Entity Role Comparison — Tyre Pyrolysis Ecosystem
A complete map of the seven entities in the tyre pyrolysis supply chain — showing each entity's core function, who they buy from, who they sell to, and their position in the EPR obligation structure.
| Entity | Core Function | Sells To | Buys From | EPR-Obligated |
|---|---|---|---|---|
| Producers, Manufacturers & Importers | Manufacture or import new tyres into the Indian market | Vehicle OEMs, dealers and distributors, consumers | Raw material suppliers (out of scope here) | Yes — primary EPR-obligated party under CPCB rules |
| Vehicle OEMs | Build and sell complete vehicles, source tyres as a component | Consumers | Producers (for tyres), other component suppliers | Indirect — linked through producer EPR chain |
| Consumers | Use tyres on vehicles until end of useful life | Out of scope (terminal user) | Vehicle OEMs through dealers, tyre dealers in the replacement market | No |
| Collection Centers | First-touchpoint aggregation of waste tyres from consumers and garages | Scrap dealers, retreaders, sometimes directly to pyrolysis units | Consumers, garages, fleets, local bodies | No (operational entity, no central obligation) |
| Scrap Dealers | Bulk volumetric aggregation layer for waste tyres | Pyrolysis units, other recyclers | Collection centers, consumers, fleets, garages | No |
| Retreaders | Extend tyre useful life by replacing worn tread | Consumers (retreaded tyres), scrap dealers and pyrolysis units (non-retreadable casings) | Collection centers, consumers, dealers | Can generate Retreading Certificates that defer producer targets by one year (not a substitute) |
| Tyre Pyrolysis Units | End-of-life processing — produces material streams (covered in Module 11) | Material buyers (output side), producers and PROs (EPR-credit side) | Scrap dealers (primary), retreaders, collection centers, producers (off-spec) | Recycler-side EPR registration required to monetise credits |
Beyond definitions
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How to read this table
- Each row covers one entity type — read across all four columns to understand its full role in the ecosystem
- EPR-Obligated column indicates the entity's formal regulatory status under CPCB tyre EPR rules — not whether they participate commercially in EPR credit transactions
- Tyre Pyrolysis Units operate in two markets simultaneously: the commodity market (selling TPO, rCB, steel) and the EPR credit market — both require separate commercial relationships
About this table
The tyre pyrolysis supply chain involves seven distinct types of entities, each with a defined role, a specific set of counterparties, and a particular relationship with the Extended Producer Responsibility (EPR) framework. Understanding where each entity sits in the chain is essential for a tyre pyrolysis operator — it determines who your feedstock suppliers are, who your output buyers are, and who you need to register with for EPR certificates.
Producers, manufacturers, and importers are at the regulatory origin of the EPR chain. They manufacture or import new tyres into the Indian market and are the primary EPR-obligated parties under CPCB rules — meaning every tonne they put on the market creates a future obligation to ensure its end-of-life processing. Vehicle Original Equipment Manufacturers (OEMs) are linked to this chain through their tyre suppliers but carry only an indirect EPR connection. Consumers are the terminal users of tyres and carry no EPR obligation — they are simply the point at which a tyre transitions to waste status.
The three middle-tier entities — collection centers, scrap dealers, and retreaders — form the aggregation and routing layer. Collection centers are the first formal touchpoint for waste tyres, gathering them from garages, fleets, and local bodies before forwarding to scrap dealers or retreaders. Scrap dealers provide the bulk volumetric aggregation that feeds pyrolysis units with consistent tonnage. Retreaders extend tyre useful life by replacing the tread — non-retreadable casings from retreaders flow back into the recycling chain. Retreaders can generate Retreading Certificates that allow producers to defer their EPR target by one year, though this is not a substitute for full EPR fulfilment.
Tyre Pyrolysis Units sit at the processing end of the chain. They buy primarily from scrap dealers, process waste tyres into material streams (Tyre Pyrolysis Oil, recovered carbon black, and steel), and sell on two parallel tracks: to material buyers on the product side, and to producers or Producer Responsibility Organisations (PROs) on the EPR-certificate side. Recycler-side EPR registration with CPCB is required before any EPR credit transaction can occur.
Key insights
- Tyre pyrolysis units must register with CPCB on the recycler side before any EPR credit transaction — this registration is separate from the state-level CTE/CTO consents
- Scrap dealers are the primary feedstock source for pyrolysis units — relationships with multiple scrap dealers across a region reduce feedstock concentration risk
- Retreading Certificates allow producers to defer EPR targets by one year — not cancel them — so retreaders are competitors for EPR credit revenue in the short term only
- Collection centers have no central EPR obligation but are the first point where waste tyres enter the formal tracking system — informal collection centers generate volumes that cannot be used for EPR credit claims
- Vehicle OEMs carry only an indirect EPR connection through their tyre suppliers — they are not direct counterparties for pyrolysis unit operators
Methodology & sources
Entity roles and EPR obligation statuses are based on CPCB notifications under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules as applied to end-of-life tyres, and industry supply chain structure as observed in India as of 2024. The retreading certificate deferral mechanism is as notified by CPCB — verify current rules at CPCB website before relying on this for financial modelling.
Related data tables
Approvals and Registration Checklist by Project Stage
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EPR Credits — Generation, Transfer, and Surplus
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EPR Targets and End-Product Certificate Weightages
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