End-of-Life Vehicles and Other Emerging Waste Rules: ELV Rules, 2025, Contaminated Sites Rules, 2025, Fly Ash, Ecomark and Keeping Notes Updated

Indian waste law has moved fast since 2022. After plastics, e-waste, batteries, tyres and used oil, the extended producer responsibility model has now reached old vehicles; a statutory procedure for cleaning up contaminated land has arrived; fly ash from coal power plants must be fully utilised on a polluter pays basis; and the Ecomark scheme for green products has been given a statutory footing. This note covers the Environment Protection (End-of-Life Vehicles) Rules, 2025, the Environment Protection (Management of Contaminated Sites) Rules, 2025, the fly ash notification, the Ecomark Rules, 2024, and a method for keeping these fast-changing notes up to date.

1. The Environment Protection (End-of-Life Vehicles) Rules, 2025

India has tens of lakhs of vehicles reaching the end of their lives every year. Most are dismantled in informal yards such as Mayapuri in Delhi, where oils, coolants, lead, mercury switches and refrigerant gases are released into soil and air, and where valuable steel and aluminium are poorly recovered. The Vehicle Scrappage Policy (2021) and the Motor Vehicles (Registration and Functions of Vehicle Scrapping Facility) Rules, 2021 created registered scrapping facilities under the Motor Vehicles Act. The Environment Protection (End-of-Life Vehicles) Rules, 2025, notified on 6 January 2025 under the Environment (Protection) Act and in force from 1 April 2025, add an environmental layer: extended producer responsibility on vehicle manufacturers and importers, a CPCB portal, EPR certificates based on recovered steel, and environmental compensation.

1.1 Application and meaning of end-of-life vehicle

The Rules apply to producers, registered owners and bulk consumers of vehicles, registered vehicle scrapping facilities, collection centres, automated testing stations and government bodies, and to all motor vehicles including electric and hybrid vehicles. They do not apply to agricultural tractors, power tillers and combine harvesters, and do not govern components already regulated by other rules (batteries, plastic packaging, tyres, used oil and e-waste), which continue to follow their own EPR regimes.

An end-of-life vehicle is a vehicle that: is no longer validly registered; has been declared unfit through an automated testing station; has had its registration cancelled under Chapter IV of the Motor Vehicles Act, 1988 or by an order of a court; or has been self-declared by its registered owner as waste. Vehicles impounded and not claimed, or abandoned, may also be treated as end-of-life vehicles through the prescribed process.

1.2 Producer responsibilities for vehicles

A producer is a manufacturer or importer of vehicles who places them on the Indian market, whether under its own brand or otherwise. Producers must register on the CPCB's centralised portal; declare the quantity of vehicles and the steel used in them for past years; meet annual EPR targets for scrapping; encourage owners to deposit end-of-life vehicles at registered facilities, including through their dealers and collection centres; follow design norms for recyclability and reduction of hazardous substances (the automotive standard AIS-129); create awareness; and file annual returns.

1.3 Extended producer responsibility and EPR certificates

The EPR target is expressed as a percentage of the weight of steel in vehicles the producer placed on the market in a base year: for 2025-26, eight per cent of the steel in vehicles sold in 2005-06 (non-transport vehicles) and 2010-11 (transport vehicles), rising in stages to thirteen per cent (2030-31 to 2034-35) and eighteen per cent from 2035-36. When a registered vehicle scrapping facility scraps a vehicle, the portal generates EPR certificates in its name for the steel recovered (one kilogram of certificate for one kilogram of steel scrap). Producers buy these certificates to meet their targets. A March 2026 amendment removed the earlier flexibility that allowed certain other steel scrap to count, so that only steel actually recovered from scrapped vehicles earns certificates. Industry reports suggest that in 2025-26 only about a third of the required scrapping took place, and manufacturers have sought a phased relaxation.

1.4 Vehicle owner responsibilities

The registered owner of an end-of-life vehicle must deposit it at a registered vehicle scrapping facility or a designated collection centre within one hundred and eighty days of its becoming an end-of-life vehicle, and may not sell or hand it over to any unregistered dismantler. Bulk consumers (fleet owners, including government departments with large fleets) have similar obligations and must file returns. The owner receives a certificate of deposit, which entitles it to concessions such as a rebate in motor vehicle tax and registration fees on a new vehicle under the Motor Vehicles rules.

1.5 Registered vehicle scrapping facilities and scrapping certificates

A registered vehicle scrapping facility (RVSF) is a facility registered under the Motor Vehicles (Registration and Functions of Vehicle Scrapping Facility) Rules, 2021 and on the CPCB portal. It must: hold consent under the Air and Water Acts and authorisation under the Hazardous Waste Rules; carry out depollution first (removing fuel, oils, coolants, refrigerant gases, batteries, airbags, mercury switches and tyres); dismantle and segregate materials; send each component to the appropriate registered recycler (batteries to battery recyclers, tyres to tyre recyclers, electronics to e-waste recyclers, oil to re-refiners); record the weight of steel and other materials; issue the certificate of deposit and the certificate of vehicle scrapping; and generate EPR certificates on the portal.

1.6 Recycling of vehicle materials

A vehicle is mostly steel and iron, with aluminium, copper, plastics, rubber, glass and, in modern vehicles, electronics and rare earth magnets. Environmentally sound scrapping recovers these materials, reducing demand for iron ore and coking coal and lowering emissions from steelmaking. The EPR model ties the producer's obligation to the steel recovered, giving steel makers a steady supply of quality scrap.

1.7 Electric vehicles under the ELV Rules

Electric and hybrid vehicles are expressly covered. The body, chassis and other parts of an electric vehicle are managed under the ELV Rules, but the traction battery must be removed safely by the RVSF and handed over under the Battery Waste Management Rules, 2022, where it may be refurbished for second-life use or recycled. Electronic control units and chargers fall under the E-Waste Rules. Electric vehicles therefore engage three EPR regimes at once.

1.8 End-of-life vehicles versus battery waste

The distinction is one of object and obligation. The ELV Rules deal with the vehicle as a whole: the producer is the vehicle manufacturer, the target is based on steel, and certificates are generated by RVSFs. The Battery Rules deal with the battery: the producer is the battery producer (or the vehicle maker that places batteries on the market), targets are based on battery weight and chemistry, and certificates are generated by battery recyclers and refurbishers. A vehicle maker may thus hold two separate EPR obligations. The ELV Rules expressly exclude batteries to prevent double counting.

2. The Environment Protection (Management of Contaminated Sites) Rules, 2025

India has hundreds of sites where soil and groundwater have been poisoned by chromium, lead, mercury, pesticides, solvents and industrial sludge, often from units that have closed. The Bichhri case and the Union Carbide site at Bhopal are the best known. Until 2025 there was no statutory procedure for finding, assessing and cleaning such sites. The Environment Protection (Management of Contaminated Sites) Rules, 2025 (S.O. 3401(E), 24 July 2025) fill that gap.

2.1 Identification of contaminated sites

District administrations report suspected contaminated sites to the State Pollution Control Board every six months, and sites may also be reported by regulators and the public. Suspected sites are entered in an inventory on a centralised online portal. The Rules do not apply to contamination by radioactive waste, mining operations, marine oil spills and authorised solid waste dumpsites, which are covered by other laws, although contamination beyond the prescribed levels can bring them within the Rules.

2.2 Investigation of contaminated sites

The State Board (or a reference organisation, an expert institution notified for the purpose) carries out a preliminary assessment within ninety days, followed by a detailed investigation within a further ninety days, with public notice at each stage. A site is declared contaminated if the concentration of any of the 189 hazardous substances listed exceeds the prescribed response levels (Schedule I). Details of declared sites are made public, and access to the site may be restricted.

2.3 Remediation and polluter liability

Within ninety days of declaration, the State Board identifies the responsible person, which may include not only the original polluter but also a subsequent owner of the land in certain cases. The reference organisation prepares a site-specific remediation plan with remediation targets, and the responsible person must carry out and pay for remediation, with financial assurance. The Rules apply strict liability in line with the polluter pays principle. Where the polluter cannot be traced or cannot pay, the site is an orphan site, and the Central and State Governments share the cost in prescribed proportions, while retaining the right to recover it later. Where contamination causes death, injury or environmental damage, criminal liability arises under the Bharatiya Nyaya Sanhita, 2023, in addition to environmental compensation.

2.4 Environmental damage assessment and land restoration

Environmental damage assessment means quantifying the harm to soil, groundwater, ecosystems and human health, and the cost of restoring them. The detailed investigation measures the extent and depth of contamination and the exposure pathways, and the remediation plan sets targets for restoring the land to a safe condition for its intended use. Contaminated land restoration may involve excavation and secure disposal, soil washing, stabilisation, bioremediation, pump-and-treat of groundwater, and capping, followed by monitoring until targets are met. A Central Remediation Committee oversees implementation nationally, meeting at least twice a year, with corresponding State committees.

3. Fly Ash Utilisation Notification

Coal-based thermal power plants produce over two hundred and fifty million tonnes of ash each year. Stored in ash ponds, it blows as dust, leaches heavy metals into groundwater, and has caused dyke breaches that buried fields and villages (as at Singrauli in 2020). Fly ash is also a resource for bricks, cement, concrete, road embankments and mine filling.

The first fly ash notification of 14 September 1999, issued under the Environment (Protection) Act and amended in 2003, 2009 and 2016, required power plants to supply ash and users within specified distances to use ash-based products. It was replaced by the notification of 31 December 2021 (in force from 1 April 2022), which adopts a polluter pays approach:

• every coal or lignite thermal power plant must ensure one hundred per cent utilisation of ash generated in a year, assessed over a three-year cycle with minimum annual levels;
• legacy ash accumulated in ponds must be utilised progressively over ten years;
• environmental compensation of Rs 1,000 per tonne of unutilised ash, collected by the CPCB and used for safe disposal and utilisation of ash;
• construction agencies, road builders and brick kilns within prescribed distances (generally three hundred kilometres) must use ash or ash-based products, with transport costs borne by the power plant up to specified limits; and
• permitted uses include bricks and blocks, cement and concrete, roads and flyovers, filling of mine voids, reclamation of low-lying areas, and agriculture under prescribed conditions.

3.1 Ash disposal and utilisation

Ash that is not immediately used must be stored in lined ash ponds with stable dykes, with dust suppression and groundwater monitoring. The NGT has repeatedly penalised power plants for dyke breaches and ash discharges into rivers and has monitored compliance with utilisation targets. The 2021 notification has been amended since (including on timelines and mine void filling), so current thresholds should be checked against the latest version.

4. Ecomark Rules, 2024 and Environmental Labelling

Environmental labelling gives consumers reliable information about the environmental performance of products, so that purchasing decisions reward cleaner production. Labels may be third-party certified (like Ecomark), self-declared claims (such as 'recyclable'), or environmental product declarations. Unverified claims lead to greenwashing, which the Central Consumer Protection Authority's Guidelines for Prevention and Regulation of Greenwashing or Misleading Environmental Claims, 2024 now address under consumer protection law.

India's Ecomark scheme dates from a 1991 government resolution, but it saw little uptake. The Ecomark Rules, 2024, notified on 26 September 2024 under the Environment (Protection) Act as part of the Mission LiFE (Lifestyle for Environment) initiative, give it a statutory basis. The Rules: provide for the Ecomark label for products that meet prescribed criteria of lower energy consumption, resource efficiency, reduced pollution, recyclability and durability; make the CPCB the administering body, with the Bureau of Indian Standards involved in certification; set up a steering committee and technical committees to frame product criteria; require accurate labelling and prohibit misleading environmental claims; and allow the licence to be suspended or cancelled for misuse. The aim is to align consumer choice with the circular economy and to support green public procurement.

5. Draft and Emerging Waste Rules: Keeping Notes Updated

Environmental rules under the Environment (Protection) Act change frequently, and judiciary examinations increasingly ask about recent changes. The table below lists the major replacements and additions since 2022:

A practical method for keeping notes current:

1. Distinguish draft from final. Under Rule 5(3) of the Environment (Protection) Rules, 1986, draft notifications are published for sixty days of public comment. A draft is not law; note it as 'proposed'.
2. Note three dates for every rule: date of notification, date of commencement, and date of any staggered obligations (targets often start a year or two later).
3. Track the replacement chain (for example, 2000, 2016, 2026 for solid waste) and note what the new rule changes, since examiners ask about the shift.
4. Check primary sources: the e-Gazette, the Ministry of Environment's notifications page, CPCB EPR portals, and PIB releases; use secondary summaries only to locate the notification.
5. Watch the courts: the NGT and High Courts often stay or read down provisions (as with EPR certificate price bands), and the Supreme Court may revive or strike down notifications.
6. Review every six months: revise each note with a dated 'last updated' line.

6. Critical Appraisal

The new rules extend producer responsibility and polluter pays in logical directions. The ELV Rules link vehicle scrapping to recovery of steel and to other waste regimes, though the targets are proving hard to meet without a supply of scrapped vehicles and a crackdown on informal dismantlers. The Contaminated Sites Rules create, for the first time, a statutory route from identification to remediation, but their success depends on State Board capacity and on the cost-sharing for orphan sites. The fly ash regime has improved utilisation but legacy ash remains large. The Ecomark Rules and greenwashing guidelines address consumer information, but uptake by industry is still limited. For aspirants, the lesson is that the EPR and polluter pays framework now runs across nearly every waste stream.

7. Related Topics and Provisions