India’s End-of-Life Vehicle (ELV) industry is in the crisis phase. Though the National Vehicle Scrappage Policy that has been proposed in 2021 has greatly contributed to the formalization of the process of demountable recycling in the country, the future of the system will be defined not in the number of facilities, but in objects that are disposed of in a responsible manner.
These ELV sessions at the MRAI Conference featured policymakers, dealers, recyclers, tech service providers, as well as international experts gathering to address this topic in detail. These two parts of the ELVs discussion featured the progression from the intent or the bottlenecks to the technical or environmental demands required.
Policy Progress and Scale: A System Taking Shape
After the scrappage scheme came into effect, significant progress has been noted by the country regarding the construction of formal ELV infrastructure. Estimates suggested that 60-70 'Registered Vehicle Scrapping Facilities,' also known as RVSFs, will be established over the next five years. However, the trend has clearly exceeded the anticipated levels of ELV facility construction in the country, as more than 192 such facilities across 24-25 states have been authorized since the scheme came into effect.
Additionally, in volume terms, this transition towards a more formal recycling system is also now in place. Around 3.8 lakh vehicles have been scrapped through this route, from 2021 onwards, indicating that more and more consumers, as well as original equipment manufacturers and governments, are becoming part of this trend. The incentives of road tax concessions, registration fees, and a Certificate of Deposit (CoD) were significant in facilitating this.
However, the more important point remains to be stressed by the same individuals: this alone is not enough; without the identification, enforcement, and management of these ELVs in full swing, there remains the very real threat of continued high volumes of vehicles finding their way into informal dismantle networks.
Channelisation: The Weakest Link in the ELV Chain
Also, one of the core issues that were being debated in the policy sphere was that of ELV channelisation, which relates to the vehicle recyclers that have ended up at the end of their vehicle lifespan.
Mr. Kartick V. Nagpal, President, Rosmerta Group, while addressing this session, stated that channelisation is perhaps the single most critical ‘bottleneck’ within this system. Though there has been rapid escalation of RVSF capabilities, infrastructure like ATS, designed to filter out environmentally unfit vehicles, remains patchily up across various States. In this way, there is a regulatory blind spot when these vehicles remain operative on paper or dismantled on road without adequate environmental safeguards.
“The biggest bottleneck today is ELV channelisation,” Mr. Nagpal noted. “Infrastructure has grown, but the system to consistently direct end-of-life vehicles into authorised facilities is still weak.”
This gap has direct consequences. Informal dismantling not only undercuts compliant operators but also undermines the environmental objectives of the scrappage policy, leading to pollution, illegal resale of restricted parts, and loss of material traceability.
Dealers and Consumers: The Market Interface
Mr. Sharvik Shah, Chairperson, Federation of Automobile Dealers Associations (FADA) identified the position automotive dealers have in the ELVs lifecycle from a dealership perspective. They have regular engagement with ELVs through the various lifecycle stages: purchase, servicing, and replacement. Nevertheless, Mr. Shah found that informal systems still attract vehicle owners through immediate cash rewards, even in cases where documentation is absent. While long-term benefits of regulation and SCR are available in formality, incentives in form of visibility still pose a challenge as a disadvantage.
“Dealers can play a crucial role in ELV identification and consumer awareness,” he said, “but unless the value proposition of formal scrappage is clear to customers, informal channels will continue to dominate.”
Environmental Risk: Why ELVs Must Flow to Responsible RVSFs
The technical heart of the session came from Mr. Kenchiro Yajima, CEO of Recycling Services (MSDI), who presented MSTI’s framework for advanced recycling and circular economy integration.
His presentation effectively demonstrated the reasons to prefer that ELVs should only be processed through RVSFs that are equipped and/or authorised to do so.
Conversely, improper dismantling, he added, causes a direct environmental pollution phenomenon. During improper dismantling, engine oil, coolant, among other fluids, leak into the soil, thereby causing groundwater contamination as well as damaging local ecosystems as a result. Further, restricted parts, like engines, inevitably evade destruction and get back into circulation illegally.
Contrary to that, authorized RVSFs are supposed to avert these results through controlled depollution, segregation, and documentation.
At the core of this approach are the core responsibilities of RVSFs, which include:
- Preventing environmental pollution through proper dismantling and depollution
- Ensuring restricted parts are destroyed and not resold illegally
- Promoting circular economy principles through material segregation and sale
- Maintaining complete documentation, including challan clearance and traceability
Mr. Yajima emphasised that ELV processing is not simply a recycling activity, but an environmental risk-management function.
From ELV Intake to Circular Economy: The Advanced Recycling Model
Building on this foundation, Mr. Yajima described MSTI’s advanced recycling and circular economy plans for RVSFs as a key intermediary between vehicle retirement and sustainable manufacturing.
The lifecycle begins with ELV receipt, which is subsequently processed in the compliant RVSF. Then, materials are passed through car-to-car processing: here, materials are recycled with a high level of purity.
An important feature of this process is precision dismantling. Contrary to cascading recycling methods, precise material separation is done at source to avoid cascade recycling, thereby ensuring an optimal purity of recycled material that can be sent into manufacturing again as better quality steels, aluminium, etc.
Another critical component is technical feedback to OEMs. By analysing real-world dismantling data, RVSFs can provide insights to manufacturers on how vehicles perform at end of life, supporting “design for recycling” principles and improving future vehicle architecture.
Through this feedback loop, RVSFs evolve from downstream processors into active contributors to vehicle design and sustainability strategy.
Strengthening Circularity: Beyond Compliance
Mr. Yajima’s speech also covered another important issue concerning the environment required for responsible ELV recycling. The strengthening of circularity is dependent upon four important aspects:
First, collective compliance. A single non-compliant operator would destroy confidence in the industry as a whole. To do so effectively, therefore, requires enforcement of a policy by every operator in industry.
Secondly, it is the matter of industry pride. RVSFs must recognize themselves as environmental custodians rather than being associated with the scrap trade. By being proud of what they do and upholding the highest of standards, the overall reputation of the industry will be enhanced.
Third, there is education and awareness. Regulation alone would not effectively resolve this. For example, public awareness would help instill a sense of discipline in automobilists.
Finally, investment and growth follow responsibility. This is because when individuals in business see that being responsible is rewarded, they will attract investment in their sector of operation.
Summarising this philosophy, one of the concluding statements on the slide captured the broader intent succinctly:
“This is not just circularity. It is a chain of positive change.”
Technology, Data, and Traceability
Complementing this operational perspective, Mr. Nitin Chitkara, CEO, MMCM, highlighted the role of digital systems in supporting ELV compliance. He noted that a single vehicle typically contains 20,000–30,000 individual components, making ELVs one of the most complex waste streams to manage.
Without digital traceability, authorisation alone cannot guarantee compliance. Component-level tracking, dismantling data, and downstream material mapping are essential for ensuring transparency, supporting Extended Producer Responsibility (EPR) reporting, and enabling audit-ready operations.
EPR and the Road Ahead: Embedding Accountability into the ELV Ecosystem
From the regulatory side, Extended Producer Responsibility (EPR) is clearly considered to mark a significant turn in the current paradigm to share responsibilities across India's ELV chain. During the session, Smt. Deepti Kapil, Additional Director, Central Pollution Control Board (CPCB), confirming her presence to address the same, stated that EPR regulations for vehicles have been notified in January and April and have been in effect from April this year as the EPR portal is now functional to onboard the producers and the recyclers
She specified further that EPR was never envisioned as a standalone process in itself, but simply as an additional layer of responsibility built upon existing environmental compliance measures. She underscored that all designated vehicle scrapping facilities will continue to be compliant with CPCB’s environmental and operational standards, as mandated in any case or timeline for EPR, to underscore the environmental protection imperative that cannot be put off or diluted in the process of policymaking itself.
In this respect, there are set obligations on behalf of these EPR schemes and those that manufacture vehicles to guarantee that when vehicles are sold and introduced into the market, they are processed through legally and environmentally acceptable means. This reflects a paradigm shift with regard to outdated conceptualisations of these schemes, whereby responsibility for ELVs commenced at the point of sale. Furthermore, EPR schemes require that these obligations are fulfilled either through direct relationships with RVSFs or through confirmed recycling outcomes.
One of the key aims of EPR, as discussed during the session, is the stabilization of ELVs into the formal sector. While there has been rapid development in the development of scrappage infrastructure with over 192 authorized RVSFs now coming online in the country, the certainty of ELVs remains a concern. Not only does the EPR framework hold the potential to ensure long-term capacity certainty for scrappage sites based on the principles of producer responsibility, but there are also likely prospects of far higher standards of environmental control.
However, in their submissions, they were quick to point out that implementing EPR will not be without challenges. The success in implementing the EPR strategy will depend on data, traceability, as well as coordination with all the concerned stakeholders like the OEMs, dealers, recyclers, etc. There will be concerns that without proper ELV identification, even if the targets are met in theory, they will not be fully met in reality.
As pointed out by Ms. Kapil, the CPCB has clearly recognized the need for the early onboarding and submission of the data on the EPR portal. In this way, the transparency of the system will be established in the beginning itself. Mechanisms related to the EPR certificate are expected to be established later on, but the urgent need at present is for the verification routes to be established properly without compromising the system's integrity in the process.
Importantly, the link between EPR and well-functioning RVSF services has been continually noted as an important success criterion. EPR will likely foster greater cooperation between OEMs and approved recyclers, especially those that can provide traced dismantling, proper depollution, and recovery of good quality materials. In a positive feedback loop, recyclers could also provide information back to manufacturers, enhancing design improvements over time.
Alternatively, when viewed from a wider policy standpoint, EPR was presented not merely as a device for ensuring compliance, but rather as a means to internalise costs to the environment within the wider value chain of the overall automobile industry. Responsibility is thus placed squarely on those engaged with ELVs with a view to curbing unofficial dismantle activity, safeguard against pollution to the environment, and ensure that there is a constant flow through to manufacturing.
As the ELV ecosystem continues to evolve, speakers emphasised that the effectiveness of EPR will ultimately depend on consistent enforcement, transparent data systems, and industry-wide cooperation. When aligned with responsible RVSF operations and supported by strong channelisation mechanisms, EPR has the potential to move India’s ELV framework from infrastructure-led growth toward a mature, accountable, and circular system.
Conclusion: From Infrastructure to Integrity
One aspect is certain at the ELV sessions held in the MRAI Conference: the issue in India is not whether the ELVs ecosystem in some form is feasible. On the one hand, more than 192 ‘RVSFs’ have been sanctioned in the country. On the other hand, more than ‘3.8 Lakh’ automobiles have already been scrapped.
The next steps are to focus on integrity, enforcement, and execution because it is time to guarantee that ELVs freely flow to responsible RVSFs while protecting environmental integrity and supporting traceability and integration of recycling throughout vehicle design.
In short, ELV recycling is not just about ‘end-of-life’ waste, but about ‘closing the loop’ with responsibility, safety, and sustainability.
(IRuniverse Rohini Basunde)
