Overview of EPR Authorisation for E-waste Management

Extended Producer Responsibility (EPR) Authorisation is the permission given by the Central Pollution Control Board (CPCB) to the Producer, Importers and Brand Owners (PIBO) of Electrical and Electronic Equipment (EEE). The EPR authorisation is mandatory and given for environmentally sound management of e-waste produced. A legislative strategy, EPR, is implemented by industrialised countries to promote and encourage the reuse, recycling, and eco-friendly disposal of electronic waste.

Extended Producer Responsibility ensures that the responsibility of disposing of of e-waste lies on the manufacturer of the goods. EPR must be fulfilled by implementing EPR plans and targets outlined in the authorisation certificate, including the details of the PRO and e-waste exchange process. EPR Authorisation is required for buyback, recycling and reuses through collection from dealers, collection centres, etc. This is achieved through a buyback arrangement, exchange scheme, Deposit Refund System or providing other means to incentivise the end-user so that collection and recycling (or disposal) can be done by authorised units (collectors, dismantlers, refurbishers) in the formal sector as per the guidelines issued by the CPCB.

EPR - E-Waste (Management) Rules 2022

The Ministry of Environment, Forests, and Climate Change issued E-Waste (Management) Rules 2022 on November 2, 2022. This will go into effect on April 1, 2023.

As per this regulation, all manufacturers, producers, refurbishers, and recyclers shall have to register on the portal and collect e-waste generated during the manufacturing, refurbishing, or disposal of any electrical and electronic equipment and ensure its recycling or disposal. The Entities must register on the portal under the appropriate category, such as manufacturer, producer, refurbisher, or recycler. If an entity falls into more than one category, it must register under each category separately. It is illegal for any entity to conduct business without registration.

All entities shall have to file annual and quarterly returns in the prescribed form on the portal on or before the end of the month following the quarter or year to which the return relates.

These regulations shall apply to all manufacturers, producers, refurbishers, dismantlers, and recyclers engaged in the manufacture, sale, transfer, purchase, refurbishment, dismantling, recycling, and processing of e-waste or electrical and electronic equipment listed in Schedule I.

The Central Pollution Control Board may charge registration fees and annual maintenance fees on entities seeking registration under these rules based on the capacity of e-waste generated, recycled or handled by them, as determined by the Central Pollution Control Board with the approval of the Steering Committee.

The producer of electrical and electronic equipment listed in Schedule I must first register on the portal to obtain and implement extended producer responsibility targets as per Schedule III and IV.

Producers who have extended producer responsibility plans under the provisions of the erstwhile E-Waste (Management) Rules, 2016, shall migrate under these rules in accordance with the procedure established by the Central Pollution Control Board with the approval of the Steering Committee.

Why is CPCB EPR Registration is Necessary for Plastic Waste and E-Waste Management?

1. CPCB EPR Registration means channelization to e-waste in a proper manner for environment-friendly carrying out of business. 
2. Every producer who is selling electronic items i.e. LED TV & LED parts, washing machine, minicomputer, chargers Computer & computer parts with input and output devices, personal computer, laptop, laptop parts -battery, mainframe, facsimile, air conditioners, and air conditioner parts, telephone, smartphone, feature phone, and many more products containing electrical circuits and parts require to obtain EPR Certificate for Import. 
3. The government has taken certain steps under EPR registration authorization for appropriate e-waste collection, channelization, disassembling, and disposing of electronic waste after the end of life.
4. We provide EPR authorization registration to have standing in the market and Services for related matters.
5. EPR Certificate is the obligation of every manufacturer of electrical and electronic equipment (EEE) for the channelization of e-waste to an authorized business.

Why PIBOs need EPR Authorisation?

When a producer introduces a product along with plastic packaging in the market that EEE will result in e-waste after being discarded. This e-waste can be in the form of plastic parts (recyclable and non-recyclable plastic waste), metal parts, wires, electronic chips, hazardous metals and chemicals found in their components (cadmium, lead, mercury), toxic chemicals used in the production of EEE ( PCTs and PCBs) and even some valuable metals. Keeping all this in mind, EPR was required to be practised.

EPR authorisation is based on the Polluter Pays principle. Thus, the entities that produce waste will need EPR Authorisation. Apart from all these are furbisher, also needs EPR authorisation.

Benefits of EPR Registration Certificate

1. EPR promotes the recycling and reuse of the e-waste (Electrical and electronics waste), hence reduces the cost of raw material for the producers/manufacturers.
2. EPR ensures the management of e-waste in environmentally friendly manner, hence reduce the harmful impact of e-waste on environment.
3. EPR Authorization from Central Pollution Control Board (CPCB) enhance the goodwill of the product and brand reputation in the market.
4. EPR promotes sustainable development, hence lowers the waste generation and misuse of the natural resources.

Documents Required for EPR Authorisation

The main documents required to obtain an EPR Authorisation for e-waste management are as follows:

1. EPR plan mentioning the required details
2. GST Certificate
3. Copy of permission from the concerned Department/Ministry for selling their product
4. Sole proprietor or Authorized Signatory KYC
5. Copies of agreement with collection centres
6. Excel sheet including details of imported products
7. Copies of agreement with dealers
8. Memorandum of Association
9. Copies of agreement with dismantlers/recyclers
10. Certification of Incorporation (CIN)
11. Copies of agreement with Treatment, Storage, and Disposal Facilities (TSDFs)
12. Company’s PAN card
13. Self-declarations on ROHS
14. Copy of DGFT permission / license (IEC certificate)
15. Copy of agreement with PRO (if applicable)

Registration Process for E-Waste EPR Authorisation

Documents & Fee Submission: The applicant must file an EPR Authorisation form, all required documents, and a comprehensive EPR Plan for the collection, dismantling and recycling of the products.

Document Scrutiny by CPCB: The Chairman of the CPCB approves or rejects the application based on the EPR plan. In case of incomplete applications or any issue flagged, the applicant will be given a timeframe to resolve such issues.

Grant of EPR authorisation: CPCB issues EPR authorisation within 120 days of receiving the accepted application. In case of amendment in rules, a revised NOC is issued.

Timeline

CPCB shall provide EPR authorization within 120 days of receiving a complete application, as per E-Waste regulations. In case of incomplete application, the CPCB may verify the application and respond with a check list within 25 days.

Note: Agreement will be signed for 1 year, and the Certificate granted will be valid for 5 years.

EPR Registration Fees

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EPR Registration For E-waste Categories of Electrical and Electronic Equipment