Refurbished devices are gaining popularity in the Indian market, yielding in an ever-rising consumer base from all segments – individuals, businesses and organisations. The refurbished product includes a consumer electronics segment and is not just limited to computers and mobiles. This business can provide a complete experience and utility of new products at a significantly lower price. The market for refurbished products is in the form of consumer goods and electronic items rejected by the original equipment manufacturer (OEM) or the buyer due to minor faults that decreased their value as brand-new products. A refurbishment business in E-Waste deals in non-functional but usable electronics. These are procured from OEMs or e-waste traders, repaired and re-distributed in the market after successfully passing a series of tests for functionality and defects.
Under the E-waste (Management) Rules, 2016, processing or collection of e-waste can be carried out only by producers or their authorised associates/partners, authorised dismantlers, recyclers and authorised refurbishers. We can call a refurbished device a reconditioned or refreshed gadget sold at a discounted price. The manufacturer or an authorised refurbisher carries out the e-waste refurbishment business. In either case, the refurbishing unit must follow compliance requirements mandated by the government agencies like the CPCB, the concerned SPCB or the MoEF&CC.
As e-waste management is regulated under the EWM Rules, 2016, the following guidelines have been elaborated as post-compliance for the e-waste refurbishment business. These act as a standard operating procedure (SOP) which is also mandatory for refurbishers to conduct business in India. This is because repairing used electronics and electrical equipment (EEE) generates other hazardous waste. It further involves processes like dismantling and metal recovery, which is a potential hazard. Therefore, this must be regulated.
The CPCB has consequently mandated the following compliance requirements for e-waste refurbishment businesses.
The premise for refurbishing should fulfil the following requirements:
From the list of post-compliances mentioned above, the procedural obligations in the e-waste refurbishment business must have become clear. However, the entrepreneur must also know the legalities associated with starting this business. The following section will briefly law down the licenses and authorization that an entrepreneur will need to start an e-waste refurbishment business.
Before establishing the unit, the e-waste refurbishment business must obtain Consent to Establish (CTE) for the facility part of the Consent NOC. After that, the concerned SPCB or the PCC awards CTE, the unit is established as per the recommended guidelines and the mandatory pollution control measures. Subsequently, the unit can approach SPCB for Consent to Operate (CTO). The Consent NOC is given in 2 stages – CTE and CTO. However, the latter includes a site inspection by authorised personnel from the board.
Documents Required for Consent NOC
The e-waste refurbishment business owner must apply for a one-time authorisation at the next stage at the CPCB. This is done after getting all prerequisites (Consent NOC, business registration, etc.).
The documents needed for the authorisation process include the following –
If the e-waste refurbishment business manages the hazardous waste generated, it will need a Hazardous Waste Management Authorisation. If the facility takes treatment, storage, and disposal assistance from a waste management facility operator, it will need to tie up with a registered TSDF.
Documents needed with Hazardous Waste Management Application
Though Extended Producer Responsibility is the obligation of a producer of EEE, this authorisation will be required in case the e-waste refurbishment business is importing the used EEE for refurbishment or refurbishing e-waste and selling it under his name. In both cases, the application and a detailed EPR Action Plan must be submitted to the CPCB.
The following are the documents required at the time of EPR authorisation –
Post-compliance with environment-related protocols is important not only to function under the law or smooth the functioning of the e-waste refurbishment business but also to act as a safety net for the refurbisher. When the EEE become e-waste, they are a potential hazard. When a refurbisher operates on such e-waste, it opens himself and his surrounding environment to the ill effects of the waste. If not discarded as per the mandated protocols, it can cause harm to human health and the environment if stored safely.
However, if the waste is disposed of in the open or un-scientifically or even if crude methods are used for refurbishing or retrieval of valuable components, then it may cause health risks and environmental damage. Besides the demand from price-sensitive consumers, the demand for refurbished EEE has also increased due to rising prices of new electrical equipment, disruption in the global supply chain and trade restrictions due to global instability in the past few years.
Read our Article:How to obtain an EPR Certificate for the import of e-waste in India?