch Pyrolysis (BP)
Advanced Batch /
Continuous Pyrolysis
Mechanical
Recycling /
Crumbing
Reclaim/
Devulcanisation
Gaseous
Pollutants
PM
SOx
NOx
CO
H
2
S
Dioxins
PM (lesser than BP)
SOx;
NOx;
CO
PM (during
process)
SOx;
NOx;
VOCs (Major
component)
Liquid
Pollutants
Tyre pyrolysis water
(pyro-water). A
mixture of water,
oil and carbon
particles.
Pyro-water
Key leachate
pollutants include
heavy metals (Zn,
Ni, Cr), and organic
compounds (PAHs)
Sulfur
compounds,
organic
contaminants,
heavy metals,
chemical
additives,
rubber industrial
wastewater
Notes
Pyro-water can be
highly polluting if
not treated properly.
This is less polluting
due to fully enclosed
structural design,
which prevents
leakage of waste
residues, and
advanced exhaust
gas treatment
systems designed to
purify emissions.
Risk of leachate
contamination from
the application
of crumb rubber
is a substantial
environmental
consideration.
Eco-friendliness
of devulcanisation
is highly
dependent on the
effectiveness of
its liquid waste
management
9 CO – Carbon monoxide; SOx – Sulphides; NOx – Nitrogen oxides; PM – Particulate matter; VOC – Volatile organic
compounds; PAH – Polycyclic aromatic hydrocarbons

44Enhancing Circular Economy
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B. Conversion Factor Calculation for EPR
Table B1: Conversion Factor Calculation (Source: CPCB)
Entities
Crumb
rubber
Reclaimed
Rubber
CRMB
Recovered
carbon
black
Pyrolysis oil
and Char
(Continuous)
Pyrolysis oil
and Char
(Batch)
Waste Tyre
(tonnes)
100 100 100 100 100 100
Recovered end
product (tonnes)
(Q
P)
75 77 500 27.2
Oil - 35
Char - 32
Oil - 35
Char - 32
Weightage (W
P)1 1.3 1.1 1.25 0.8 0.5
Equivalent
Certificate
(tonnes) (Q
EPR)
100 130 110 125 80 50
Conversion
Factor (C
F)
1.333 1.298 0.2 3.676 1.49 1.49
The Conversion Factor (CF) is meant to equate the quantum of waste tyres going in as input
to the amount of recycled product derived from it as output. As such, the formula for CF is
relatively straightforward:
C
F
= (Waste Tyre (tonnes))
Q
P

where Q
P
– Recovered end product (tonnes). The values were taken from industry stakeholder
consultation, as per the CPCB
In the case for CRMB, where 500 tonnes of product are produced relative to 100 tonnes of
waste tyre due to the low requirement of crumb rubber in the modifier for the bitumen mixture
(20-25% at most). Similarly, continuous and batch pyrolysis have the same conversion factor
and it is arrived at by addition of the Q
P
of both oil and char for the above formula, instead of
distinct products as is for the other categories.

45Enhancing Circular Economy
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C. International Specifications for Tyre Pyrolysis Oil (TPO)
10
Uptake
Analysis Method Unit MinPreferred Max Comment
Density 15°C- kg/m
3>
910
- -
Lower the
better
Flash point
DIN EN ISO
3679
°C > -10> 40 - -
50% Boiling
Point
DIN EN 15199 °C 250 > 340 - -
Nitrogen (N)ASTM D5291 mg/kg - < 5.000 6.500-
Sulphur - wt% - < 0.9 1.1 -
Halogens DIN EN 15408 mg/kg - < 20 30 -
Chloride (Cl)DIN EN 15408 mg/kg - - - -
Fluorine (F)DIN EN 15408 mg/kg - < 1 -
Under
investigation
Bromine (Br)DIN EN 15408 mg/kg - < 10 - -
Total Acid
Number
ASTM D 664
mg
KOH/g
- < 4 8 -
B(a)P
DIN EN 16143
(based on)
mg/kg - < 20 50 -
Water
content
DIN 51777-01
%(m/m)- - 0.5
No free
water
allowed
Particles Visually - - - none -
Solids ASTM D7579 wt% - - 0.2 -
Ash ASTM D482 wt%
< 0.01 < 0.05 -
Pour point
DIN EN ISO
3016
°C - - 0 -
Silicon (Si)DIN 51399-1 mg/kg - < 10 30 -
Zinc (Zn) DIN 51399-1 mg/kg - < 3 10 -
Aluminum
(Al)
DIN 51399-1 mg/kg - < 3 10 -
Iron (Fe) DIN 51399-1 mg/kg - < 3 10 -
Copper (Cu) DIN 51399-1 mg/kg - < 3 10 -
Other metalsDIN 51399-1 mg/kg - Each < 1
Each
< 3
-
Oxygen (O)
DIN 51732
mod.
%(m/m)- < 0.5 < 1 -
10 From purchase specification of TPO for H&R Group (Germany) (as on 19.03.2025)

46Enhancing Circular Economy
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NOTES