Overview of EPR Certification in India

EPR or Extended Producer responsibility, also called environmental stewardship, is a legislative strategy implemented by MoEF, GOI to promote and encourage recycling, reuse and eco-friendly disposal of certain types of waste. EPR regime was first introduced in e-waste management and subsequently for plastic packaging waste, then for end-of-life battery and used tyre waste. CPCB has released several EPR guidelines in these categories and delineates the responsibilities of producers and entities in the recycling sector. Entities using plastic packaging, handling e-waste, waste battery and used tyre waste require to adhere to the CPCB guidelines that include registration of all entities on the dedicated EPR portal, generating their respective targets for waste recycling (or disposal) maintaining records of sale and purchase among the registered entities and submission of data as prescribed as well as filing annual returns of the waste management to the CPCB. The Board releases and updates these guidelines frequently, requiring the stakeholders to remain updated and strictly adhere to EPR certification and EPR compliance. Recently, the EPR regime has been defined for producers of waste lubricating oil, too and will be applicable from April 2024 onwards.

Why Does Your Business Need EPR Certification?

EPR Certification is required for the purpose of buy-backs, recycling and reuses through collection from dealers, collection centres etc. This can be achieved through a buy-back arrangement, exchange scheme, deposit refund system or providing other means to incentivise the end-user so that authorised units can do collection and recycling (or disposal) in the formal sector as per the guidelines issued by the CPCB.

Recycling targets are calculated based on the weight of manufactured/purchase/ imported and collection data. Producers will have to obtain EPR certificates from recyclers according to the quantity of waste items recycled by recyclers and use such certificates to meet their EPR targets.

Highlights of the CPCB EPR Portal

As per the waste management rules, any business entity introducing the product into the market will be responsible for the product's whole life cycle. For instance, if your business manufactures and sells the product to the consumer under your brand name, or if you procure the product, brand it under your own name, and import the product for sale, you will need an EPR certification and fulfil your EPR targets.

The identified producers as well as the recyclers will have to submit an online application along with the relevant information, documents & Application fees for registration. After the submission of all documents and its scrutiny, the CPCB will issue EPR registration certificate / registration number to the applicant. The recycling targets will be auto-generated once the application is submitted.

Types of Business That Require EPR

EPR Certification is the permission given by the Central Pollution Control Board (CPCB) to the Producer, Importers and Brand Owners (PIBO) to ensure that they are fulfilling their part in waste management and promote a circular economy where utilisation of the resource is based on the 3Rs reduce, recycle and reuse. The following types of businesses will require EPR Certification.

EPR for E-Waste Management Businesses

To get an EPR certification, EEE manufacturers and importers, e-waste recyclers or refurbishers must make an application for EPR registration on the centralised CPCB EPR portal. Presently there are four categories under which the CPCB issues registration. These include the Producers, Recyclers (including dismantlers), refurbishers and Importers. These entities must apply to the CPCB along with the mandatory documents and a comprehensive EPR Plan for the collection, dismantling and recycling.

If your business falls under the definition of producer, refurbisher, or recycler of EEE, you must register yourself on the centralised EPR portal of e-waste. A producer is an entity that manufactures and offers to sell EEE and their components under its own brand or offers to sell under its own brand, assembled EEE and their components produced by other manufacturers or suppliers or offers to sell imported EEE and their components irrespective of the selling method used such as dealer, retailer, e-retailer, etc. Documents required for EPR Registration for E-Waste

• CIN (if available)
• GST
• IEC (if available),
• PAN of company (if available) and PAN of Authorised Person
• Postal Address from where sale in the entire country is being managed
• List of EEE from the list of notified EEE, along with their codes for which registration is required
• Covering letter
• Affidavit cum undertaking duly signed by the authorised person
• A self-declaration on the letterhead of the company duly signed by the authorised person.

• Copy of valid consent certificate,
• Company’s PAN, CIN & GST
• Details of the quantities of plastic packaging etc.
• MSME Certificate
• Authorised Person Aadhar Card Number & Copy
• District Industries Centre of the State (DIC Certificate or Factory License)
• Total Capital Invested on Project
• Water and Air Consent Details
• Representative pictures of plastic packaging
• Flow Diagram of Manufacturing Process
• Total Production capacity,
• Details of the Facility, GPS Location, pictures of raw material, storage area
• Disaster Management Plan
• Details of Pre & Post-consumer waste.

• Covering letter
• An undertaking regarding the submission of authentic data
• Tyre Composition (in Excel Format)
• Submission of plantwise manufacturing data (in Excel Format)
• PAN Card of the company
• GST Number of the company
• IEC number of the company (Only in case of import)
• CIN number of the company
• Aadhar Card of the Authorized Person
• Address of the office of the company in the country

EPR for Battery Business

MoEF&CC published the Battery Waste Management Rules 2022 for managing hazardous battery waste. The rules made EPR applicable to producers, dealers, consumers and entities involved in the collection, transportation, recycling and refurbishment of waste batteries. Besides the above entities, the rules have defined the terms manufacturer, producer and Public Waste Management authorities as stakeholders in Battery Waste Management Rules, 2022. Producers may engage themselves in recycling or authorise any other entity to collect, or refurbish waste batteries.

The Rules have defined EPR obligations towards battery waste management through collective efforts of Producers, Importers, and entities involved in the handling of 'end-of-life batteries'. A centralised portal has been created by CPCB for the identified stakeholders' registration and generating recycling targets. The documents required in this regard include

• Company GST Certificate
• PAN Card of the company
• Corporate Identification Number (CIN) document
• Consent Issued by SPCBs/PCCs under the Air/Water Act and authorisation under Hazardous & Other Waste (Management & Transboundary Movement) Rules, 2016
• Import Export Certificate issued by Ministry of Commerce & Industry (in case of importers)
• District Industries Centre (DIC) registration (if the unit is registered with DIC)

EPR Certification-What Will Change For Your Business?

• Through EPR certification, the registered entity will be able to trade anywhere in the country without the hassle of waste management in different parts of the country if they are conducting their business in more than one state.
• Though the onus of recycling has been shifted to producers who are responsible for introducing products. The producers can transfer the cost incurred along with the price of the product which the consumers pay. In addition to it, waste management through producers ensures effective waste management as they can recycle and reuse the product in their operation.
• EPR also ensures the proper waste management of hazardous waste after the end of their life and ensures that no harm is caused to the environment or to humans who may use unscientific methods of recycling practices.

EPR for Waste Oil for Manufacturers of Oil and Recyclers, and Importers of Used Oil

The framework of EPR for Waste Oil has been designed to promote sustainable and eco-friendly use and disposal of oil and lubricant, lower waste generation, and increase recycling capacity in the country. The producer of oils and lubricants and used oil importers and recyclers will need to register for EPR as per the applicable categories on the CPCB portal. After registration, the entities must fulfil their target as defined in the HWM Amendment Rules, 2023 and submit quarterly and annual returns per the directions. To meet EPR targets, the producers and waste oil importers with EPR Targets will be allowed to purchase EPR certificates from registered recyclers. Registered oil recyclers can generate EPR certificates after they recycle waste oil in their facilities. The 2023 HWM Amendment Rules also empower the CPCB to cancel an entity's registration if they knowingly withhold necessary information for the registration, return, report or other information required under this schedule or if there are any other irregularities.

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