Vehicle Scrapping & ELV EPR Registration

Overview

Vehicle scrapping involves the safe dismantling and recycling of end-of-life vehicles (ELVs) to recover valuable materials and manage hazardous waste in compliance with Indian environmental laws. As per the Vehicle Scrapping Policy, vehicles older than 15 years must undergo fitness testing, and those failing the test must be scrapped at a Registered Vehicle Scrapping Facility (RVSF).

Vehicle Scrapping Process (Brief)

1.  Collection & Transportation
ELVs are collected from owners, bulk consumers, dealerships, or government schemes and transported to authorized facilities.
2.  Pre-Treatment (Depollution)
Documentation and removal of hazardous materials such as fuel, oils, coolants, batteries, and brake fluids.
3.  Dismantling & Segregation
Recovery of reusable parts and segregation of metals, plastics, rubber, glass, and e-waste.
4.  Shredding & Recycling
Vehicle shells are shredded, and materials are separated using advanced technologies for recycling and reuse.

Who Needs Vehicle Scrapping & EPR Compliance Services?

Our services support both mandatory compliance entities and organizations pursuing voluntary sustainability alignment.

1. Authorized Vehicle Scrapping & Dismantling Facilities

Vehicle scrapping and dismantling units must obtain authorization from Transport Authorities and State Pollution Control Boards (SPCBs) and comply with depollution, safety, and waste management norms.
We assist with authorization, CTE/CTO, waste approvals, and operational compliance.

2. Vehicle Manufacturers & Importers (EPR Obligated Entities)

Automobile manufacturers and importers are required to fulfil EPR obligations for ELVs and vehicle-generated waste.
We support EPR registration, target fulfilment through authorized recyclers, and statutory reporting.

3. Automotive Component Manufacturers & Ancillaries

Component manufacturers handling regulated waste streams must ensure proper channelization and EPR compliance.
We provide applicability assessment, recycler linkage, and compliance reporting support.

4. Fleet Operators & Bulk Vehicle Owners

Large fleet owners disposing of vehicles in bulk must route ELVs through authorized scrapping facilities.

Registration Process under RVSF ELV EPR Framework

Step 1: Eligibility Assessment

Identify applicability under ELV Rules, 2025 based on producer status, vehicle category, and annual sales/import data.

Step 2: Account Creation on CPCB ELV Portal

Producer creates login credentials by submitting basic organizational details, PAN, GST, and authorized signatory information.

Step 3: Submission of EPR Registration Application

Upload required documents including:

• Company incorporation documents
• GST & PAN
• Vehicle sales/import data
• Authorization letter
• Undertaking as per CPCB format

Step 4: Section-Wise Data Filing

Detailed disclosure of:

• Vehicle categories placed in market
• Historical and projected sales data
• EPR obligation calculations
• Proposed compliance mechanism

Step 5: Payment of Registration Fees

Fees are paid online as prescribed by CPCB based on applicant category.
Step 6: CPCB Scrutiny & Approval
CPCB reviews the application. Queries, if any, must be responded to within stipulated timelines.

Step 7: Grant of RSVF EPR Registration

Upon approval, the Producer is issued a Certificate of Registration enabling participation in the ELV EPR framework.

Difference between Producer / Importer / Brand Owner & Recycler

1.  Producer (Vehicle Sector) 

A Producer is any entity that introduces vehicles into the market under its own brand name or through import. Under environmental and Extended Producer Responsibility (EPR) regulations, such entities are legally responsible for ensuring proper end-of-life vehicle (ELV) management and regulatory compliance.

A.  Manufacture or Assembly of Vehicles under Own Brand

• An entity qualifies as a Producer if it:
• Manufactures vehicles in its own production facility
• Assembles vehicles from CKD/SKD kits or components
• Sells vehicles under its own registered brand name

B.  Sale of Vehicles under Own Brand (Third-Party Manufacturing)

• An entity is also considered a Producer if it:
• Gets vehicles manufactured by a third-party manufacturer
• Markets and sells them under its own brand
• Holds ownership of the brand and places the product in the market

C.  Importer of Vehicles

• Entities importing vehicles into the country are also categorized as Producers. This includes:
• Import of fully built vehicles (CBU)
• Import of semi-knocked down (SKD) or completely knocked down (CKD) units
• Import of electric vehicles or specialty vehicles
• Importers bear the same environmental and EPR compliance obligations as domestic manufacturers.

Regulatory Responsibilities of a Producer

• Producers are required to:
• Obtain EPR registration with the competent authority
• Maintain records of production, sales, and material composition
• Meet End-of-Life Vehicle (ELV) recycling targets
• Coordinate with Registered Vehicle Scrapping Facilities (RVSFs)
• Submit annual compliance returns and reports
• Ensure environmentally sound disposal and recycling

2.  Recycler / RVSF

A Recycler is an authorized entity engaged in the collection, processing, and recycling of post-consumer waste into reusable raw materials or products. Within the EPR ecosystem, recyclers act as solution providers who help obligated entities fulfil their recycling targets.

Key responsibilities
Recyclers are required to:

• Establish and operate an authorized recycling facility with verified processing capacity
• Procure waste through formal or informal collection channels
• Process waste into recycled material in compliance with environmental norms
• Maintain traceability of input waste and output recycled material
• Upload recycling data and material balance information on the EPR portal
• Generate EPR recycling certificates corresponding to the quantity of waste processed

 

1.  Regulatory Strength

• Ensures statutory compliance under ELV & EPR framework
• Reduces risk of penalties and enforcement action

2.  Operational Efficiency

• Establishes end-to-end vehicle traceability
• Strengthens coordination with authorized RVSFs/recyclers

3.  Financial & Strategic Value

• Minimizes long-term compliance liabilities
• Enables structured compliance cost management

4.  ESG & Market Advantage

• Demonstrates responsible environmental governance
• Improves ESG disclosures and stakeholder confidence

This section provides a complete overview of RVSF Registration (Vahan Portal), CPCB EPR Registration, Roles & Responsibilities of Producers / Importers / Brand Owners / Recyclers, Required Documentation, and Annual Compliance Framework under the Extended Producer Responsibility (EPR) regime for vehicles and End-of-Life Vehicles (ELVs).

1.    RVSF Registration on Vahan Portal

Purpose : Authorization as Registered Vehicle Scrapping Facility and traceability of end-of-life vehicles.
Process
1.    Pre-requisites: Land, infrastructure, dismantling & depollution equipment, environmental approvals (CTE, CTO).
2.    Account creation: Register on Vahan / RVSF portal.
3.    Application filing: Enter facility details, capacity, safety, and traceability system.
4.    Document upload: Land papers, layout, environmental approvals, equipment list, safety certificates.
5.    Inspection: Authority verification and compliance check.
6.    Approval: Grant of RVSF registration and activation on portal.
7.    Post-approval

• Maintain vehicle traceability
• Issue Certificate of Deposit
• Upload scrappage data periodically

2️ CPCB EPR Registration

Purpose: Participation in EPR ecosystem for certificate generation or obligation fulfilment.
Process
1.    Create account on CPCB EPR portal and select entity category.
2.    Submit company, facility, and waste stream details.
3.    Upload documents (CTE, CTO, authorization, machinery, agreements, and photographs).
4.    CPCB scrutiny and clarification submission.
5.    Grant of EPR registration and portal activation.
6.    Upload recycling data and generate / retire certificates.
 

1. Documents required by the Producer (Manufacturer / Assembler)

• Certificate of Incorporation / Partnership deed / Proprietorship proof
• PAN and GST registration
• CIN, MOA & AOA (for companies)
• Authorized signatory ID and authorization letter
• Manufacturing / assembly license
• Plant layout and machinery details
• Vehicle category, model and production capacity details
• Annual sales projections and market placement data
• EPR action plan and ELV management strategy
• Material composition and recyclability declaration
• Agreement / tie-up with RVSFs
• Compliance undertaking and board resolution

2.  Documents for Importers

• Incorporation / Partnership deed, PAN, GST, IEC
• Authorized signatory ID & authorization letter
• Import product list & packaging material declaration
• Bill of entry & customs documents
• Annual import quantity / previous year data
• Brand authorization 
• Recycler / waste processor agreement
• EPR action plan & waste management mechanism
• Undertaking for EPR target compliance

3. Documents required by the Brand Owners

• Incorporation / Partnership deed, PAN, GST
• Trademark / brand ownership proof
• Authorized signatory documents
• Product list with packaging details & material breakup
• Sales data (previous / projected) & distribution details
• EPR plan & waste management strategy
• Recycler / PRO agreement
• Self-declaration on packaging introduction
• Annual target sheet & compliance undertaking

4.  Documents required by the RVSF Facilities

• Incorporation certificate & land ownership / lease documents
• Zoning approval & facility layout plan
• CTE, CTO & hazardous waste authorization 
• Environmental management & pollution control details
• Machinery list, CCTV / IT infrastructure & safety certificates
• Manpower details & SOPs
• Facility photos & geo-tagging
• ELV dismantling / depollution equipment details
• Data traceability system & recycler agreement
• Security and vehicle storage plan

CPCB EPR Annual Compliance & Reporting Framework

The Annual Compliance Framework under Extended Producer Responsibility (EPR) ensures that Producers, Importers, Brand Owners (PIBOs), and RVSF Facilities meet statutory recycling targets, maintain ELV traceability, and comply with regulatory reporting requirements.

1.  Producers / Importers / Brand Owners (PIBO)
Annual Obligations

• Declare total vehicles manufactured, imported, and sold (category-wise)
• Calculate EPR targets based on vehicles placed in the market
• Ensure ELVs are collected and channelized through authorized RVSFs
• Obtain and reconcile recycling / dismantling certificates

Documentation & Records

• Sales and import data with VIN (Vehicle Identification Number) traceability
• Agreements with Registered Vehicle Scrapping Facilities
• ELV collection and recycling certificates
• Material composition and recyclability declarations
• Internal compliance tracking reports  

Regulatory Filing

• Submission of Annual EPR Return on the designated portal
• Upload of supporting documents and certificates
• Renewal / updating of EPR registration as required

2.  Registered Vehicle Scrapping Facilities (RVSF)
Annual Obligations

• Report number of ELVs received and dismantled
• Maintain depollution and hazardous waste management records
• Issue Certificates of Destruction (CoD)
• Report material recovery and dispatch to authorized recyclers

Documentation & Records

• Vehicle receipt and dismantling register
• Hazardous waste disposal records
• Pollution control and environmental monitoring logs
• Worker safety and compliance documentation
• Valid CTO and Hazardous Waste Authorizations

Regulatory Filing

• Submission of Annual Operational Returns
• Renewal of Consent to Operate and related approvals
• Inspection and audit preparedness

For Importers & Brand Owners

• CPCB ELV RSBF EPR Registration

For Manufacturers / RVSF Owners

• SPCB Consent to Establish (CTE) as RVSF
• SPCB Consent to Operate (CTO) as RVSF
• SPCB Hazardous Waste Management Authorization
• CPCB RVSF EPR Registration
• VAHAN Portal Registration