EPR Certificate E Waste: What is It and Why Does It Matter?
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Overview
According to the World Health Organization (WHO), the world produced an estimated 62 million tonnes of e-waste in 2022, in which only 22% e-waste was collected and recycled in systematic manner. To tackle this, the government across the globe implemented EPR (Extended Producer Responsibility) framework. It placed the responsibility of managing e-waste that has reached it end-of life phase (end of useful life) on manufacturers.
In India, EPR framework was introduced by the Ministry of Environment, Forest, and Climate Change. EPR Registration for E-Waste encourages environmentally sound management of electronic waste. It means that producers must take all steps necessary to ensure that the waste is managed in such a manner that does not damage the environment or put the safety and health of citizens at risk.
Let’s delve deeper and understand the Extended Producer Responsibility (EPR) framework for managing E-Waste in India.
What is EPR Certificate for Electronic-Waste?
The Extended Producer Responsibility (EPR) is a strategic approach that regulates PIBOs (Producers, Importers, and Brand Owners) of plastic waste, e-waste, and other specified waste in India. To obtain EPR Certification For E-Waste, PIBOs are required to apply on the EPR portal of CPCB at (eprewastecpcb.in). The Central Pollution Control Board (CPCB) also issues EPR obligations/ recycling targets whose fulfillment is necessary to operate EEE business smoothly and with no legal repercussions.
The E-Waste Management Rules were implemented to manage electronic waste (e-waste) in an environment-friendly manner and promote a circular economy within the nation. The EPR framework involves the grant of EPR certification to the four major entities namely producers, manufacturers, recyclers, and refurbishers. These entities cannot carry out any business in the electronic segment without registration from the designated authority. Further, such entities cannot deal with or enter into contracts with any unregistered producer, manufacturer, refurbisher, or recycler.
Guidelines under The E-Waste (Management) Rules, 2022
To obtain EPR For E-Waste Management, producers have to approach the CPCB. The CPCB is a statutory organization established under the Water (Prevention and Control of Pollution) Act in 1974. The organization is given the responsibility to oversee and assign duties to various stakeholders as per the E-Waste Management Rules 2022.
The rules were notified in 2011 and came into force from 1st May 2012 onwards. The concerned ministry later amended the rule which became effective from 1st April, 2023. EPR E-Waste management rules are applicable to every producer, bulk consumer, dismantler, collection center, and recycler of electronic waste involved in the sale, purchase, manufacture, and processing of electrical and electronic equipment. It includes their spares, parts, consumables, and components which are necessary to make the product operational.
Producers are legally bound to obtain an EPR certificate from the CPCB and fulfill their extended producer responsibility targets. Targets are the percentage of generated total electronic waste that must be collected and recycled in the given period of time.
What are Electrical and Electronic Equipment under EPR?
As per the E-Waste Management Rules, EEE (Electrical and Electronic Equipment) means those devices or equipment which are dependent on electro-magnetic field or electric current to become functional. Whereas, E-Waste are EEE whose some part or whole device is discarded as waste, and rejected from manufacturing, repair, and refurbishment process.
Since e-waste contains hazardous substances such as lead, mercury, cadmium, etc., it has the potential to cause health risks and harm the environment. Thus, the rules encourage producers to take steps that are essential to manage e-waste in a proper manner.
The rules categorize EEE under two heads namely IT and Telecommunication Equipment and Electronics and Consumer Electricals such as ACs, TV, Washing Machine, etc. The CPCB has released a list of EEE that fall under the EPR framework. These are as follows:
- Centralized Data Processing Main Frame
- Centralized Data Processing Minicomputers
- Personal Computers
- Laptops
- Notebook Computers
- Notepad Computers
- Printers including Cartridges
- Typewriters
- Telephones
- Television
- Refrigerators
- Washing Machine
- Air Conditioners
- Mercury-containing and Fluorescent Lamps
- Walkie Talkie
- Smart Watch, VR Cameras, Bluetooth Headset, etc.
- Wi-Fi devices and Modem
- Scanners
- Investors
- Speakers, Home theatre, Sound Bar, Multi-Media Speaker, etc.
What is Target-Based Approach Under EPR E-Waste Rules?
The EPR promotes the establishment of an effective e-waste collection mechanism and aims to reduce hazardous substances in EEE. As per the rules specified for e-waste management in India, producers are mandated to meet the annual targets of E-waste collection.
Target based approach under the EPR E-waste rules lays down guidelines on phase wise targets for collection of e-waste either in weight or numbers. In addition, it is necessary for every producer to ensure that their EEE do not contain hazardous substances beyond the prescribed maximum limit.
The targets are based on sales of EEE or previously sold EEE and are as follows.
| Year | E-Waste Recycling Target (as per weight) |
|---|---|
| 2023-2024 | 60% of the quantity of Electrical and Electronic Equipment (EEE) placed in the market. |
| 2024-2025 | 60% of the quantity of Electrical and Electronic Equipment (EEE) placed in the market. |
| 2025-2026 | 70% of the quantity of Electrical and Electronic Equipment (EEE) placed in the market. |
| 2026-2027 | 70% of the quantity of Electrical and Electronic Equipment (EEE) placed in the market. |
| 2027-2028 | 80% of the quantity of Electrical and Electronic Equipment (EEE) placed in the market. |
| 2028-2029 onwards | 80% of the quantity of Electrical and Electronic Equipment (EEE) placed in the market. |
Note: E-waste recycling targets for importers are stipulated at 100% after the product is no longer in use and reaches the end-of-life phase. The targets will not apply to waste generated from solar PV modules, cells, or panels.
Producers who have recently started operations and their product’s average life is greater than its years of sales operations, then they are required to follow the below-mentioned targets.
| Year | E-Waste Collection Target (as per weight) |
|---|---|
| 2023-2024 | 15% of the sales of FY 2021-22 |
| 2024-2025 | 20% of the sales of FY 2022-23 |
| 2025-2026 onwards | 20% of the sales of FY of preceding two years. |
Who are Producers under E-Waste EPR Certificate Rules?
The CPCB generates an EPR certificate in favor of a producer when it receives the required information as per the SOP (Standard Operating Procedure). SOP specifies the information that must be provided in the application and the documents needed to obtain the EPR certificate. Under the EPR rules, producers are any person who:
- Offers to sell or manufacture electrical and electronic equipment and their consumables, parts, spares, or their components under the brand name of its own.
- Sell under its brand name the assembled electronic and electrical equipment, and their consumables, components, spares, or parts produced or supplied by any other manufacturer or supplier.
- Sell imported electrical and electronic equipment, etc.
Note: Producers encompass all the entities involved in the above-mentioned activities irrespective of their selling technique, such as retailers, e-retailers, and dealers.
In addition, the rules cover a manufacturer who is an entity or a person that has manufacturing facilities of EEE. Refurbisher are those who repair or assemble used EEE to extend its working life and sell in the market. Lastly, recyclers are engaged in reprocessing and recycling of waste electrical and electronic devices, their components or parts to recover precious and semi-precious metals, and other useful materials that can be recovered.
Who is not Covered Under the E-Waste Management Rules?
The E-Waste Management Rules do not apply to the following:
- Plastic Packaging and other plastic waste which is covered under the Plastic Waste Management Rules 2016.
- EPR Certificate For Battery Waste as these are regulated under the Battery Waste Management Rules 2022.
- Radio-active waste as they are covered under the Atomic Energy Act 1962.
- Micro Enterprises as defined in the MSME Act 2006.
Which Documents are Required for E-Waste Certificate?
EPR E-Waste certificate remains valid for 5 years from the date of grant of certification. After this, the producers are required to renew their registration certificate 120 days before its expiration. To obtain the certificate, producers have to submit basic information and request documents, such as:
- Company Name/ Trade Name
- Official E-Mail ID
- Legal Name
- CIN or Incorporation certificate if available
- Land Line number if available
- GST Certificate
- IEC is available
- Company’s PAN if available
- PAN of the authorized person
- Name, Address, Company Email-Id, and Contact Information of Authorized Person
- Postal Address from where sale is being managed i.e., corporate official address.
- List of EEE and their codes.
Along with this basic information, producers are required to submit details on the following:
- Quantity of EEE sold in the market in the specified financial year (for those producers whose market presence is either equal to or greater than the average life of its EEE).
- Sales data is given in metric tonnes.
Note: Producers whose market presence is less than the average life of its EEE are only required to provide quantity sold data since the time sales started.
- A scanned copy of a cover letter signed by an authorized person specifying that the information provided is not false and true to the best of his knowledge.
- Self-Declaration
- CA certificate which certifies EEE quantity sold in the financial year.
- Signature on the designated place in the ROHS (Restriction of Hazardous Substances) declaration.
- Awareness Plan of EPR For Plastic, E-Waste, or Other Waste.
In case the application is found incomplete, the CPCB will communicate all shortcomings to the applicant within 25 days.
What is Extended Producer Responsibility (EPR) Plan?
The EPR Certificate registration process mandates producers to submit an EPR plan. The plan provides details for achieving targets and collection and recycling mechanisms of e-waste generated by the producer. The plan includes the following key information:
Collection and Storage Plan:
Producers have to submit their EPR plan specifying their scheme or method for channelizing their e-waste. It must include a brief write-up and diagram or flow chart depicting e-waste movement.
Channelization Scheme:
It includes information on returning e-waste by consumers or bulk consumers, either through a buy-back program, exchange system, take-back system, or dealers. If the e-waste is channeled through the ‘Deposit Refund Scheme’ (DRS), then it must provide details about the mode of refund.
Dismantlers and Recyclers:
The Plan must encompass the information on authorized recyclers or dismantlers for channelization of e-waste. Specify the name, address, contact details, and processing capacity of authorized recycling facilities or dismantlers which are part of the channelization scheme of the producer.
Collection Centres:
Producers have to provide details of their collection center. It must include information such as the name and location of the entity who is operating these centers.
What is the Cost of an EPR Certificate for E-Waste?
The fee structure for producers willing to obtain the certification or renew the existing certificate depends on the annual E-Waste targets. Producers who have just started operations have to pay the processing fees of INR 10,000.
Those who are already in the business and have annual recycling targets are required to pay the processing fees as follows:
- Target less than 50 MT: Rs. 2,500
- 50 MT – 100 MT: Rs. 7,500
- 100 MT – 1000 MT: Rs, 1,50,000 (1.5 Lakhs)
- 1000 MT – 5000 MT: Rs. 10,00,000 (10 lakhs)
- More than 5000 MT: Rs, 15,00,000 (15 Lakhs)
For amendment in existing EPR certificate, revision in EPR targets, and conversion from EPR authorization (for producers) to EPR registration, the processing fee is Rs. 10,000.
The fee structure for recyclers, manufacturers, and refurbishers is as follows:
Recycler:
- New Recycler (Registering for the 1st time – 5-year validity): Rs. 15,000
- Renewal (after five years): Rs. 7,500 + Rs. 0.625 per MT
- Amendments: Rs. 3,000
Manufacturer:
- One Time Registration: Rs. 15,000
Refurbisher:
- New Refurbisher (1st time registration): Rs. 15,000
- Renewal: Rs. 7,500 + Rs. 0.625 per MT
- Amendment: Rs. 3,000
Note: Annual Maintenance charges for all stakeholders (manufacturers, producers, recyclers, and refurbishers) is Rs. 5000.
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