Extended Producer Responsibility (EPR) for Automobile Manufacturers in India

Introduction

The automobile industry in India is one of the largest globally, contributing significantly to the economy, employment, and innovation. However, this growth also comes with an environmental cost—vehicles and their components generate large volumes of plastic waste, batteries, e-waste, tyres, hazardous fluids, and eventually end-of-life vehicles (ELVs).

To address these challenges, India has adopted a comprehensive Extended Producer Responsibility (EPR) framework. Under this policy, manufacturers such as Toyota, Tata Motors, Mahindra, Honda, Hyundai, and Maruti Suzuki are accountable for the collection, recycling, and environmentally sound disposal of the waste generated from their vehicles and packaging.

EPR is no longer just compliance—it is central to building a circular economy where resources are reused, pollution is minimized, and sustainability becomes part of the core business model.

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a regulatory framework that makes producers—manufacturers, assemblers, and importers—responsible for managing products throughout their lifecycle, including post-consumer waste.

For automobile manufacturers, EPR spans across multiple waste categories:

• Plastic Waste – Packaging materials, dashboards, bumpers, trims, and other plastic parts.
• Batteries – Lead-acid, nickel-metal hydride, lithium-ion, hybrid, and EV batteries.
• E-Waste – Electronic components such as sensors, ECUs, infotainment systems, airbags, wiring harnesses.
• Tyres – End-of-life tyres from passenger vehicles, trucks, and buses.
• Hazardous Waste – Waste oils, brake fluids, asbestos parts, and filters.
• Ozone-Depleting Substances (ODS) – Refrigerants and coolants in air-conditioning systems.
• End-of-Life Vehicles (ELVs) – Collection, depollution, dismantling, recycling, and scrapping of unfit vehicles.

This holistic approach ensures that every component of a vehicle is managed responsibly.

EPR Rules Relevant to Automobile Manufacturers

1. Plastic Waste Management Rules, 2016

• Covers both vehicle components made of plastic and packaging waste.
• Producers must register with CPCB, set up collection systems, and send plastics to authorized recyclers.
• Annual recycling targets are notified by CPCB.

2. Batteries Waste Management Rules, 2022

• Applies to lead-acid, lithium-ion, and EV batteries.
• Manufacturers must ensure batteries are collected and sent to registered recyclers/refurbishers.
• Annual recycling/refurbishment targets are mandatory.

3. E-Waste Management Rules, 2022

• Applies to ECUs, sensors, infotainment units, airbags, wiring, and electronics.
• Producers must create take-back systems and ensure channelization to authorized e-waste recyclers.

4. Waste Tyre EPR Guidelines, 2022

• Requires producers to declare tyre sales and ensure recovery of end-of-life tyres.
• Recycling options include crumb rubber, pyrolysis oil, and alternative raw materials.

5. Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016

• Covers waste oils, brake fluids, asbestos, filters, and hazardous residues from vehicle servicing and dismantling.
• Producers must ensure safe disposal at authorized Treatment, Storage, and Disposal Facilities (TSDFs).

6. Solid Waste Management Rules, 2016

• Covers non-hazardous waste such as glass, foams, fabrics, and packaging generated during operations.

7. Ozone Depleting Substances (Regulation & Control) Rules, 2000

• Applies to air-conditioning refrigerants (HFCs, CFCs).
• Requires safe recovery and channelization through authorized facilities.

8. End-of-Life Vehicle (ELV) Rules, 2025

• Producers must:
  • Partner with or establish Registered Vehicle Scrapping Facilities (RVSFs).
  • Purchase EPR Certificates from RVSFs to meet annual scrapping obligations.
  • Publish collection points for old vehicles.
  • Run consumer awareness programs on safe vehicle scrapping.

Key Responsibilities for Automobile Manufacturers

1. Registration: All OEMs must register with CPCB under each relevant EPR framework (plastics, batteries, tyres, e-waste, ELVs).
2. Meeting Targets: Fulfil annual collection and recycling targets as per each rule.
3. Authorized Channelization: Send all waste only to authorized recyclers, refurbishers, or scrapping facilities.
4. EPR Certificates: Buy certificates generated by recyclers (tyres, plastics, ELVs) to prove compliance.
5. Annual Returns: File EPR returns on CPCB’s centralized portal (by June 30 each year for the previous financial year).
6. Awareness Programs: Educate customers on safe disposal, battery returns, tyre recycling, and scrapping processes.
7. Eco-Design: Integrate sustainability into vehicle design (as per AIS 129), making recycling easier and safer.

Benefits of EPR for Automobile Manufacturers

• Regulatory Compliance: Prevents fines, license suspensions, and reputational risks.
• Environmental Sustainability: Reduces landfill waste, pollution, and illegal disposal.
• Resource Efficiency: Recovers valuable materials—steel, aluminum, plastics, rubber—for reuse.
• Competitive Advantage: Brands like Toyota, Tata, and Mahindra can highlight their green credentials.
• Support for Circular Economy: Keeps resources circulating in the economy and lowers dependency on virgin raw materials.

Challenges for the Automobile Industry

• Nationwide Reverse Logistics: Creating collection centers and reverse logistics across all states.
• Informal Recycling Sector: Integrating small scrap dealers into a formal compliance network.
• High Compliance Costs: Batteries and e-waste recycling require significant investment.
• Consumer Awareness: Many vehicle owners are unaware of formal scrapping and recycling requirements.

Conclusion

Extended Producer Responsibility (EPR) for automobile manufacturers in India represents a paradigm shift in how vehicles and their components are managed. From plastics and batteries to tyres, e-waste, hazardous residues, and old vehicles, every waste stream now has a defined compliance mechanism under Indian law.

Leading automobile companies like Toyota, Tata Motors, Mahindra, Honda, Hyundai, and Maruti Suzuki must embed EPR compliance into their core business strategy. Doing so will not only ensure legal compliance but also enhance brand value, conserve resources, and position them as leaders in sustainability.

EPR is no longer just an environmental regulation—it is a business imperative for long-term competitiveness in India’s automobile sector.

References

• Ministry of Environment, Forest and Climate Change. End-of-Life Vehicle (Management) Rules, 2025
• CPCB. Guidelines for Environmentally Sound Facilities for Handling and Scrapping of ELVs, 2023
• Plastic Waste Management Rules, 2016 (MoEFCC)
• Batteries Waste Management Rules, 2022 (MoEFCC)
• E-Waste Management Rules, 2022 (MoEFCC)
• Waste Tyre EPR Guidelines, 2022 (MoEFCC)
• Hazardous Waste Management Rules, 2016 (MoEFCC)