Your Full Guide to EPR Registration
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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 centers, 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, refurbisher) 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 Responsibility aims 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 Authorization ?
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 practiced.
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
1.
Documents & Fee Submission
The applicant must file an EPR Authorization form, all required documents, and a comprehensive EPR Plan for the collection, dismantling and recycling of the products.
Document Scrutiny by CPCB
The Chairman of the CPCB approves or rejects the application based on the EPR plan. In case of incomplete applications or any issue flagged, the applicant will be given a timeframe to resolve such issues.
2.
Grant of EPR Authorization
CPCB issues EPR authorisation within 120 days of receiving the accepted application. In case of amendment in rules, a revised NOC is issued.
3.
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.
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FAQ's
EPR registration aims to shift the obligation of environmental protection through the plastic product life cycle from the consumer to the producer/manufacturer. It intends to reduce the stress caused to the environment by a product from its conception to creation, designing, packaging, and marketing. It encourages take-back programs, recycling initiatives, and proper disposal of both the product and its packaging.
Extended Producer Responsibility, or EPR, is an initiative of the Ministry of Environment, Forest and Climate Change (Government of India). It was implemented under the Plastic Waste Management (PWM) Rules, 2016. EPR registration is essential for manufacturers, producers, importers, and brand owners.
EPR aims to shift the obligation of environmental protection through the plastic product life cycle from the consumer to the producer/manufacturer. It intends to reduce the stress caused to the environment by a product from its conception to creation, designing, packaging, and marketing. It encourages take-back programs, recycling initiatives, and proper disposal of both the product and its packaging.
Any individuals with specific responsibilities or roles can go ahead with the EPR registration process to obtain enhanced access personalised to their needs.
In order to streamline the implementation of EPR, the Ministry of Environment, Forest and Climate Change, Government of India, in its fourth Amendment to the Plastic Waste Management Rules for EPR registration, dated February 16, 2022, notified ‘Guidelines on Extended Producer Responsibility for Plastic Packaging’ in the Schedule II of the Rules. According to the guidelines of this notification, Producers, Importers and Brand Owners (PIBOs) are now mandated for EPR registration through the online portal formed by the Central Pollution Control Board (CPCB).
Yes, users can update their EPR registration details as and when needed. However, they must ensure the details furnished are accurate.
