India Is Tightening the Gate on Waste-Tyre Imports. EPR Compliance Now Decides How Much Can Move

India has not announced a blanket ban on waste-tyre imports. It has done something more operationally important.

In a decision uploaded on 14 October 2026, the Ministry of Environment, Forest and Climate Change recorded the outcome of its 159th Expert Committee meeting, held on 28 September. The committee recommended fresh import quantities in 23 cases involving old tyres, tubes and related rubber scrap.

The total was 288,219 metric tonnes.

Yet the headline quantity is not the real story. Of that total, 91,479 tonnes can move only after an additional EPR compliance check, a CPCB site inspection or verification against the applicable standard operating procedure. Two other applications were deferred without a fresh quantity recommendation.

This is not an import closure. It is a change in the quality of proof expected before imported feedstock reaches a plant. The Ministry's decision connects three records that businesses often manage separately: permission to import, evidence of physical recycling and fulfilment of EPR obligations.

For waste-tyre importers, that connection is decisive. Under India's rules, an importer of waste tyres is also a producer for EPR purposes. Its obligation in a given year equals 100% of the waste tyres it imported in the previous financial year.

An import recommendation therefore creates more than feedstock. It creates a future compliance liability.

The numbers at a glance

The import totals are Recykal Times calculations from the 159th meeting decision. "Recommended" does not mean that the material has already entered India. The certificate figure is a live FY 2026-27 portal snapshot and will change as certificates are generated, transferred, adjusted or extinguished.

The headline number contains two different decisions

The 288,219-tonne total looks like one large opening for imported scrap. It is not.

The decision effectively creates two groups. About 196,740 tonnes was recommended without an express later EPR or site-verification condition in the recorded decision. The remaining 91,479 tonnes was placed behind another compliance gate.

Two large cases show how this works.

In one, the committee recommended 61,493 tonnes. It said 25,000 tonnes could be granted, while the balance of 36,493 tonnes should follow only after the applicant's EPR compliance for the previous financial year is verified and CPCB reports satisfactory compliance.

In another, the committee recommended 42,876 tonnes in two equal parts. The first 21,438 tonnes could move ahead. The second 21,438 tonnes was tied to verification of the applicant's EPR compliance.

Several smaller recommendations followed a similar logic. Some were divided into an initial quantity and a later tranche. Some new or recently assessed units were given a full recommendation subject to a CPCB visit and verification of compliance with the waste-tyre recycling SOP.

The point is not that these businesses were found to have committed wrongdoing. The decision does not support that conclusion. The point is that declared capacity alone no longer settles how much imported material a unit can access.

The practical gate is becoming evidence-based and, in some cases, staged.

EPR has moved inside the import decision

India's waste-tyre EPR rules place tyre businesses on different compliance clocks.

For manufacturers and importers of new tyres, the post-FY 2024-25 obligation is generally 100% of new tyres manufactured or imported two years earlier. For a waste-tyre importer, the obligation is 100% of waste tyres imported one year earlier.

That shorter lag matters. A large waste-tyre import in FY 2026-27 feeds directly into the importer's FY 2027-28 obligation.

CPCB's FAQ requires a waste-tyre importer to hold registrations in both the producer and recycler roles. Where it owns more than one plant, every recycling site needs its own registration. This is a useful clue to the regulator's view of the business: the importer is not treated as a trader standing outside the recycling system. It is expected to account for both the material brought into India and the plant that converts it.

EPR fulfilment is also more than purchasing a number on a portal. Producers must buy certificates online from registered recyclers and file returns. The rules provide for producer and recycler data to be cross-checked. If the two sides report different figures, the lower figure is considered for fulfilment. Certificates are also subject to environmental audit.

That makes a certificate only one part of the defence. The underlying quantities, parties, products and returns must agree.

Recykal Times previously reported the filing extension for FY 2025-26 waste-tyre returns. That extension changed the reporting timetable. It did not dilute the obligation or the need for a verifiable transaction trail.

The Ministry is testing whether the whole plant record holds together

The 159th meeting decision reads less like a simple capacity-allocation exercise and more like a plant-level reconciliation.

Across the cases, the committee considered authorised capacity, actual production, waste-tyre procurement from domestic sources, electricity consumption, sales, GST-related records, earlier import permissions and the findings of CPCB visits. Fire-safety documents also mattered.

Each measure tests a different part of the same claim.

A plant may have consented capacity, but electricity and production records indicate whether it operated. Import documents show whether earlier permissions were used. Domestic procurement reveals how imported feedstock fits into total material consumption. Sales and GST records help test whether output left the plant through recorded commercial channels. EPR returns and certificate activity connect the physical operation to the regulatory portal.

The strongest file is therefore not the one with the largest capacity figure. It is the one in which every dataset describes the same operating plant.

The two deferred cases reinforce this point. In one, the recorded information showed nil production after the unit had fully used an earlier import permission, and the committee sought clarification. In another, the committee deferred the matter pending clarification connected to fire safety.

Neither deferral should be read as a final adverse finding. Both show why operational records and site controls can now determine access to imported material.

A large certificate balance is not a free pass

The live CPCB dashboard adds a second layer to the story.

On 16 October 2026, the FY 2026-27 imported-tyre stream showed 318,354.997 tonnes of certificates generated, 78,710.240 tonnes transferred and 239,644.757 tonnes available. On those figures, about 24.7% of generated imported-tyre certificates had been transferred. This percentage is our calculation.

It would be tempting to call the remaining balance an oversupply. The data do not prove that.

The dashboard is a moving snapshot, not an annual market settlement. Waste-tyre importer obligations arise with a one-year lag. A certificate generated in a given financial year remains valid until two years after that year closes. A certificate displayed as available can be transferred later, while new certificates can also enter the system.

The portal also displays domestic-tyre and imported-tyre certificate streams separately. The rules give imported waste tyres a weightage of one across end-product categories and provide an adjustment mechanism for certificates used by waste-tyre importers. Businesses should therefore not treat the total visible balance as a single pool with no category, timing or audit conditions.

More importantly, the Ministry's import decision shows that aggregate certificate availability does not replace applicant-level verification. A market can have certificates available and still require an individual importer to prove that its earlier obligations, plant operations and reported transactions reconcile.

The real constraint is not simply the national volume of certificates. It is the integrity of the evidence attached to the entity using them.

Import policy is also drawing a line between recycling routes

India's rules expressly prohibit the import of waste tyres for producing pyrolysis oil or char.

The cases in the latest decision are instead centred on material for products such as crumb rubber and reclaimed rubber. These routes can serve rubber goods, moulded products, road applications and other industrial uses, subject to product quality and buyer requirements.

This distinction is easy to miss because India's EPR framework recognises several recycling outputs, including pyrolysis products from domestic waste tyres. But recognition of an output under EPR does not mean imported waste tyres may be used to make it. The import prohibition for pyrolysis oil or char remains explicit.

For brands and procurement teams, the end product matters because certificate generation is linked to reported recycling output, conversion factors and sales information. A tonne entering a gate is not automatically a tonne of compliant EPR performance. The acceptable route, actual output and portal record all matter.

For brands, a tyre is becoming a chain of evidence

Tyre brands and vehicle manufacturers may not file the import application for a crumb-rubber plant, but they operate in the same EPR market.

They rely on registered recyclers for certificates. The rules allow the portal to compare what the producer reports with what the recycler reports, and use the lower number when the figures differ. A recycler's weak material trail can therefore become a producer's compliance problem even after a commercial certificate purchase has been agreed.

The latest import decision raises the standard of due diligence. A credible recycling counterparty should be able to show how its imported and domestic feedstock records are separated, how earlier import permissions were used, which registered unit processed the material, what end product was sold and how the certificate quantity was derived.

For importers, the same chain runs in the other direction. Permission to bring in waste tyres cannot be managed independently from future EPR demand. Each import tranche affects the next year's obligation, so certificate sourcing should be modelled before the material arrives, not after the return becomes due.

For recyclers seeking imported feedstock, utilisation is now a regulatory asset. A plant with orderly production, power, purchase, sales and portal records can demonstrate that more material will be processed in a controlled system. A plant that cannot reconcile those records may find that nominal capacity does not translate into import access.

What this means for you

Tyre and vehicle brands: Treat certificate procurement as verified recycling procurement. Confirm the recycler's registration, unit identity, output route and supporting transaction data before relying on certificates for fulfilment. The commercial contract should also address corrections if portal cross-checks reduce the eligible quantity.

Waste-tyre importers: Build one reconciliation covering the import permission, bill of entry, inward weight, plant consumption, output, sale and EPR certificate. Track the FY 2027-28 obligation created by FY 2026-27 imports while negotiating the feedstock, not at the end of the compliance year.

Crumb and reclaimed-rubber recyclers: Capacity is only the outer limit. The more persuasive operating record is throughput supported by electricity, procurement, production, sales, GST and portal data. Site readiness, fire controls and compliance with the applicable CPCB SOP now affect how quickly recommended quantities can move.

EPR and procurement teams: Keep imported and domestic waste-tyre records distinguishable. The dashboard's separate streams, the imported-tyre weightage rule and the applicant-level import conditions make broad, blended assumptions risky.

What to watch

1. The next published Expert Committee decision: Watch whether staged quantities and EPR-linked conditions become the standard treatment for larger waste-tyre applications.
2. CPCB verification of the conditional 91,479 tonnes: The public decision does not give one completion date. Later permissions and site findings will show how much of this quantity clears the second gate.
3. The imported-certificate stream through 31 March 2027: Track generation, transfers and the available balance together. One figure alone cannot show whether the market is tightening.
4. Application-level utilisation disclosure: A public link between quantity permitted, quantity imported, quantity processed and certificates generated would make the system easier to audit and harder to misread.
5. Any change to the pyrolysis restriction: No relaxation is contained in the 159th meeting decision. Waste-tyre imports for producing pyrolysis oil or char remain prohibited under the EPR rules.

The bottom line

India is still allowing waste-tyre imports for recognised recycling uses. What is changing is the gate.

The latest decision recommends 2.88 lakh tonnes of feedstock, but places almost one-third behind further verification. It also shows that an importer's past EPR performance, plant records and site controls can determine its next quantity.

The competitive advantage is no longer import access alone. It is the ability to prove, tonne by tonne, that imported scrap became a legitimate product and a defensible EPR record.