Law Updates

Subject

Summary: The State Pollution Control Board, Odisha , issued Public Notice No. 11208/IND-I-SWM-Misc-152(2025-26) on 23 July 2026 concerning compliance with the Environment Protection (End-of-Life Vehicles) Rules, 2025. The Odisha ELV EPR registration notice 2026 calls upon producers, Registered Vehicle Scrapping Facilities and bulk consumers operating in the state to register through the Central Pollution Control Board's centralised ELV Extended Producer Responsibility portal within three months. It also directs them to make a hard-copy submission to the Odisha Board. The notice is relevant to vehicle manufacturers, assemblers, sellers and importers that fall within the Rules' definition of “producer” registered vehicle scrapping facilities and fleet-owning bulk consumers. It also restates duties for registered vehicle owners, collection centres and automated testing stations. The central Rules were notified by the Ministry of Environment, Forest and Climate Change through S.O. 98(E) dated 6 January 2025 and came into force on 1 April 2025. The Odisha notice does not create the entire ELV framework afresh. It is a state-level compliance and enforcement communication requiring covered entities operating in Odisha to complete registration and follow the existing Rules. Particular Verified details Issuing authority State Pollution Control Board, Odisha, under the Department of Forest, Environment and Climate Change, Government of Odisha Document type Public notice and state-level compliance direction Date of issue 23 July 2026 Date of publication Not expressly specified in the notice the official file is hosted in the Odisha SPCB's July 2026 web directory Governing rules Environment Protection (End-of-Life Vehicles) Rules, 2025 Rules' effective date 1 April 2025 Main entities addressed Producers, Registered Vehicle Scrapping Facilities and bulk consumers operating in Odisha Core direction Register on the centralised online ELV EPR portal and submit a hard copy to the Odisha SPCB Time allowed by notice “Within 3 months” the starting point is not separately stated Indicative date if counted from notice date 23 October 2026, subject to confirmation from the Odisha SPCB Transition period No separate transition period is expressly specified in the notice Portal CPCB EPR ELV portal Enforcement warning Action considered appropriate, including environmental compensation, may be initiated for default under the applicable framework The issue date, the Rules' commencement date and the state registration direction are different dates. Businesses should not treat 23 July 2026 as the commencement of the national Rules those Rules have applied since 1 April 2025. The Regulatory Framework The Ministry of Environment, Forest and Climate Change made the Environment Protection (End-of-Life Vehicles) Rules, 2025 by exercising powers under the Environment (Protection) Act, 1986 and the Environment (Protection) Rules, 1986. The Rules establish an Extended Producer Responsibility system for vehicles and set duties for producers, registered owners, bulk consumers, Registered Vehicle Scrapping Facilities, collection centres, automated testing stations, CPCB, State Boards and state governments. The framework operates alongside the Motor Vehicles Act, 1988, the Central Motor Vehicles Rules, 1989 and the Motor Vehicles (Registration and Functions of Vehicle Scrapping Facility) Rules, 2021. A vehicle becomes an End-of-Life Vehicle according to the vehicle-scrapping framework referred to in the 2025 Rules the Odisha notice does not create a separate definition. CPCB administers the centralised online system and registers producers. State Pollution Control Boards use the same portal to register RVSFs and bulk consumers and receive their returns. The Rules also connect environmental compliance with vehicle fitness testing, authorised scrapping, material recovery, hazardous-waste disposal and EPR certificates. The attached notice is therefore best classified as a public notice covering registration, reporting and enforcement under an existing national framework. It is not an amendment to S.O. 98(E), a new set of rules or an extension of the 1 April 2025 commencement date. Why This Was Implemented? The Odisha notification makes it quite clear that its objective is to notify the regulated parties and get them into compliance with the 2025 Rules. This objective is achieved through the following measures contained in the compliance mechanism: identification of obligated producers, fleet owners, and scrapping facilities transition of registration and returns to one centralized portal association of vehicle fitness data with ELV management channelling of ELVs to either Registered Vehicle Scrapping Facilities or collection points accounting of recovered steel and other material flows certification of extended producer responsibility target attainment using EPR certificates and allowing environmental compensation where specified non-compliance causes environmental or public-health harm. These are purposes of the verified regulatory framework. They should not be read as a claim that every operational outcome has already been achieved. Scope and Applicability The 2025 Rules apply to all types of vehicles covered under the definition of Section 2(28) of the Motor Vehicles Act, 1988, such as electric vehicles, battery-run vehicles, e-rickshaws, and e-carts. Agricultural tractors, agricultural trailers, combine harvesters, and power tillers. The Rules apply to producers, registered vehicle owners, bulk consumers, RVSFs, collection centres, automated testing stations, and entities involved in testing, handling, processing, and scrapping ELVs The Odisha notice's three-month registration direction specifically names producers, RVSFs and bulk consumers operating in Odisha. Stakeholder or product Covered? Relevant condition Main responsibility Producer Yes Manufactures or assembles and sells vehicles under its brand, sells under its brand vehicles made by others, or imports vehicles CPCB registration, EPR targets, annual return and other producer duties RVSF Yes Operates as a Registered Vehicle Scrapping Facility State Board registration, environmentally sound scrapping, records and quarterly returns Bulk consumer Yes Owns more than 100 vehicles, including a State transport undertaking State Board registration, timely ELV deposit and annual return Registered vehicle owner Yes Vehicle is registered in that person's name Fitness testing and ELV deposit within the prescribed period Collection centre Yes Receives or stores ELVs under the applicable framework Safe handling, transfer to RVSF and records Automated testing station Yes Declares vehicles unfit under the Central Motor Vehicles Rules Upload unfit-vehicle details to the portal Electric or battery-operated vehicle Yes Falls within the Rules' vehicle definition Subject to ELV framework, with specified waste streams governed separately Agricultural tractor, agricultural trailer, combine harvester or power tiller No Expressly excluded from the 2025 Rules Not covered by these Rules Waste batteries, plastic packaging, waste tyres, used oil and e-waste are carved out to the extent that their respective waste-management rules govern them. This does not remove the vehicle itself from ELV regulation it separates specified waste streams into their applicable regimes. Implementation Timeline and Compliance Calendar Event or requirement Date or frequency Affected entity Required action National notification issued 6 January 2025 All covered stakeholders Review S.O. 98(E) and determine applicability ELV Rules commenced 1 April 2025 All covered stakeholders Comply with the 2025 Rules Current-year EPR obligation declaration By 30 April each year Producer Declare current-year EPR obligation to CPCB Producer annual return By 30 June each year Producer File Form 1 for the previous financial year Bulk-consumer annual return On or before 30 June each year Bulk consumer File Form 2 for the previous financial year RVSF quarterly return By the 30th day of the month following the previous quarter RVSF File Form 3 and keep supporting records Odisha public notice issued 23 July 2026 Entities operating in Odisha Review registration and filing status State notice registration period Within three months Producers, RVSFs and bulk consumers in Odisha Complete portal registration and hard-copy submission Indicative three-month date 23 October 2026, if counted from 23 July 2026 Same entities Treat as a planning date and confirm with Odisha SPCB Deposit of an ELV Within 180 days from the date the vehicle becomes an ELV Registered owner or bulk consumer Deposit at an eligible sales outlet, collection centre or RVSF The key point that comes up in relation to Odisha specifically is that of three months. Since there is no separate mention of the date from which the period will commence, it would be better if the entities get a written clarification of the same. What Has Changed? The national obligations have existed since the Rules came into force on 1 April 2025. The main development is the Odisha Board's state-level direction calling for registration and a hard-copy submission within three months, backed by an enforcement warning. Compliance area Earlier governing position Odisha notice position Practical meaning Producer registration Producer applies in Form 4 to CPCB through the portal Producers operating in Odisha are told to register within three months Unregistered producers should regularise their status promptly RVSF registration RVSF applies in Form 5 to the State Board through the portal RVSFs operating in Odisha are told to register within three months Portal and state-level registration status should be checked Bulk-consumer registration Bulk consumer applies in Form 6 to the State Board through the portal Bulk consumers operating in Odisha are told to register within three months Fleet ownership must be assessed against the “more than 100 vehicles” threshold Physical submission Not detailed in the notice's summary of the central Rules Hard-copy submission to Odisha SPCB is directed The exact hard-copy contents and procedure require confirmation Enforcement The Rules allow registration action, inspection, audit and environmental compensation in specified cases Odisha SPCB warns that appropriate action may be initiated for default Evidence of registration, filings and operational compliance should be organised The notice should not be described as creating a new nationwide EPR regime or changing the national EPR target schedule. Who Must Register on the CPCB ELV EPR Portal? The Odisha notice names three categories: producers, Registered Vehicle Scrapping Facilities, and bulk consumers operating in Odisha. The Rules use one central portal but allocate the registering authority differently. Entity Application form under the Rules Registering authority Portal route Producer Form 4 Central Pollution Control Board Centralised online portal Registered Vehicle Scrapping Facility Form 5 Concerned State Pollution Control Board Centralised online portal Bulk consumer Form 6 Concerned State Pollution Control Board Centralised online portal A producer includes an entity that manufactures or assembles and sells vehicles under its own brand, sells under its brand vehicles produced by another manufacturer or supplier, or imports vehicles. A bulk consumer means a consumer owning more than 100 vehicles and includes a State transport undertaking. The Rules provide for issuance of registration certificates within 15 days of receipt of the application. Registration remains valid until suspended or cancelled. These provisions do not remove the need to answer portal objections or supply accurate information. State-Specific Registration Direction and Deadline The notification is to those obligated entities that have been “operating in the State of Odisha” and must register in three months. It does not provide any additional separate date for its final period and does not state anything about being “three months from the date of this notification.” For internal planning purposes, companies can take three months from 23 July 2026, making the tentative date 23 October 2026. As implied in the notice, when this period begins, the date needs to be confirmed with the Odisha SPCB. It would not be wise to postpone the overdue registration process. Hard-Copy Submission to the State Pollution Control Board The notice requires a hard-copy submission to the State Pollution Control Board, Odisha, in addition to portal registration. It does not expressly specify: whether the hard copy must contain the full application, portal acknowledgement, registration certificate or another record the supporting-document list whether producers and State Board registrants must submit different sets the physical submission address or permitted delivery method whether an acknowledgement will be issued or whether the hard copy must be submitted before, with or after portal approval. A safe approach is to obtain written procedural confirmation from the Board and retain proof of dispatch or receipt. Businesses should not rely on a generic document checklist that has not been issued for this notice. Stakeholder-Wise ELV Compliance Matrix Stakeholder Registration or portal duty Operational duty Return or record duty Deadline or frequency Main compliance risk Producer Register with CPCB in Form 4 Meet EPR targets use registered entities to support collection Form 1 annual return and current-year obligation declaration 30 June and 30 April respectively EPR shortfall or engagement with unregistered entities RVSF Register with State Board in Form 5 Depollute, dismantle, segregate, recover and route residues lawfully Form 3 quarterly return and material records 30th day of next month after each quarter Incomplete mass balance or unlawful downstream transfer Bulk consumer Register with State Board in Form 6 Test vehicles and deposit ELVs within 180 days Form 2 annual return On or before 30 June Threshold misclassification or retained ELVs Registered owner No ELV portal registration is required merely because of ownership Test and deposit ELV within 180 days Keep practical transfer evidence Vehicle-specific Retaining an ELV beyond permitted period Collection centre No separate portal-registration duty stated in this notice Collect, store safely and send ELVs to RVSF Receipt, transfer and handling records Ongoing Poor traceability or unsafe storage Automated testing station Upload unfit vehicle details Conduct functions under vehicle-testing framework Portal data As vehicles are declared unfit Missing or inaccurate uploads Responsibilities of Vehicle Owners Every registered owner and bulk consumer must ensure that the vehicle is tested in accordance with section 56 of the Motor Vehicles Act, 1988 and rule 52 of the Central Motor Vehicles Rules, 1989. Once the vehicle becomes an ELV under the referenced vehicle-scrapping framework, it must enter an authorised collection or scrapping route. The owner may deposit the ELV at a producer's designated sales outlet, a designated collection centre or an RVSF. The Rules do not require an ordinary registered owner to register on the ELV EPR portal merely because the person owns a vehicle. Responsibilities of Collection Centres Collection centres must collect and store ELVs, handle them in an environmentally sound manner and send them to an RVSF. They must keep records of ELVs received, ELVs sent to an RVSF and the manner in which those vehicles were handled. The Odisha notice does not create a separate collection-centre registration process. A collection centre should nevertheless verify its legal relationship with the producer or RVSF and maintain a clear vehicle-level chain of custody. Role of Automated Testing Stations An automated testing station must upload details of vehicles declared unfit under rule 182 of the Central Motor Vehicles Rules, 1989 to the centralised portal. Upload may occur directly or by linking the Central Government's electronic portal established under rule 181(1). This reporting function helps connect fitness outcomes with ELV compliance. It does not authorise the testing station to scrap vehicles unless the station separately holds the required status and approvals. Obligations of Bulk Consumers A bulk consumer owns more than 100 vehicles the threshold is not “100 or more.” State transport undertakings are included. A covered fleet owner must: obtain registration from the State Board through the centralised online portal ensure vehicles undergo the prescribed fitness testing deposit each ELV at an eligible destination within 180 days of it becoming an ELV avoid retaining the ELV beyond that period and file Form 2 on or before 30 June for the previous financial year. Form 2 seeks fleet and ELV information, including vehicles registered, specified age-related details, fit vehicles, unfit or end-of-life vehicles, and vehicles deposited for scrapping. Fleet data should therefore be reconciled before filing. Producer Extended Producer Responsibility and Scrapping Targets Producers must fulfil EPR for vehicles introduced in the domestic market, including vehicles put to self-use. They must meet category-specific scrapping targets in the Schedule and fulfil EPR through certificates generated by their own RVSF or another qualifying RVSF. For financial year 2025-26, the Schedule sets a minimum target of 8% of the steel used in non-transport vehicles placed in the market in 2005-06 and 8% of the steel used in transport vehicles placed in the market in 2010-11. For 2026-27, the minimum remains 8%, using 2006-07 as the base year for non-transport vehicles and 2011-12 for transport vehicles. Later years use the relevant historical base years and higher percentages according to the Schedule. Up to 30% of an annual target may be carried forward for compliance over the next four years. EPR target calculation under these Rules concerns steel scrapping. Batteries, waste tyres and used oil remain governed under their respective waste-management frameworks. Producers should not use that target basis to ignore other ELV material-handling duties. Producer Take-Back, Buy-Back, Deposit-Refund and Awareness Measures The Rules require producers to take measures that encourage safe ELV deposit. They may deploy a buy-back scheme, deposit-refund scheme or another arrangement and may designate a registered entity to help fulfil EPR. Producers must also arrange to receive ELVs through designated collection centres, including sales outlets publish the list on their website and at prominent places at sales and service centres provide the list to CPCB through the portal and conduct awareness campaigns. The Rules give flexibility in scheme design but do not make one named scheme the only permitted route. Annual Returns for Producers and Bulk Consumers Filer Form Recipient or portal route Frequency Due date Main information Producer Form 1 Centralised portal to CPCB Annual 30 June for previous financial year Vehicle numbers and types, steel weight, self-use vehicles and EPR fulfilment Bulk consumer Form 2 Centralised portal to State Board Annual On or before 30 June for the previous financial year Fleet details and ELVs deposited for scrapping The producer must separately declare the current year's EPR obligation by 30 April of the same year. Registration does not replace return filing, and a return does not cure a missing registration. Responsibilities of Registered Vehicle Scrapping Facilities An RVSF must receive unfit vehicles and ELVs and undertake treatment, depollution, dismantling, segregation and scrapping according to applicable law. It must register with the concerned State Board in Form 5 and maintain complete material and destination records. Environmentally Sound Depollution, Dismantling and Material Handling The Rules require treatment involving depollution and collection of liquids, gases, catalysts, mercury-containing parts, batteries and hazardous waste. They also require dismantling, segregation, safe storage of different waste categories in separate bins, and recycling or refurbishment of materials such as plastic, metals, tyres, catalytic converters, magnets, batteries and e-waste. Separate waste regimes continue to apply to specified materials. RVSFs should map each output stream to the correct authorised recipient and retain evidence of quantity and handover. Downstream Transfer to Recyclers, Refurbishers and Co-Processors Where the RVSF does not have its own recycling or refurbishing facility, recovered and segregated materials must be sent to registered recyclers or refurbishers or to co-processors for recycling and reuse. The facility should verify the status of each downstream party rather than rely only on a commercial invoice. Disposal of Hazardous and Non-Recyclable Residues Non-recyclable or non-refurbishable material and non-utilisable hazardous material must be sent to a Common Hazardous Waste Treatment, Storage and Disposal Facility authorised under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The Odisha notice does not set storage periods, transport-document requirements or treatment charges. Those details must be determined from the applicable waste law, authorisations and official directions. Generation, Issuance, Exchange and Purchase of EPR Certificates Stage Responsible entity Verified basis or action Material recovery RVSF Process ELVs and account for steel and other materials Certificate generation basis RVSF data Weight of steel scrap generated, measured in kilograms Certificate issuance CPCB Weight of steel scrap generated, measured in kilograms Purchase Producer Purchase through the portal within current and carried obligations Adjustment Portal mechanism Apply certificates first to earlier obligations Reporting RVSF Record certificate transactions and include them in quarterly returns A used certificate cannot be exchanged again, and a certificate purchased by one producer cannot be transferred to another producer. Certificates generated by RVSFs are valid for five years. Generation is conditional on accounting for other ELV materials and environmentally sound disposal of non-recoverable or hazardous residues. Quarterly Returns for Registered Vehicle Scrapping Facilities An RVSF must file Form 3 on the centralised online portal to the State Board by the 30th day of the month following the previous quarter. The return covers the weight of ELVs received and category-wise material recycled, refurbished, transferred for recycling or refurbishment, processed, or sent to a Common Hazardous Waste Treatment, Storage and Disposal Facility. The facility must also keep supporting records. Portal figures should reconcile with vehicle receipts, weighment records, downstream acknowledgements, waste manifests where applicable, and EPR certificate transactions. Record-Keeping, Portal Reporting and Data Linkage Stakeholder Record or data Destination Timing Producer Market placement, steel weight, self-use vehicles, EPR fulfilment CPCB portal Annual and as obligation declarations require Bulk consumer Fleet, fitness status and ELVs deposited State Board through portal Annual RVSF ELV receipts, output weights, downstream transfers, disposal and certificates State Board through portal Quarterly and ongoing records Collection centre ELVs received, handled and sent to RVSF Internal record produce when required Ongoing Automated testing station Vehicles declared unfit Centralised portal directly or through linkage On declaration or system process Recommended internal controls include portal acknowledgement files, controlled spreadsheets or system records, due-date alerts, authorised-signatory review and periodic reconciliation. These controls support compliance but do not replace the forms prescribed by the Rules. Documents and Records Required Documents or records required are as follows: Form 4 registration application Form 5 registration application Form 6 registration application Form 1 annual return Form 2 annual return Form 3 quarterly return ELV receipt and transfer records Downstream handover records Portal acknowledgements and hard-copy receipt The exact hard-copy pack required by the Odisha notice is not expressly specified. Businesses should not assume this table is itself the Board's hard-copy checklist. Impact on Businesses Vehicle Producers and Importers Producers need clean historical data on vehicle placement and steel weight, a valid portal registration, current-year obligation declarations, annual returns, and enough eligible certificates to meet targets. Procurement and EHS teams must ensure that ELV partners are registered. Registered Vehicle Scrapping Facilities RVSFs face the most detailed operational burden. Vehicle receipt, depollution, material segregation, downstream transfer, hazardous-residue disposal, quarterly reporting, and certificate generation must form one reconcilable record trail. Bulk Consumers and Fleet Operators Fleet owners must first test whether they cross the “more than 100 vehicles” threshold. Covered fleets require State Board registration, vehicle-level fitness and ELV tracking, timely deposit, and an annual Form 2 return. Collection Centres and Testing Stations Collection centres need reliable receipt, storage and transfer controls. Automated testing stations need accurate portal uploads for vehicles declared unfit. Weak data at either point may affect the chain of custody downstream. Challenges and Cost Implications The notice does not prescribe fees or quote compliance costs. Likely cost drivers include portal preparation, historical data cleansing, weighment and material records, authorised downstream services, safe storage, staff time, audit readiness and professional support where needed. Short-term challenges may include identifying the correct entity category, resolving portal data gaps, compiling hard-copy records and reconciling past returns. Ongoing burden will centre on vehicle and material traceability, timely filings and vendor verification. MSMEs operating RVSFs may feel these system and staffing costs more sharply, though the legal duties do not disappear because an entity is small. Benefits for Businesses Effective compliance can provide practical benefits without guaranteeing a commercial outcome: clearer chain of custody for retired vehicles lower risk of dealing with informal or unregistered scrapping channels better material and hazardous-waste accountability stronger audit evidence orderly EPR certificate generation and purchase better fleet retirement data and improved coordination across legal, EHS, operations, procurement and finance teams. Is This a Right Decision or Additional Burden? The direction supports an established environmental objective: ELVs should enter traceable facilities capable of depollution, recovery, and safe residue disposal. Central portal data can help regulators compare vehicle intake, recovered material, returns, and producer obligations. The additional state-level hard-copy direction creates an administrative burden, especially because the required contents and process are not stated. A clear checklist, filing channel, and unambiguous final date would reduce avoidable uncertainty. On balance, registration enforcement is consistent with the Rules, while procedural clarification would make implementation more practical. Business Opportunities Created The framework can create legitimate demand for authorised scrapping capacity, collection networks, material recovery, recycling, refurbishment, hazardous-waste services, compliance systems, portal support and independent record review. Producers may also need better vehicle and steel-data architecture to forecast obligations. These are likely commercial implications, not assured revenue projections. Entry into any activity remains subject to the applicable registration, authorisation, technical and environmental requirements. Business and Regulatory Perspective From a regulatory perspective, registration makes the obligated population visible and enables inspections, returns and EPR certificate controls. From a business perspective, the harder task is not clicking “register” it is building data and operating controls that remain consistent across the portal, physical records and actual ELV movement. The notice therefore deserves attention even from an entity that has already started registration. Businesses should verify whether the registration is active, whether the correct authority is reflected, whether returns are current, and whether the Odisha hard-copy direction has been met. Common Mistakes or Risks to Avoid Treating every owner of 100 vehicles as a bulk consumer when the definition says more than 100. Counting the 180 days from the Odisha notice rather than from the date a vehicle becomes an ELV. Assuming producer registration with CPCB removes the Odisha hard-copy direction. Filing a registration application but overlooking annual or quarterly returns. Using an unregistered entity for ELV scrapping or EPR fulfilment. Treating recovered steel as the only waste stream requiring control. Reporting certificate quantities that do not reconcile with steel recovery and other material records. Inventing a hard-copy document pack instead of obtaining official clarification. Practical Readiness Plan for Producers, RVSFs and Bulk Consumers Conduct an applicability review. Make sure the legal entity, function, vehicle type, fleet size, and Odisha operation linkages are accurate. Verify registration validity. Ensure that there is registration reflected on the portal and whether objections are still pending. Respond to Odisha filing. Get the checklist from the Board in the original and physical copy and file it. Resolve return loopholes. Conduct a review of Form 1, Form 2, or Form 3 filing and current year declarations by the producers. Align operational proof. Align vehicles, dates, weights, destination of materials, and certificates. Audit vendor controls. Ensure that the scrapping and downstream entities have the requisite status for the activity. Get ready for consideration. Have all your registrations, returns, acknowledgements, and operating proof in place. How Can Corpseed Help? Corpseed can support affected businesses with ELV EPR registration services and related compliance work based on the entity's actual role and records. ELV Rules applicability assessment for producers, importers, RVSFs and fleet operators CPCB ELV EPR portal registration support Form 4, Form 5 and Form 6 application-document review Odisha SPCB hard-copy submission coordination after procedural confirmation Form 1, Form 2 and Form 3 filing support ELV compliance-gap and record-traceability assessment EPR certificate and registered-vendor document review Ongoing environmental compliance calendar and audit-readiness support The scope should be fixed after checking the entity category, registration status, portal records, and outstanding filings. Corpseed assists with preparation and coordination but cannot guarantee registration, certificate issuance, regulatory acceptance, or a fixed authority timeline. Businesses covered by the Odisha notice may contact Corpseed for an applicability and filing-status review before completing the portal and physical-submission process.