EPR and e-Waste Compliance

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EPR (Extended Producer Responsibility) and e-Waste Compliance

Electronic Waste commonly called e-waste is electronic products nearing the end of their useful life. E-waste is considered dangerous, as certain components of some electronic products contain materials that are hazardous, depending on their condition and density. The hazardous content of these materials poses a threat to human health and environment. Discarded computers, televisions, VCRs, stereos, copiers, fax machines, electric lamps, cell phones, audio equipment and batteries if improperly disposed can leach lead and other substances into soil and groundwater. Many of these products can be reused, refurbished, or recycled in an environmentally sound manner so that they are less harmful to the ecosystem.

By virtue of E-Waste (Management) Rules, 2016, Ministry of Environment, Forest and Climate Change, as regulator has notified the following mandatory compliances for producers of Electrical / Electronic Goods

  • To ensure that the products when introduced are RoHS (Reduction in hazardous Substances) Compliant.
  • Under extended producer responsibility, producer collects back a percentage of the produced goods and get them disposed of / recycled in an environment friendly manner.
  • The producer is also needed to appropriately label the products with information about end-of-life equipment handling
  • Ensure that only Authorized Recyclers repair and handle the e-waste
  • Announce its E-waste Authorized Collection Centres/points to dispose products that have reached end-of life.

Compliance to RoHS

Every producer of electrical and electronic equipment shall ensure and Self-Declare that, new Electrical and Electronic Equipment and their components or consumables or parts or spares do not contain Lead, Mercury, Cadmium, Hexavalent Chromium, polybrominated biphenyls and polybrominated diphenyl ethers beyond a maximum concentration value of 0.1% by weight in homogenous materials for lead, mercury, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers and of 0.01% by weight in homogenous materials for cadmium. Such Declaration needs to be submitted while seeking Extended Producer Responsibility

EPR Authorization

EPR stands for Extended Producer’s Responsibility. It is a registration for Indian Producer / Manufacturer / Importer of product for E-waste management. EPR Authorisation is given by the Central Pollution Control Board (CPCB). With EPR authorisation, the manufacturer / importer of electronic and electrical products has been given the responsibility to control E-waste by the products after expiry of their lifetime.

How to get EPR Authorization?

Extended Producer Responsibility – Authorisation of Producers. –

  • Apply in Form-1 to Central Pollution Control Board with EPR Plan. The actual targets are drawn from quantity of products code wise, placed in the market in the previous years and taking into consideration the average life of the equipment. Producer indicates the estimated quantity of e-waste for the current year and the quantity expected to be collected with the collection scheme proposed to be implemented by the producer.
  • Central Pollution Control Board evaluates EPR Plan and grants Authorisation, in Form 1(aa) within a period of one hundred and twenty days.
  • The EPR – Authorisation is valid for five years
  • This authorisation covers targeted quantity of e-waste, product code wise, to be collected during the year. The Central Pollution Control Board fixes the targets in accordance with Schedule III of Notification.

Extended Producer Responsibility – Authorisation of Manufacturer

  • The manufacturer generating e-waste to apply for authorisation to concerned State Pollution Control Board (SPCB), indicating it possesses appropriate facilities, technical capabilities and equipment to handle e-waste safely
  • State Pollution Control Board evaluates and grants within a period of one hundred and twenty days an authorisation in Form 1(bb)
  • The authorisation is for specified place of operations and is valid for five years;
  • Every person authorised needs to maintain the record of e-waste handled by them in Form-2 and prepare and submit an annual return containing the details specified in Form3 on or before the 30th day of June following the financial year to the concerned SPCB

The manufacturer / importer of electronic and electrical products have to provide documentary evidence for E-waste management plan and agreement with Recycling agency.

CII provides complete support in managing documentation and formalities in getting EPR Authorisation.

Plan for Manufacturer Includes

  1. Collection of e-waste generated during the manufacture and channelize it for recycling or disposal;
  2. Ensure that no damage is caused to the environment during storage and transportation of e-waste;
  3. Maintain records of the e-waste generated, handled and disposed in Form-2 and make such records available for scrutiny by the concerned State Pollution Control Board;
  4. File annual returns in Form-3, to the concerned State Pollution Control Board on or before the 30th day of June

Plan for Producer Includes

  1. Collection and channelization of e-waste generated from the ‘end-of-life’ of their products or products with same code;
  2. Establish mechanism for channelization of e-waste from ‘end-of-life’ products including those from their service centres, dealer, collection centres, Producer Responsibility Organisation, through buy-back arrangement, exchange scheme, Deposit Refund System, etc. to authorised dismantler or recycler or to Treatment, Storage and Disposal Facility, as needed
  3. Pre-treatment to immobilise the mercury and reduce the volume of waste to be disposed off
  4. providing contact details such as address, e-mail address, toll-free telephone numbers or helpline numbers to consumer(s) or bulk consumer(s) through their website and product user documentation so as to facilitate return of end-of-life electrical and electronic equipment;
  5. creating awareness

[/vc_column_text][vc_text_separator title=”WHO CAN APPLY?” i_icon_fontawesome=”fa fa-users” title_align=”separator_align_left” add_icon=”true” css=”.vc_custom_1588500252571{margin-bottom: 0px !important;border-bottom-width: 0px !important;padding-bottom: 10px !important;}”][vc_column_text]Indian Manufacturers / Producers Import of electrical and electronic equipment is allowed only to producers having Extended Producer Responsibility Authorisation.[/vc_column_text][vc_text_separator title=”REQUIREMENT FOR EPR (EXTENDED PRODUCER RESPONSIBILITY) and e-WASTE COMPLIANCE” i_icon_fontawesome=”fa fa-book” i_color=”juicy_pink” title_align=”separator_align_left” add_icon=”true” css=”.vc_custom_1589008849477{margin-bottom: 0px !important;border-bottom-width: 0px !important;padding-bottom: 10px !important;}”][vc_column_text css=”.vc_custom_1589470291524{margin-top: 0px !important;border-top-width: 0px !important;padding-top: 0px !important;}”]

Documents Required

  • Legal Entity Documents for Manufacturer / Importer
  • Production / Import History Product Code Wise for last 10 years
  • Valid CRS Certificate / ISI Mark License, if Applicable
  • Documents for CPCB Certification
  • Self-declaration for Reduction of Hazardous Substances (RoHS) compliance with BoM, RoHS Test Reports, RoHS Certificate
  • Location and Details of all offices
  • EPR Plan covering implementation methodology, Budgeting, Flow Diagrams
  • for Collection and movement of E-Waste to Recycler
  • Estimated generation of e-waste item-wise for forthcoming years
  • Estimated collection target for the forthcoming year(s)
  • Copies of agreement with Dealers, Collection Centre, Recyclers, Treatment, Storage and Disposal Facility, etc.

[/vc_column_text][vc_text_separator title=”TYPICAL TIMELINES*” i_icon_fontawesome=”fa fa-calendar” i_color=”custom” title_align=”separator_align_left” add_icon=”true” i_custom_color=”#0a7c00″ css=”.vc_custom_1588500315577{margin-bottom: 0px !important;border-bottom-width: 0px !important;padding-bottom: 10px !important;}”][vc_column_text css=”.vc_custom_1589008801762{margin-top: 0px !important;border-top-width: 0px !important;padding-top: 0px !important;}”]2 to 3 months[/vc_column_text][/vc_column][/vc_row]