EPR Registration for E-waste Management in India

As technological advancements continue to revolutionize the world, the flip side is the surge in electronic waste (E-waste), necessitating robust mechanisms for proper disposal and management.

In response to this growing concern, India has implemented the Extended Producer Responsibility (EPR) Authorization, placing the responsibility for managing the life cycle of electronic products on the producers.

Let's explore more about the essential role of EPR Registration for E-waste management in India.

Extended Producer Responsibility (EPR) Registration

Extended Producer Responsibility is a regulatory approach that shifts the responsibility for the end-of-life management of a product from the consumer to the manufacturer.

Enacted by the government in 2011, the EPR law mandates that manufacturers bear the responsibility of ensuring the environmentally sound disposal of their products.

This initiative is particularly applicable to producers and importers of electric or electrical equipment.

To comply with EPR regulations, manufacturers must obtain the EPR certificate, a mandatory requirement for those involved in the production or import of electric or electrical equipment.

This certification is issued by the Central Pollution Control Board (CPCB) under the Ministry of Environment, Forest and Climate Change (MoEFCC), Government of India.

Under the E-Waste (Management) Rules, 2016, manufacturers of Electrical and Electronics (EEE) products/equipment listed in Schedule 1 are obligated to collect, recycle, and dispose of the final stage of their products through an authorized dismantler or recycler.

According to the guidelines, manufacturers and importers are required to collaborate with authorized recyclers to manage the disposal of electronic waste.

Importance of EPR Registration for E-waste Management

EPR Registration for E-waste management plays a pivotal role in India by holding electronic device manufacturers accountable for establishing E-waste collection and recycling systems.

• EPR registration makes manufacturers accountable for setting up systems to manage E-waste, preventing environmental and health risks.
• This registration motivates manufacturers to collaborate with recycling facilities, promoting effective and responsible E-waste recycling practices.
• EPR Authorization enables maximum resource recovery by partnering with specialized facilities, minimizing environmental impact and promoting sustainable resource management.
• EPR registration initiatives raise awareness and education about E-waste recycling, encouraging producers to implement programs that increase public knowledge of the importance of recycling electronic devices.
• E-waste EPR registration ensures an organized and accountable approach to managing E-waste, leading to environmental protection, reduced hazardous substances, and the preservation of natural resources.

Requisites for Producers for E-waste EPR Registration

1. Producers with EEE having equal or greater lifespan than the market average must provide:

• Quantity of EEE sold yearly for its average lifespan, as per CPCB.
• Sales data in metric tonnes.​

2. Producers with a market presence less than their EEE lifespan must provide:

• Quantity of EEE sold since sales began.
• Letter of intent on company letterhead, signed by an authorized representative.
• Affidavit on a 100-rupee stamp paper, signed by an authorized representative and notarized.
• CA Certificate verifying accurate quantity of EEE sold or imported.
• Self-declaration on company letterhead about the availability of RoHS technical documents.
• Details of Awareness Plan.

List of Product Categories Under EPR Registration for E-waste

EPR registration covers a diverse range of product categories, including:

• Information Technology & Telecommunication Equipment
• Consumer Electrical and Electronic Products
• Large and Small Electrical and Electronic Equipment
• Electrical and Electronic Tools (With the exception of large-scale stationary industrial tools)
• Toys, Leisure and Sports Equipment
• Medical Devices (With the Exception of All Implanted and Infected Products)
• Laboratory Instruments

Click here to view the full list of mandatory products that come under EPR Registration for E-waste.

Who Needs EPR Registration in India?

EPR registration is mandatory for various entities involved in the electronic product life cycle:

• Recycler
• Producer
• Refurbisher
• Manufacturer

Each entity has specific responsibilities to ensure the proper disposal and management of E-waste, such as:

Recyclers- They must:

• Register on the portal.
• Align facility and processes with Central Pollution Control Board standards.
• Send unrecoverable material to registered recyclers.
• Dispose of recycling process residue in an authorized facility.
• Maintain and share E-waste records on the portal for verification.
• Submit quarterly and annual returns on the portal promptly.

Producers- Producers of electrical and electronic equipment listed in Schedule I must:

• Register on the portal.
• Achieve extended producer responsibility targets from Schedule-III and Schedule-IV via the portal.
• Transition from previous E-waste (Management) Rules under CPCB guidance.
• Raise awareness through various communication means.
• Submit quarterly and annual returns on the portal by the month following the relevant quarter or year.

Refurbishers- They must:

• Register on the portal.
• Collect E-waste generated during refurbishing, hand it over to a registered recycler, and upload information on the portal.
• Ensure refurbished equipment complies with the Compulsory Registration Scheme of the Ministry of Electronics and Information Technology and Standards of the Bureau of Indian Standards.
• File annual and quarterly returns on the portal by the end of the month following the respective quarter or year, as applicable.

Manufacturers- They must:

• Register on the portal.
• Collect and responsibly recycle or dispose of E-waste generated during the production of electrical and electronic equipment.
• Submit annual and quarterly returns on the portal by the end of the succeeding month or quarter, as applicable.

E-waste EPR Registration Cancellation

Cancellation of EPR registration for E-waste may occur under certain circumstances, such as:

• Discovery of fraudulent documents.
• Non-compliance with EPR obligations.

The entity has 15 days to respond before the E-waste EPR cancellation process begins.

Note: Timely renewal of EPR Registration can prevent this cancellation.

Renewal Process of EPR Registration for E-waste Management

The renewal process is essential to maintain ongoing compliance with EPR regulations. It involves updating information, including any changes in production volumes, and reaffirming the commitment to E-waste management responsibilities.

Producers and manufacturers are required to submit a renewal application for their e-waste EPR registration at least 120 days before its expiration date.

EPR Registration Certificate Procedure for E-waste Management

The EPR Registration procedure for E-waste involves the following steps:

Step 1: Preparation

Gather essential information about electronic products, production volumes, and formulate an E-waste management plan.

Step 2: Application Submission

Submit the completed EPR registration application to the Central Pollution Control Board (CPCB) or the State Pollution Control Board (SPCB) along with the required documents.

Step 3: Document Verification

The regulatory authority reviews the submitted documents to ensure compliance with requirements and regulations.

Step 4: Assessment and Approval

The application undergoes assessment, and upon meeting the criteria, approval for EPR registration is granted.

Step 5: Issuance of Certificate

Upon successful verification, the CPCB issues the EPR registration certificate.

Required Documents for EPR License for E-waste Management

The EPR license for E-waste in India requires the submission of several important documents, including:

• Company Profile and Details

Provide comprehensive information about the producer, including company details, registration certificates, and contact information.

• Product Specifications

Detail the specifications of electronic products covered under the EPR registration, specifying their composition and components.

• E-waste Management Plan

Present a detailed plan outlining strategies for the collection, transportation, recycling, and disposal of E-waste. The plan should align with environmentally friendly practices and comply with regulatory guidelines.

• Authorization Letter (for Collective Registration)

If opting for collective registration, provide an authorization letter from each producer in the group, clearly stating the agreement to share EPR responsibilities.

• Proof of Financial Responsibility

Demonstrate financial capabilities to meet the expenses associated with E-waste management, including recycling and safe disposal.

• Annual Compliance Report

Submit annual reports detailing the E-waste collected, processed, and disposed of during the reporting period.

Conclusion

EPR Registration for E-waste management in India is a critical step towards ensuring a sustainable and responsible approach to handling electronic waste.

Brand Liaison is a trusted compliance consultant company for manufacturers seeking to navigate the complexities of EPR Registration seamlessly.

Our team provides assistance and support to manufacturers, facilitating a smooth and efficient process for obtaining EPR certificates.

With our expertise, guidance, and streamlined process, we empower manufacturers to meet their EPR obligations with ease, contributing to a cleaner and greener future.

You May Share it on Social Media-