India’s vehicle scrapping framework has moved beyond simply sending old vehicles to an authorised scrapping facility. Vehicle manufacturers, assemblers, brand owners and importers now have direct Extended Producer Responsibility obligations for End-of-Life Vehicles.
Under the Environment Protection (End-of-Life Vehicles) Rules, 2025, vehicle producers are required to register with the Central Pollution Control Board, calculate their applicable EPR obligation, fulfil that obligation through EPR certificates generated by Registered Vehicle Scrapping Facilities and complete annual compliance through the centralised ELV EPR portal.
The Rules were notified on 6 January 2025 and came into force on 1 April 2025. They apply to producers, vehicle owners, bulk consumers, Registered Vehicle Scrapping Facilities, collection centres, automated testing stations and other entities involved in ELV management.
For a vehicle producer, however, registration is only the first step. The larger compliance exercise involves historical vehicle data, steel-weight calculations, producer classification, certificate procurement, EPR target reconciliation and annual return filing.
Green Permits assists vehicle producers with ELV EPR registration, target assessment, document preparation, CPCB portal filing, EPR certificate compliance and annual return support.
ELV stands for End-of-Life Vehicle.
Under the 2025 Rules, Extended Producer Responsibility essentially places responsibility on vehicle producers for ensuring environmentally sound scrapping of vehicles that reach the end of their useful or registered life.
The framework works through three important elements:
The CPCB FAQ specifically clarifies that simply collecting old vehicles and sending them to an RVSF does not by itself satisfy the EPR target. The producer fulfils the target through the applicable EPR certificates generated by RVSFs.
This distinction is important because ELV compliance is not merely a vehicle collection programme. It is a measurable EPR system linked to steel recovery and portal-based certificate accounting.
The Environment Protection (End-of-Life Vehicles) Rules define a producer as an entity engaged in:
The CPCB ELV portal further classifies producer activities into eight categories from P1 to P8.
| Code | Producer Activity |
|---|---|
| P1 | Manufacture/assemble and sell vehicles under own brand |
| P2 | Sell vehicles under own brand manufactured/assembled by another manufacturer |
| P3 | Manufacture/assemble vehicles and sell them to another producer |
| P4 | Manufacture/assemble vehicles sold in the market under another producer’s brand |
| P5 | Import vehicles and sell under own brand |
| P6 | Import vehicles and sell under the imported brand |
| P7 | Import vehicles and sell them to another producer |
| P8 | Import vehicles for self-use |
The correct classification matters because procurement, sales and transfer information entered on the portal can affect the EPR quantity assigned to different parties.
Suppose Company A manufactures commercial vehicles for Company B, and the vehicles are sold to customers under Company B’s brand.
The compliance analysis should not begin by assuming both companies carry the same EPR obligation. The supply arrangement, producer category, vehicle sales data and acceptance of transferred quantities on the portal need to be examined.
This is one reason an ELV EPR applicability review should ideally be completed before filing the registration application.
The Rules apply broadly to vehicles within the definition under the Motor Vehicles Act and specifically include:
The Rules exclude the following vehicle categories:
The ELV framework also excludes certain waste streams from being governed directly under these Rules where separate waste-management regulations already apply. These include waste batteries, plastic packaging, waste tyres, used oil and e-waste covered under their respective waste-management rules.
Therefore, an automobile producer may simultaneously face obligations under more than one environmental compliance framework.
An electric vehicle producer, for example, may need to assess ELV EPR together with other applicable obligations relating to batteries, electronic equipment, tyres, used oil or packaging depending on its business and products.
CPCB has developed the centralised EPR Portal for End-of-Life Vehicles for implementation of the framework.
The January 2026 CPCB SOP states that a producer registration application is divided into five principal sections:
Understanding what each section asks for before starting the application can prevent inconsistencies between company records and the data finally submitted to CPCB.
The producer first creates an account on the CPCB ELV EPR portal.
Basic information includes details such as:
The authorised person should be an authorised official of the company. CPCB’s SOP specifically states that the name of a consultant, agent or other agency acting on behalf of the producer should not be provided as the company’s authorised person.
Once the account is created, login credentials are generated and communicated to the registered email addresses.
Before filing the application, producers should create a consolidated registration folder.
According to the CPCB Producer SOP, documents can include:
Additional information becomes necessary during subsequent portal sections, including manufacturing facility details, sales information, vehicle weights, steel weights, turnover information, CA certificates and declarations.
| Requirement | Suggested Internal Team |
|---|---|
| GST, PAN, CIN | Finance/Legal |
| IEC | Import/Export Team |
| Manufacturing facility data | Plant/Operations |
| Vehicle production records | Production |
| Vehicle sales | Finance/Sales |
| Total vehicle weight | Engineering/Product |
| Steel weight | Engineering/BOM Team |
| Export quantities | Export/Finance |
| Co-branding arrangements | Commercial/Legal |
| CA certificate | Finance + Chartered Accountant |
| Final undertaking | Authorised Signatory |
For large automobile companies, the environmental or compliance team usually cannot prepare the registration dataset alone. Finance, engineering, sales, imports and legal teams may all hold different parts of the required information.
Where the producer operates a manufacturing or assembly facility, CPCB requires information relating to the facility.
This can include:
A producer operating multiple facilities should reconcile the information carefully so the plant-level information corresponds with the sales and production records used elsewhere in the application.
For many producers, the most challenging part of ELV EPR registration is not uploading basic company documents. It is building the correct vehicle and steel dataset.
The CPCB portal requires producers to classify information according to:
Vehicle categories available in the SOP include:
Sales information is then divided into different transaction types.
The producer reports:
The producer must provide details of the recipient producer.
CPCB’s SOP notes that quantities reported under this category can be used for adjustment of EPR targets subject to acceptance by the recipient producer.
Co-branded vehicles require additional information relating to the other producer or brand partner.
This is particularly important for OEM manufacturing, contract manufacturing and joint-brand arrangements.
Vehicles put to the producer’s own use should not simply disappear from the compliance dataset.
The Rules expressly include vehicles put to self-use within a producer’s EPR responsibility.
CPCB’s January 2026 SOP states that quantities reported as exports are not used in calculating the EPR target.
The CPCB FAQ similarly explains that entities that do not introduce vehicles into the domestic market are not subject to EPR targets, although registration requirements can still apply.
This makes separation between domestic and export sales essential.
ELV EPR is fundamentally different from an obligation calculated only on the number of vehicles sold.
The EPR target is linked to the weight of steel used in vehicles for the corresponding base year.
Therefore, simply having historical sales numbers may not be sufficient.
A producer may need to reconstruct:
CPCB’s Form 1 annual return specifically requires information regarding the number of vehicles, total weight and weight of steel in those vehicles.
For companies with many vehicle models, this can become a significant data-reconciliation exercise.
The current ELV EPR framework establishes different target phases for transport and non-transport vehicles.
| Compliance Period | EPR Target | Reference Vehicle Years |
|---|---|---|
| 2025-26 to 2029-30 | Minimum 8% of steel used | 2010-11 to 2014-15 respectively |
| 2030-31 to 2034-35 | Minimum 13% of steel used | 2015-16 to 2019-20 respectively |
| 2035-36 onward | Minimum 18% of steel used | 2020-21 onward as applicable |
| Compliance Period | EPR Target | Reference Vehicle Years |
|---|---|---|
| 2025-26 to 2029-30 | Minimum 8% of steel used | 2005-06 to 2009-10 respectively |
| 2030-31 to 2034-35 | Minimum 13% of steel used | 2010-11 to 2014-15 respectively |
| 2035-36 onward | Minimum 18% of steel used | 2015-16 onward as applicable |
These target blocks are set out in the CPCB ELV FAQ and the Rules.
For a transport vehicle producer, FY 2026-27 falls within the 8% target phase and corresponds to steel used in the applicable vehicles introduced in FY 2011-12.
For a non-transport vehicle producer, FY 2026-27 similarly carries an 8% target but corresponds to the applicable vehicles introduced in FY 2006-07.
This demonstrates why old sales records can become important even though the EPR framework itself became effective in 2025.
Consider a simplified example.
Assume an applicable producer’s verified historical vehicle data results in:
Steel used in vehicles for the relevant base year: 20,000 MT
If the applicable EPR rate is 8%:
EPR obligation = 20,000 MT × 8% = 1,600 MT
The producer would need to fulfil the applicable obligation through EPR certificates in accordance with the Rules and portal mechanism.
This example is only illustrative. Actual EPR liability depends on the producer’s vehicle category, applicable financial year, historical sales data, steel weight, transfer adjustments and CPCB portal assessment.
Registered Vehicle Scrapping Facilities play a central role in the system.
EPR certificates are generated based on the weight of steel recovered from ELVs processed at registered RVSFs or other eligible automobile-sector steel scrap processed by the facility in accordance with the applicable framework.
The CPCB portal generates the EPR certificate in favour of the RVSF, after which producers can purchase eligible certificates for fulfilment of their obligations.
This creates the compliance chain:
Vehicle Producer → EPR Obligation → RVSF Processes ELV → Steel Recovered → EPR Certificate Generated → Producer Purchases Certificate → Obligation Fulfilled
No.
According to the CPCB FAQ, a producer can purchase EPR certificates only up to the extent of its applicable obligation, including:
Once purchased by a producer, the EPR certificate cannot be transferred to another producer.
The FAQ also states that ELV EPR certificates have a validity of five years.
Yes, but the Rules do not allow unlimited postponement.
The ELV framework permits 30% of the EPR target of a particular year to be carried forward to the subsequent four years for compliance.
Producers should therefore maintain a year-wise obligation ledger rather than looking only at the current year’s target.
A useful internal compliance tracker should show:
| Financial Year | Original Target | Certificates Used | Eligible Carry Forward | Outstanding |
|---|---|---|---|---|
| FY 1 | X MT | X MT | X MT | X MT |
| FY 2 | X MT | X MT | X MT | X MT |
| FY 3 | X MT | X MT | X MT | X MT |
This makes annual return preparation and certificate procurement substantially easier.
Obtaining ELV EPR registration is not the end of the compliance process.
A registered producer has continuing responsibilities under the Rules.
The producer must declare its EPR obligation for the current financial year to CPCB.
The producer must file the Form 1 annual return for the previous financial year through the centralised online portal.
The return covers matters including:
Therefore, annual compliance should not begin in the last week of June. Producers should maintain supporting records throughout the year.
Form 1 requires producers to report key company and EPR information.
Important components include:
The Rules specifically note that target compliance includes vehicles put to the producer’s own use.
A mismatch between registration data, CA-certified sales information and annual return data can therefore create a compliance issue even where sufficient certificates have been purchased.
The Rules impose responsibilities beyond registration and certificate procurement.
A producer must also:
The Rules further state that producers should not engage unregistered entities for scrapping ELVs or for fulfilling EPR obligations.
A good ELV compliance system should maintain more than the final CPCB certificate.
Recommended records include:
Maintaining these records continuously can substantially reduce the amount of reconstruction required during annual compliance.
CPCB’s January 2026 SOP specifies producer registration fees based on average annual turnover.
| Average Annual Turnover | Registration Fee |
|---|---|
| Up to ₹10 crore | ₹25,000 |
| Above ₹10 crore and up to ₹50 crore | ₹50,000 |
| Above ₹50 crore and up to ₹250 crore | ₹2,00,000 |
| Above ₹250 crore and up to ₹1,000 crore | ₹5,00,000 |
| Above ₹1,000 crore | ₹10,00,000 |
The SOP also provides that 50% of the application fee is payable as the annual processing fee at the time of filing returns.
These are government/portal charges and should be distinguished from professional consultancy fees.
The January 2026 CPCB SOP states that a producer application is to be processed within 15 working days, with registration either granted or rejected as applicable within the stated processing framework.
However, this should not be interpreted as a guaranteed approval period.
Where information or documents are incomplete, CPCB can return the application through the portal for clarification or resubmission.
The SOP also provides that false or irrelevant information or documentation may result in rejection, forfeiture of the application fee and the need for a fresh application.
Actual completion time can therefore depend heavily on the quality and consistency of the information submitted.
Most ELV applications are data-heavy. Problems are therefore more likely to arise from inconsistent records than from the basic uploading of PAN or GST documents.
Common issues a producer should check before submission include:
A pre-filing reconciliation can identify many of these issues before they become CPCB queries.
Before filing, a vehicle producer should be able to answer the following:
If several answers are “no”, the company should complete the data exercise before filing.
The ELV framework provides for environmental compensation in cases of non-compliance.
According to CPCB’s FAQ, environmental compensation may apply to producers for matters such as:
The framework also addresses violations involving RVSFs and unregistered entities.
CPCB’s Producer SOP further states that registration may be revoked where a registered entity furnishes false information, wilfully conceals information or commits irregularities, subject to the applicable procedure and opportunity of being heard.
For this reason, ELV EPR compliance should be treated as an auditable regulatory process rather than a one-time portal registration.
MoEFCC published the Draft Environment Protection (End-of-Life Vehicles) Amendment Rules, 2026 on 27 March 2026.
The draft proposes substantial changes, including expanded reporting relating to historical quantities of steel, tyres, oil, electrical and electronic products, batteries and plastics used in vehicles.
However, as of 2 September 2026, the Ministry’s official Rules & Regulations page continues to list S.O. 98(E) – Environment Protection (End-of-Life Vehicles) Rules, 2025 as the notified ELV Rules, while the 2026 amendment remains listed by the Ministry as a draft amendment. It should therefore not be treated as a final binding amendment unless and until a final notification is issued.
Vehicle producers should nevertheless monitor this development because a final amendment could materially change future data and compliance requirements.
ELV compliance involves regulatory interpretation, historical data preparation, engineering information, financial certification and ongoing certificate management.
Green Permits provides end-to-end assistance for vehicle manufacturers, assemblers, brand owners and importers.
Our support can include:
The objective is not simply to obtain registration but to create a compliance structure that can be maintained year after year.
ELV EPR is unusual because the current compliance obligation can depend on historical vehicle data from many years earlier.
A producer that waits until the annual filing deadline may discover that:
Resolving these issues can take substantially longer than uploading an application.
The better approach is to create an ELV EPR master dataset that can be updated each financial year and used for target calculation, certificate procurement and return filing.
Where an entity falls within the producer framework under the Environment Protection (End-of-Life Vehicles) Rules, it is required to obtain producer registration from CPCB through the centralised online portal.
Yes. Import of vehicles is included within the definition of producer. CPCB’s portal further recognises different importer situations under P5, P6, P7 and P8 classifications.
Yes. The Rules expressly include electric vehicles, battery-operated vehicles, e-rickshaws and e-carts.
Agricultural tractors, agricultural trailers, combine harvesters and power tillers are excluded from the applicable vehicle scope specified in the Rules.
The CPCB Producer SOP states that exported vehicle quantities reported in the relevant field are not used for EPR target calculation.
The CPCB portal includes P8 – Import of Vehicles for Self Use, and the Rules include vehicles put to self-use within the producer’s EPR framework.
A producer must submit Form 1 by 30 June for the previous financial year.
The Rules require the producer to declare its current-year EPR obligation to CPCB by 30 April of the same year.
Yes. Up to 30% of a year’s target may be carried forward to the subsequent four years for EPR target compliance.
CPCB’s ELV FAQ states that an EPR certificate is valid for five years.
The CPCB framework enables producers to purchase eligible EPR certificates from registered RVSFs through the portal mechanism. The portal dashboard provides information regarding available certificates and RVSFs.
No. CPCB specifically clarifies that collection and transfer of ELVs to an RVSF does not by itself count as EPR fulfilment. The target is fulfilled through applicable EPR certificates.
For vehicle producers, ELV EPR compliance involves much more than creating a CPCB login. Historical vehicle sales, steel-weight data, producer transfers, exports, self-use vehicles, EPR targets, RVSF certificates and annual returns all need to work together.
A single inconsistency can affect the EPR target or create a query during registration or annual filing.
Green Permits assists vehicle manufacturers, vehicle importers, assemblers and brand owners with complete ELV EPR registration and annual compliance support across India.
📞 Call Green Permits: +91 78350 06182
📧 Email: wecare@greenpermits.in
🌐 Website: www.greenpermits.in
Book a consultation with Green Permits for ELV EPR registration and annual compliance support for your vehicle business.
