[Explainer] Why are waste tyres a growing environmental concern?

In December 2022, India became the world’s third-largest automobile market, surpassing Japan. The sector accounts for around 7% of India’s gross domestic product (GDP). As the vehicle market expands, there is a corresponding growth in the Indian tyre market.

Tyre production in India rose by 21% in 2022 and a further 6% in 2023, reaching a total production of 217.4 million units in a year. By weight, 2.5 million metric tonnes (MT) of tyres have been produced in India annually since 2019.

This growth story, however, has a flip side. “After accounting for wear and tear of 20%, about 2 million MT of tyres are discarded as scrap annually,” said Satish Goyal, president of the Tyre & Rubber Recyclers Association of India (TRRAI). “Add to this the 0.8 million MT of scrap tyre imported into India annually from countries such as the United Kingdom, Australia and UAE, where recycling tyres is not permitted, which brings the total tyre waste handled in India to 2.8 million MT,” he said.

In 2022, India’s Ministry of Environment, Forests and Climate Change (MoEFCC) introduced extended producers’ responsibility (EPR) for waste tyres, which means the producer or importer is responsible for the safe disposal of the end-of-life tyres. The producer or importers can buy their EPR certificates from recyclers who are then responsible for converting waste tyres into environmentally safe products. “EPR is a boon for tyre recycling in India. Recyclers can now invest in environmentally safe technologies. However, unless tyre producers come forward to pay for it, it will not be easy,” said Goyal. Data from the Central Pollution Control Board (CPCB) shows that currently, less than 1% of the recycling of the tyres is paid for by tyre producers.

How do waste tyres impact the environment and public health?

Waste tyres constitute about 1% of the total municipal solid waste in India, as per a 2021 report by the central Ministry of Housing and Urban Affairs (MoHUA). However, tyres are non-biodegradable and occupy significant space in waste dumping areas. Water stagnation in recklessly discarded tyres makes them an ideal breeding ground for mosquitoes and rodents, leading to diseases such as malaria and dengue.

Given its potential to retain heat, fuel is derived from rubber tyres and though banned, it is a cost-effective but polluting fuel in brick kilns and jaggery-making units. Burning tyres emit carcinogenic pollutants such as aromatic hydrocarbons, dioxins, furans, etc.

Tyres also catch fire easily, which, once ignited, is difficult to put out. Tyres have been responsible for many historical fires. Among them, the largest one has been in Wales which began in 1989 and took 15 years to extinguish, notes a 2017 report, Circulating Tyres in the Economy by Chintan Environmental Research and Action group. It was caused by 10 million stockpiled tyres. In another case in May 2016, 9000 people living near a “toxic cloud” from a burning tyre dump near Madrid in Spain were told to leave their homes. In India, there have been no instances of fire in stockpiled tyres, but toxic fumes from rubber burning contribute to the frequent garbage landfill fires. The ash and residue from the fire pollute further by leaching into soil and groundwater.

India was discarding 2,75,000 tyres every day in 2021, as per the MoHUA report. “There is no tracking of these discarded tyres and monitoring of their disposal across India,” said the report. Recyclers meanwhile say all parts of a scrap tyre are reused.

According to TRRAI’s Goyal, there are about 800 registered recyclers in India, which is about 70-80% of the entire tyre recycling sector. Most plants are located in Uttar Pradesh and Haryana, with 250 and 150 units, respectively. Goyal’s association, TRRAI, has 400 members. Of the total 800 recyclers in India, 650 produce Tyre Pyrolysis Oil (TPO). Tyre and rubber recycling today is a Rs. 35 billion industry, set to grow ten times due to the “increasing size of the domestic automobile industry and the value-addition in the recycling industry in the same period,” says one estimate.

How are waste tyres recycled?

The materials recovered out of waste tyres, as approved by the MoEFCC, are reclaimed rubber, crumb rubber, crumb rubber modified bitumen (CRMB), Recovered Carbon Black (RCB) and Tyre Pyrolysis Oil (TPO) and its char.

Besides these, old tyres can be reused by undergoing retreading and regrooving processes. Retreading means vulcanising (a chemical process) a new tread on tyres which have their casing in good condition. Regrooving is manually carving grooves on old tyres. Retreading is common for slow-moving and animal-driven vehicles but considered unsafe for fast-moving vehicles. “Tractors used in paddy fields need to have new tyres every two years, so there is a big market for retreading in Punjab and Haryana,” said a tyre producer and recycler from Ludhiana. Regrooving tyres in heavy-load vehicles such as lorries, trucks and buses means lower overhead costs for fleet operators, says the Chintan report.

Reclaim and crumb rubber are used to make conveyor belts, doormats, floor tiles for gymnasiums, play and walking areas, bicycle pedals, shoe soles, pots, rubber sheets, hosepipes, and battery containers. CRMB is used as an additive to bitumen in making roads. Rubberised bitumen is less prone to temperature variation and rain than ordinary bitumen and “more resistant to thermal cracking, fatigue cracking, rutting, moisture damage and age hardening. Till 2017, over 1,25,000 km of road had been laid using CRMB. “This is the most environment-friendly disposal of waste tyres. About 6-8 lakh MT of bitumen is being imported annually in India. By adding crumb rubber to bitumen, we can reduce this by 12-14%,” said the Chintan report.

Pyrolysis is the chemical decomposition of organic material at elevated temperatures in the absence of oxygen. The tyre pyrolysis process generates 40% oil, 33% carbon char and 15-20% steel wire. The oil generated or TPO is used as an alternative to fuel furnaces. It is most commonly used in making hot mixes for road laying. India produces 1 million MT TPO, said Goyal. But if extraction of TPO is not done correctly, it releases smoke and soot. “The conditions in which labour works in these units are inhumane. These are closed units with no air ducts. The owners give them jaggery and alcohol to douse the effect of carbon on lungs, but that doesn’t help for long,” said the Ludhiana tyre producer and recycler on conditions of anonymity.

The carbon char generated through pyrolysis is used as filler material for black polymer products like water tanks and also in paints and dyes. “Because of its high calorific value, carbon char is still used for heating in brick and cement kilns, though it is not permitted,” said Goyal. “A product (char) that was considered dust earlier and would be let out in the atmosphere is now diligently collected as it is also used to make RCB, a material that is used back in new tyres,” he said.

At present, around 30% of a new tyre is composed of virgin carbon black, a petroleum product. But RCB that is extracted from carbon char by a series of processes can replace this up to some extent. “A new policy is being worked out to use 5-10% RCB in new tyres now, which will help reduce the volume of virgin carbon black used in new tyres,” said Goyal.

What does the law say?

As per the 2022 EPR notification, tyre producers, importers (including those importing scrap tyres), recyclers, and retreaders are supposed to register on the Central Pollution Control Board’s (CPCB) EPR portal. Producers and importers can fulfill their EPR obligation by buying EPR certificates online from recyclers via this portal. Based on the quantity of tyre recycled by them, the recyclers generate these certificates on the portal. Each recycling method carries weightage points and recyclers are given credits accordingly. In 2022-23, more than 4 lakh credits were generated by recyclers, while above 91,000 credits were generated in 2023-24. Non-compliance of the EPR would invite a refundable fine.

In 2022-23, when the notification came, producers were required to fulfill the EPR obligation of up to 35% of the tyres, about eight lakh credits produced by weight. For 2023-24, it was supposed to be 70% or 18 lakh credits. In the year 2024-25 and after that, it will be 100%. However, as per the portal, the producers bought only about 5000 credits, not even 1%.

“The tyre producers don’t want to pay for EPR as it is an additional cost for them so they are alleging that TPO is an unstable and polluting industry. They want us to sell EPR credit at the rate of Rs 2/kg, but it is not sustainable for us to run a recycling company at less than Rs 5-6/kg,” said Goyal. All the 650 registered TPO units in India have the state pollution control board’s consent to operate. If they were polluting, they would not be given the consent, he added.

In November 2023, the CPCB designated TPO as an Orange category industry due to its air pollution potential from combustion and fugitive emissions. The Orange category stands second, following the most polluting industry (Red), based on the Pollution Index (PI). In January this year, the CPCB brought out standard operating procedures for the industry and reiterated the restriction on the import of import waste tyres for TPO production.

“The crumb rubber sector, because it is allowed, imports most of their raw material requirement. While the TPO sector, which forms 80% of the formal recyclers in the country, uses only the tyre waste generated in India. Instead of wishing it away, it is crucial to improve the technology in the TPO sector. Otherwise, who will bear the burden of waste in India?” said Goyal.

“I agree that even till two years ago, the TPO industry was not stable. When the technology started coming in from China in 2010, there were many problems with it. But over a period, we have upgraded it to meet environmental norms. Now, we can claim that TPO is a zero-waste technology. Even the gas emitted is condensed back to generate fuel that runs the plant,” said Goyal.

Bharati Chaturvedi, director of Chintan, disagrees. “A good technology in the laboratory does not mean it functions well in real-time as well. It is like a scientifically designed landfill or a waste-to-energy plant, which is great in theory but not able to perform without creating pollution. If it is such a great idea, why do state pollution control boards keep shutting down TPO units now and then,” said Chaturvedi.

According to her, there needs to be better channelisation of waste tyres between producers and recyclers. Additionally, there needs to be better market mechanisms for the uptake of products recycled from waste tyres. “For instance, the government can make the use of CRMB mandatory in road construction, at least for all Public Works Department roads. The producers need to discuss pricing with the recyclers, the cost of storage and transportation, etc; otherwise, the informal sector is anyway ready to take it up and treat it the way they have been doing it all these years,” she said.

Banner image: Roadside tyre repair shop in Haryana. Tyre production in India rose by 21% in 2022 and a further 6% in 2023. Photo by Shashwat Nagpal/Flickr.