17.04.2022 @ Roots Café, Bandrol, Himachal Pradesh

Scrolling through the Instagram early in the morning, while sitting on the thinking pot during the last day of the holiday, makes a startling revelation by a glimpse into the brief video made and uploaded by World Economic Forum1. It gives an insight and raises questions on the monster we created, that the threat it poses to the mankind at large and the ways towards its annihilation, if any.

I would choose not to go very elaborate with the literature, being verbose and rhetoric; I would restrain myself and stick to the hard numbers and the consequential requirements.

This piece is being written by me, apart from a burning issue, it attracted certain practical aspects, since my close association with the solid waste management industry along with renewable energy.

India being world’s 3rd largest producer and 4th largest consumer of natural rubber, generated around 169 million units of tyres in the FY ending 2021, which has witnessed a decrease by 4% from the preceding FY, though the industry forecast expected to grow to reach 218 million units by 2026. As a natural corollary, out of more than 1.5 billion units of waste tyres, India is contributing approx. 6%. It also imports around 3 lacs tons of tyres to recycle and disposal every year. Apart from that it also discards approx.. 2,75,000 tyres every day.

A further research takes us to the order dated 19.09.2019 passed by NGT in OA No. 400/2019 with regard to the issue of absence of proper management of end of life tyres/ waste tyres as per the laws of the land and most specifically provisions of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The alarming unauthorized and illegal use of waste tyres by the Pyrolysis Industry operating in the country, engaged in producing inferior quality pyrolysis oil, pyrolysis gas, solid residue (char) carbon black and steel through the pyrolysis process, were brought to the knowledge of the Tribunal. Concerned over making India a graveyard or dump-yard of highly polluting hazardous waste material, it at once warned CPCB and other authorities to regulate and restrict import of waste tyres for recycling. 

Further, vide order dated 25.10.2021, other suggestions were made by NGT. As an off shoot of which my attention was drawn to a draft Regulation on Extended Producer Responsibility (EPR) for Waste Tyres, 20212, by virtue of which:

  • obligations have been laid down on the producers as well as recyclers of waste tyre for registration and other compliances;
  • The manufacturers and importers of new tyres to be responsible for waste tyre recycling target in percentage form, year-wise;
  • The import of waste tyre for the purpose of producing pyrolysis oil/ char is completely prohibited;
  • The producers are under obligation to fulfil its EPR obligation through online purchase of EPR certificate from registered recyclers; 
  • The modus operandi of EPR Certificate Generation is also provided under the Regulation. A violation of the requirements under the Regulations would entail environmental compensation.

The waves of questions emerged by an insight into the issues are definitely not satiated vide the concerns of NGT coupled with status report submitted by CPCB, directions of NGT and a draft Regulation for EPR, which is yet to be notified. 

An integrated approach is the only way forward and probably that is what the constituent assembly envisaged while borrowing DPSP (Chapter IV) from Irish Constitution, further insertion of Article 48-A by the Parliament, with the Supreme Court and the High Courts of the country playing a vanguard role in protecting the environment through the routes of statutes or vide the conundrum of right to life and personal liberty, guaranteed under Article 21 of the Constitution of India.

Apart from the Regulations being in force with the precaution of registration, proclamation of consent, redemption of certificates and the deterrence of imposition of penalty/ compensation, incentivization of the industries for recycling and a road map of the finish products along with process technology are required to be in place. Vide a detailed policy decision, Government of India to ensure, so that the next level of environmental crisis can be nipped by adhering to the best technology available with least hazardous and most useful end use in the form of recycling of tyres.

A consumption intensive economy apart from incentivizing and promoting manufacturing, shall have to parallelly establish an all pervasive scientifically processed recycling industry, else the waste or the consequential hazard of the waste, would subsume the ‘generate’.

1   Kuwait is recycling one of the world’s largest tyre graveyards, the dumpsite held more than 42 millions tyres where fire keeps breaking out, emitting noxious black smoke into nearby suburbs. The Government has moved the tyres to a facility at al-Salmi, where recycling has begun, where the tyre is getting sorted and shredded, compressing the same into rubber floor tiles which can then be resold. The plant opened in January, 2021 and can recycle 3 million tyres a year. Another company is planning to open a facility for tyre pyrolysis at al-Salmi. The process turns then into an oil which can be used in cement factory. Globally, scrapped tyre is a major environmental hazard due to the chemical emits, the products mix and the difficulty in processing. World produces 1.5 billion waste tyres a year. They are difficult to recycle, when they are dumped, they are becoming a serious fire hazards. A smoke that brock out in Wales in 1989 was still smouldering 15 years later. The recycled tyres can be utilized for asphalt giving roads better grip and more durability, rubber pad that can fit under train and tram carriages and even railway slippers.

2 https://moef.gov.in/wp-content/uploads/2022/01/S.O.-5497E-Date31-12-2021-Draft-Notification-for-seeking-public-comments-on-Regulation-on-Extended-Producer-Responsibility-for-Waste-Tyres.pdf

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