EPR Authorisation (E-Waste)

Introduction to Extended Producer Responsibility (EPR)

Extended Producer Responsibility [EPR] is a legislative strategy implemented by industrialised nations in order to encourage and promote the reuse, recycling, and eco-friendly disposal of electronic and polymer waste. EPR lays the responsibility of disposing of this waste on the manufacturer of the goods itself. EPR rules are put in place to ensure that the manufacturer/producers take the responsibility of minimising the impact of the waste generated by their products.

The producers are required to collect back the waste generated from their products when such products reach the end of its life cycle. It THis can be done either by promoting the collection (take-back process)  of the waste generated post the consumption of their products or by encouraging the recycling of such products in the most eco-friendly manner possible. Recycling should be done or assigned only to the recyclers registered with the respective Pollution control committee or Board.

Under the EPR scheme, companies involved in waste management are required to register with the CPCB and implement a waste management plan. They are also required to pay a fee for the registration and for any services provided by the CPCB under the EPR scheme. However, there is no concept of "authorization" involved in this process.

If you are looking for information on the registration process for waste management companies under the EPR scheme, you can visit the official website of the CPCB and click on the "EPR Registration" tab. The website will provide detailed instructions on how to fill out the online application form and submit the required documents.

EPR is issued by central pollution control board (CPCB) to producers who are responsible for the generation of e-waste or plastic waste or polymer waste or bulk users of these wastes.

Applicability of EPR on E-Waste

EPR Authorisation is applicable to producers, manufacturers, bulk users, importers, recyclers, dismantlers & collection centres of electric and electronic equipment waste.

EPR for e-waste is applicable on :

➲ Producer of electrical and electronic equipment or plastic  

➲ A bulk user of electrical and electronic equipment

➲ Bulk importer of electrical and electronic equipment

➲ Recycler, dismantlers, refurbishers or collection centres of e-waste.

Electrical and electrical equipment includes the following:

• IT and communication equipment and
• Consumer electrical and electronics such as TVs, Washing machine, refrigerators, Air conditioner including fluorescent and other mercury-containing lamps are covered under these rules.

As per the recent notice by central pollution control board (‘CPCB’) has emphasized the requirement for all producers of electronic and electrical equipment under E-waste management rules, 2016, to obtain extended producers responsibility-Authorization (EPR authorization) from CPCB. It can be obtained after applying in form-1.

Authorization is needed to be obtained for ensuring that end-of-life EEE generated from the products of the producers are canalized to authorization dismantler/recyclers.

EXTENDED RESPONSIBILITY RESPONSIBILITY IS APPLICABLE ON THE FOLLOWING:

1. Bulk consumer means the majority of consumers of electrical and electronic devices, such as central government or government agencies, public sector companies, banks, educational institutions, international organizations, international agencies, partnerships and public or private companies registered under the Factories Act of 1948 (63 of 1948) and the Companies Act of 2013 (18 of 2013) and health-care facilities with a turnover of more than one crore or more than 20 employees;

2. Collection Center means a centre or collection point or both established by the producer individually or as an association to collect e-waste in order to channel the e-waste to the recycler and to play the role stated in the producer's Extended Producer Authorisation and have facilities in compliance with the guidelines of the Central Pollution Control Board, including the collection centre formed by the dismantler or recycler, which should form part of their authorization issued by the State Pollution Control Board where the facilities are situated;

3. Dealer means any individual or company that purchases or receives electrical and electronic equipment and its components or consumables or parts or spare parts from producers for sale as listed in Schedule I of these Rules;

4. E-retailer means a person or business organization that uses the Internet, telephone, electronic network to sell its goods;

5. Manufacturer means an individual or organization or business as specified in the Companies Act, 2013 (2013) or business as specified in the Factories Act, 1948 (1948) or Small and Medium Enterprises as defined in the Micro, Small and Medium Enterprises Development Act, 2006 (2006), which has electrical and electronic equipment manufacturing facilities.

6. Producer means any person who, irrespective of the selling technique used, such as distributor, seller, e-retailer, etc.;

a. manufactures and offers to sell electrical and electronic equipment and its components or consumables or parts or spare parts under its own brand; or

b. offers to sell electrical and electronic equipment assembled under its own name, and its components or consumables or parts or spare parts manufactured by other manufacturers or suppliers; or

c. offers to sell imported electrical and electronic equipment and its components or consumables or parts or spare parts;

​7. ​Recycler means any individual engaged in the recycling and reprocessing of electrical and electronic waste equipment or assemblies or components thereof and having facilities as laid down in the Central Pollution Control Board guidelines;

8. Refurbisher means any company or undertaking registered under the Factories Act, 1948 or the Companies Act, 1956 or both or district industrial centres engaged in the refurbishment of used electrical and electronic equipment for the purposes of those rules.

Applicability of EPR on Plastic Waste

EPR for plastic waste management shall be mandatorily taken by every producer, manufacturer, recycler, reuser, dismantler, gram panchayat segregator of plastic products or plastic waste.

All the persons mentioned above are responsible for recycling or taking back as much as the plastic waste they produce.

In practice, if the manufacturer puts 100MT of polymer packaging material on the market, it is responsible for the processing and disposal of 100MT of post-consumer plastic waste. This responsibility can also be assigned to the Producer Responsibility Organization (PRO). A PRO shall be paid by the producer for the storage and safe disposal of plastic waste. Because the EPR transferred the burden of waste management from governments to these product producers, it has contributed to the introduction of innovative product and packaging solutions leading to a reduction in plastic waste.

Documents Required

➲ CIN Certificate.

➲ MOA (1st,2nd and last page).

➲ GST certificate.

➲ Rent Agreement.

➲ Aadhar Card and PAN card of the authorized signatory.

➲ Board declaration for authorized signatory.

➲ EC Code (Only in case of imports)

➲ Letter Head in the original.

➲ Product Details mentioning year-wise import (expected/actual) 

➲ A booklet containing product details (soft copy)

➲ Letterhead (pdf format).

➲ Quantity of product placed in the Indian market (Year Wise)

➲ URL of Companies Website

➲ Toll-Free No of the Company

➲ Details of Collection Center(s)

Procedure for obtaining EPR Authorisation

➲ Identifying the applicability and eligibility of establishment

➲ Preparing the drafts, EPR plan, Budget required filing of the application

➲ Preparing of draft application and respective attachments

➲ Submission of Application in CPCB

➲ Clarifying the remarks if raised by the department

➲ Obtaining of registration certificate

Why was EPR introduced in India?

The E-Waste (Management) Rules, 2016, the Plastic Waste Management Rules, 2016, and the Solid Waste Management Rules, 2016 are critically reviewed with respect to the "extended producer obligation" concept, compared to the first EPR-based regulations in India, the Batteries (Management and Handling) Regulations, 2001. The failure of recent regulations to consider the role of the broad informal sector in the collection and recycling of solid waste, one of the key reasons for the failure of BMHR, undermines their effectiveness. To address this downside, an EPR process has been introduced to combine the informal collection system with formal recycling, along with the removal of informal recycling units.

The Extended Producer Responsibility (EPR) for e-waste was introduced in India to promote sustainable waste management practices and reduce the environmental impact of e-waste.

E-waste refers to the waste generated from discarded electronic and electrical equipment, such as computers, phones, and appliances. This waste is a major source of pollution, as it contains hazardous substances such as lead, mercury, and cadmium that can contaminate the air, water, and soil.

The EPR scheme for e-waste was introduced by the Ministry of Environment, Forest and Climate Change (MoEFCC) under the E-Waste (Management) Rules, 2016. It applies to all producers, manufacturers, and importers of electronic and electrical equipment, as well as dealers and collection centers involved in the management of e-waste.

The EPR scheme for e-waste requires companies to register with the relevant state pollution control board and implement a waste management plan. They are also required to pay a fee for the registration and for any services provided by the state pollution control board under the EPR scheme.

The main objective of the EPR scheme for e-waste is to reduce the amount of e-waste being sent to landfills and incineration plants, and promote the recycling and reuse of e-waste. It aims to create a more circular economy by incentivizing companies to design their products in a way that makes them easier to recycle and dispose of safely.