Amit, a first-generation entrepreneur, planned to establish a 20 MT per day continuous tyre pyrolysis plant in an industrial area in northern India. He had experience in transportation, but this was his first recycling project.
The machinery supplier offered a complete plant package and requested a 40% advance payment. The commercial proposal appeared attractive, so Amit paid the advance before obtaining Consent to Establish from the State Pollution Control Board.
The difficulty started when his environmental application was reviewed. The application mentioned a capacity of 20 MT per day, but the machinery layout indicated a possible processing capacity of 24 MT per day. The proposed layout also did not provide a separate covered area for recovered carbon material, an impervious pyrolysis oil storage zone or sufficient space for pollution-control equipment.
The application remained under clarification for almost 11 weeks. During this period, the machinery was ready for dispatch, the industrial shed rent continued and the project loan started attracting interest.
A revised DPR, process flow diagram, mass balance and plant layout were then prepared. The following changes were made:
The redesign increased the project cost by approximately ₹9.5 lakh and delayed installation by nearly 3 months. However, it prevented a larger problem. Had the plant been installed according to the original layout, the business could have faced CTO refusal, expensive civil modifications and a possible production stoppage.
This is an illustrative case study based on common issues seen in recycling projects. It shows why regulatory planning should begin before machinery procurement.
A waste tyre recycling plant setup in India is not only a machinery installation project. It is a regulated industrial operation involving land selection, pollution-control planning, State Pollution Control Board approval, CPCB registration, GST-linked material records and Extended Producer Responsibility certificate management.
The applicable framework is primarily contained in the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The Hazardous and Other Wastes Amendment Rules, 2022 inserted Rule 9(4) and Schedule IX to establish an EPR framework for waste tyres. The framework applies to producers, recyclers and retreaders engaged in the manufacture, sale, transfer, collection, storage and processing of tyres or waste tyres.
A plant owner must therefore develop the technical project and compliance file together. The capacity stated in the DPR, CTE, CTO, Hazardous Waste Authorization and CPCB application should match the actual machinery installed at the site.
The project should be planned around 4 connected questions:
India produced approximately 4.2 million metric tonnes of tyres during FY 2024-25, according to the NITI Aayog waste tyre circular economy report. Approximately 2.5 million metric tonnes were absorbed by the domestic market, 1.5 million metric tonnes were exported and 0.2 million metric tonnes represented tubes and flaps. Imports of new tyres were approximately 0.07 million metric tonnes.
Two-wheelers and three-wheelers represented approximately 53% of total tyre production by volume. Passenger cars contributed around 26%, truck and bus tyres contributed 11%, light commercial vehicles contributed 5%, agricultural tyres contributed 4% and other categories contributed approximately 1%.
These numbers indicate a substantial and recurring waste tyre stream. Tyres generally have a shorter service life than the vehicles on which they are fitted. Their replacement creates a continuous feedstock market for crumbing, reclaiming, recovered carbon black and controlled pyrolysis operations.
The CPCB national dashboard showed the following status on 14 July 2026:
The same dashboard showed approximately 4.375 million MT of EPR credits generated during FY 2025-26, consisting of about 2.910 million MT for domestic tyres and 1.465 million MT for imported tyres. Dashboard figures are dynamic and should be verified before preparing a financial forecast.
The selected technology determines the investment cost, land requirement, pollution potential, operating risk and value of the EPR certificates that may be generated.
A mechanical crumb-rubber plant usually requires shredders, granulators, magnetic separators, fibre separators, dust-control systems and product-sizing equipment. It has no pyrolysis reactor or tyre-derived oil storage, but noise and rubber-dust controls remain important.
A reclaim-rubber facility normally requires additional heat, chemicals, mixing and processing systems. Depending on the process, the unit may also require effluent treatment and more extensive occupational-safety controls.
A tyre pyrolysis plant processes tyres in a low-oxygen environment to produce pyrolysis oil, recovered carbon material, steel wire and combustible gas. Continuous pyrolysis plants generally require greater automation, safety interlocks and pollution-control investment than small batch plants.
| Recycling process | Main product | EPR weightage |
|---|---|---|
| Reclaiming | Reclaimed rubber | 1.30 |
| Carbon recovery | Recovered carbon black suitable for new tyre manufacturing | 1.25 |
| CRMB production | Crumb rubber modified bitumen | 1.10 |
| Mechanical recycling | Crumb rubber | 1.00 |
| Continuous pyrolysis | Pyrolysis oil and char used as fuel | 0.80 |
| Batch pyrolysis | Pyrolysis oil and char used as fuel | 0.50 |
CPCB applies both an end-product weightage and a conversion factor. For example, the conversion factor reported for reclaimed rubber is 1.298, crumb rubber is 1.333 and pyrolysis output is 1.49. The certificate formula is:
QEPR = QP x CF x WP
In this formula:
A higher product weightage does not automatically mean a more profitable plant. The entrepreneur must also evaluate product demand, energy consumption, recovery percentage, product specifications and the cost of pollution-control equipment.
Plant capacity should be selected after examining feedstock availability and buyer demand. Machinery suppliers may propose a capacity based on reactor size or equipment throughput, but the approved capacity should be supported by a realistic material-sourcing plan.
A 20 MT per day plant operating for 300 days would require approximately 6,000 MT of waste tyres annually. If actual operations reach only 60% utilization, the annual input would fall to approximately 3,600 MT.
This difference affects revenue, electricity consumption, labour utilization, working capital and EPR certificate generation. A project should therefore not be financially modelled at 100% capacity from the first month.
A practical utilization plan may be:
These are commercial planning assumptions, not statutory capacity limits. The CPCB and SPCB capacity will be based on the approved machinery, process and consent documents.
No single national land standard applies to every tyre recycling plant. Land requirement depends on the process, input storage, finished-product storage, fire separation, vehicle movement and state-specific siting requirements.
A dry mechanical recycling unit generally requires less land than an integrated tyre pyrolysis or reclaim-rubber facility. Pyrolysis plants need additional space for reactor systems, gas handling, oil storage, carbon storage and emergency movement.
| Plant type | Capacity | Indicative land |
|---|---|---|
| Small crumb-rubber plant | 5 to 10 MT/day | 0.5 to 1 acre |
| Medium crumb-rubber plant | 15 to 25 MT/day | 1 to 2 acres |
| Continuous pyrolysis plant | 10 to 20 MT/day | 1.5 to 3 acres |
| Integrated recycling facility | 30 to 50 MT/day | 3 to 6 acres |
These are pre-feasibility ranges. The final land requirement should be calculated from the equipment layout and applicable state siting criteria.
The layout should separately identify:
Electricity consumption depends heavily on the recycling route. Mechanical shredding and granulation use substantial electrical power, while pyrolysis requires both electrical systems and thermal energy.
A 5 to 10 MT per day mechanical plant may require approximately 150 to 350 kW of connected load. A 15 to 30 MT per day integrated crumb and reclaim plant may require approximately 500 to 1,200 kW.
A continuous pyrolysis facility may require approximately 250 to 600 kW of electrical load, in addition to the thermal energy required by the reactor. Part of the combustible gas generated by the process may be reused as fuel, subject to safe system design.
Fresh-water demand can range from a few kilolitres per day for a dry mechanical unit to 10 to 30 KLD or more for a plant using cooling systems, wet scrubbers or reclaim-rubber processing.
The DPR should quantify:
Zero Liquid Discharge is not automatically mandatory for every waste tyre recycling project. A dry shredding and crumbing plant may generate little process wastewater.
However, a pyrolysis or reclaim-rubber facility may generate scrubber water, oily wastewater, floor-washing water, cooling-tower blowdown or contaminated stormwater. The SPCB may require an ETP, closed-loop water system, evaporation arrangement or zero-discharge condition based on the process and location.
The project should not release untreated process water outside the premises. Clean stormwater and potentially contaminated drainage should be separated.
The basic wastewater strategy should provide for:
Plant investment varies according to technology, automation, location, imported equipment, pollution-control systems and working-capital requirements.
Low-cost machinery quotations often exclude electrical infrastructure, civil construction, pollution-control systems, installation, fire protection, professional fees and working capital.
| Plant model | Capacity | Indicative project investment |
|---|---|---|
| Basic shredding and crumb rubber | 5 to 10 MT/day | ₹1 crore to ₹4 crore |
| Integrated crumb and reclaim rubber | 15 to 30 MT/day | ₹5 crore to ₹15 crore |
| Continuous tyre pyrolysis | 10 to 20 MT/day | ₹4 crore to ₹12 crore |
| Integrated multi-output facility | 30 to 50 MT/day | ₹12 crore to ₹30 crore or more |
These figures are preliminary planning estimates. They may exclude land purchase, GST, interest during construction, feedstock inventory and initial working capital.
A properly prepared cost estimate should separately include:
The physical plant approval is primarily handled by the concerned SPCB or PCC. Waste tyre recycler registration and certificate transactions are managed through the CPCB EPR portal.
Consent to Establish should be secured before establishing the process or installing the machinery. Consent to Operate and applicable Hazardous Waste Authorization should be obtained before commercial operation.
The CPCB application relies on plant-specific evidence. The authority may verify the capacity, machinery, geotagged photographs, consent documents, invoices and actual operating records.
| Regulation or approval | Requirement | Stage | Principal risk |
|---|---|---|---|
| Industrial land approval | Land must permit the proposed industrial activity | Before purchase or lease | Location rejection |
| Consent to Establish | Approval of process, capacity and pollution controls | Before establishment | Machinery and layout may become unusable |
| Factory plan approval | Approval of industrial building and worker-safety arrangements | Before construction or operation | Factory licence delay |
| Fire NOC | Fire prevention and emergency response systems | Before operation | Production restriction |
| Consent to Operate | Permission to commence production | After installation | Production halt |
| Hazardous Waste Authorization | Handling and disposal of applicable hazardous waste | Before waste handling | Authorization refusal |
| CPCB recycler registration | Registration of the individual recycling facility | Before EPR certificate activity | No certificate generation |
| GST-linked record system | Traceable purchase and sales documentation | During operation | Certificate disallowance |
| Periodic returns | Monthly information and quarterly and annual filing | During operation | Notice, suspension or EC |
A project can generally require 5 to 8 months from initial feasibility to commercial operation. A complex pyrolysis facility or a project in a sensitive location may take longer.
The timeline should not be treated as guaranteed. Processing depends on application quality, state procedures, site inspection, portal verification and the number of clarifications raised by the authority.
| Step | Authority | Planning period | Principal documents |
|---|---|---|---|
| 1. Feasibility study | Internal and consultant | 2 to 3 weeks | Capacity, process and financial model |
| 2. Land due diligence | Industrial authority | 1 to 3 weeks | Land papers and zoning documents |
| 3. DPR and layout | Technical team | 2 to 4 weeks | Process flow, mass balance and layout |
| 4. CTE application | SPCB or PCC | 6 to 16 weeks | DPR, land documents and control proposal |
| 5. Construction and installation | Project owner | 8 to 20 weeks | Approved plans and supplier drawings |
| 6. CTO and authorization | SPCB or PCC | 4 to 12 weeks | Compliance report and monitoring evidence |
| 7. CPCB registration | CPCB portal | Subject to complete application | CTE, CTO, authorization and plant evidence |
| 8. Trial and commercial operation | Project owner | 2 to 4 weeks | Trial records and operating procedures |
A CPCB portal registration target should not be treated as the complete project timeline. The plant must first have consistent environmental approvals and verifiable machinery.
The CPCB registration application should be prepared while the plant is being constructed. Waiting until machinery commissioning often leads to document inconsistencies.
One registration is associated with the individual recycling facility. A company operating multiple plants may therefore need separate facility-specific registrations.
The capacity shown in the CTO should match the CPCB application. If the CTO permits 20 MT per day, the recycler should not enter 25 MT per day merely because the machinery supplier claims that higher output is possible.
The recycler first creates an account and enters the facility details, GPS coordinates, authorized-person information and approval validity.
The applicant then uploads environmental documents, plant photographs, machinery details, capacity information, process flow and mass balance. CPCB and the concerned SPCB or PCC may verify the information before or after registration.
Once registered, the recycler must maintain procurement, production and sales information on the portal. CPCB guidance requires purchase and sales invoices to be entered sequentially, beginning with the oldest transaction.
The normal filing sequence includes:
The waste tyre EPR targets are different from the 8%, 13% and 18% targets applicable under the ELV framework. Those percentages should not be used in a waste tyre article.
For waste tyres, the initial targets were 35%, 70% and 100%. From FY 2024-25 onward, established producers generally have an obligation equal to 100% of the new tyres manufactured or imported in year Y-2.
A production unit established after 1 April 2022 begins its obligation after 2 years. A waste tyre importer has an obligation equal to 100% of the quantity imported in year Y-1.
| Financial year | Waste tyre EPR target |
|---|---|
| FY 2022-23 | 35% of FY 2020-21 quantity |
| FY 2023-24 | 70% of FY 2021-22 quantity |
| FY 2024-25 | 100% of FY 2022-23 quantity |
| After FY 2024-25 | 100% of the quantity in year Y-2 |
| Waste tyre importer | 100% of imports in year Y-1 |
A wear-and-tear discount factor is also applied to the applicable obligation. The NITI Aayog report records the current factor as 20%.
CPCB generates certificates in favour of registered recyclers based on the quantity of waste tyres recycled, the eligible end product and supporting sales information.
The recycler must upload the quantity of tyres procured or imported, the quantity recycled, the quantity of end products produced and the quantity sold. Procurement invoices, bills of lading for imports and GST-linked sales invoices form part of the evidence.
EPR certificates are valid for 2 years from the end of the financial year in which they were generated. An expired certificate is automatically extinguished unless it has already been used or extinguished under the applicable provisions.
Important controls include:
Imported waste tyres cannot be used for producing pyrolysis oil or char. Imported tyres must be used by the actual user for permitted recycling or recovery outputs other than tyre pyrolysis oil.
This is particularly important for pyrolysis projects. A plant should not assume that imported waste tyres can be used when domestic waste tyre prices increase.
The project should separately maintain:
Registered recyclers must maintain information relating to tyre procurement, recycling, product generation, product sales and EPR certificate transactions.
Quarterly and annual returns must be filed by the end of the month following the relevant quarter or year. CPCB has also issued notices concerning non-submission of annual returns for FY 2022-23, FY 2023-24 and FY 2024-25, showing that return filing is an active enforcement area.
A recycler should reconcile its records every month rather than waiting until the annual return.
The monthly reconciliation should cover:
Consider a hypothetical plant processing 1,000 kg of waste tyres. Its projected material balance might show the following output:
| Output | Illustrative quantity |
|---|---|
| Rubber or carbon-rich material | 350 to 450 kg |
| Pyrolysis oil or rubber product | 350 to 450 kg |
| Steel wire | 100 to 150 kg |
| Gas, moisture and process loss | 50 to 100 kg |
| Total | 1,000 kg |
This example is illustrative and not a guaranteed recovery ratio. Actual output depends on tyre composition, moisture, technology, temperature and operating practices.
The commercial model should not treat every output as immediately saleable. Carbon material may require further processing and testing. Steel may need cleaning and baling. Oil quality may vary between operating batches.
The DPR should therefore include:
A registration certificate does not protect a plant that operates outside its approved capacity or process. CPCB and SPCBs may verify the machinery, invoices, raw-material quantities, production records and product sales.
Providing incorrect information, using false certificates or failing to cooperate during verification may lead to environmental compensation and proceedings under Section 15 of the Environment Protection Act.
CPCB guidance specifically identifies over-generation of certificates above 5% of the actual waste recycled as a serious non-compliance.
| Non-compliance | Business consequence |
|---|---|
| Machinery installed before CTE | Layout alteration and project delay |
| Capacity mismatch | CTO or CPCB application objection |
| Missing pollution-control system | Consent refusal or production stoppage |
| Incorrect invoices | EPR certificate rejection |
| Over-generation above 5% | Environmental compensation and prosecution risk |
| Missing returns | Show-cause notice and portal action |
| Unapproved imported tyre use | Import and environmental action |
| Poor oil or char storage | Fire risk and SPCB closure |
| Unauthorised residue disposal | Environmental liability |
| Dealing with an unregistered entity | EPR non-compliance |
Most approval delays are caused by inconsistencies rather than the absence of a single document. A GST certificate may show one address while the CTE application shows another. The machinery quotation may show a different capacity from the DPR.
A process flow may mention a scrubber without showing how its wastewater will be treated. The product list may include recovered carbon black even though the machinery only produces unprocessed char.
The most common delay points include:
Before ordering machinery, the entrepreneur should complete a basic technical and commercial verification.
For a 20 MT per day unit operating 300 days, feedstock demand can reach 6,000 MT annually. A supply agreement covering only 500 MT would therefore be inadequate, even though it may appear sufficient during the first few trial months.
The entrepreneur should also secure potential buyers before selecting the technology. A project producing 7 MT of carbon material per day requires a market for approximately 2,100 MT annually at 300 operating days.
Before financial closure, confirm:
A waste tyre recycling plant setup in India requires the technical process, approvals and commercial model to work together.
A plant with a ₹5 crore machinery investment can remain non-operational because of a missing approval, unsuitable site or incorrect layout. In contrast, spending approximately 1% to 3% of the project value on feasibility, DPR preparation, approval planning and documentation can reduce larger modification and delay risks.
Early compliance planning provides 4 practical benefits:
Green Permits supports waste tyre recycling projects through feasibility assessment, DPR preparation, process planning, plant layout, SPCB approvals, CPCB registration and EPR compliance systems.
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Waste tyres are regulated under the Hazardous and Other Wastes Rules, 2016, including Rule 9(4) and Schedule IX inserted through the 2022 amendment.
A small mechanical plant may require approximately 0.5 to 1 acre. A 10 to 20 MT per day continuous pyrolysis facility may require approximately 1.5 to 3 acres, subject to the layout and state siting conditions.
A small shredding and crumb-rubber plant may require approximately ₹1 crore to ₹4 crore. A continuous pyrolysis plant may require approximately ₹4 crore to ₹12 crore. These are indicative planning estimates.
A waste tyre EPR certificate is valid for 2 years from the end of the financial year in which it was generated.
