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.

Need for Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) was in the making for a long time. EPR in India was first introduced in 2011 under the E-waste (Management and Handling) Rules 2011. Indeed it was an effort to shift the responsibility of waste management to the producer of the product that generated the waste (plastic waste and e-waste). Later with the E-waste (Management)Rules 2016, the manufacturers/producers, along with the dealers and refurbishers (who intend to sell refurbished EEE), were also identified as additional stakeholders and included under EPR.

The need for extended Producer Responsibility was felt to make an entity that introduces EEE in the consumer market responsible for the safe collection, dismantling and disposal (or recycling) of the e-waste generated by their products. Extended Producer Responsibilityaims to circle e-waste back into the system to get resources embedded in the discarded items. EPR was incepted in Sweden, which became the first country to implement it in 1988. Since then, EPR has been implemented in many countries across the globe.

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.

Documents Required for EPR Authorisation

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

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

Registration Process for E-Waste EPR Authorisation

Renewal of EPR Authorisation

The EPR authorisation received from the CPCB is valid for five years. An application for Renewal of EPR Authorisation must be made within 60 days of the expiry of the authorisation.

The renewal fee for EPR Authorisation is the same as the application fee for a new application. In case of renewal of EPR authorisation, the Member Secretary is the approving authority.

Refusal of EPR Authorisation by CPCB

CPCB can refuse EPR authorisation to an applicant if he cannot provide requisite details on quantity, its EPR plan and RoHS, self-declaration or the agreement copy with authorised dismantler/recyclers within 45 days after the CPCB raises such issue. However, an opportunity to present its case is given to the applicant before the refusal of grant of EPR authorisation.

Cancellation of EPR authorisation

If, at any stage during the operation, the CPCB or the concerned SPCB finds the authorised entity not complying with the provisions, guidelines or amendments in the E-waste (Management) Rules, 2016, their EPR authorisation can be cancelled by the CPCB.

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