EPR Compliance for E-Waste

Attention all businesses committed to sustainability and environmental responsibility! Get ready to embrace a popular term that is revolutionizing the way we handle waste generation - EPR Compliance.

Gone are the days of simply discarding waste without a second thought. Today, EPR Compliance is the driving force behind a new era of responsible waste management. It compels businesses to take ownership of the entire lifecycle of their products, from creation to disposal. By doing so, we can collectively ensure that waste is minimized, recycled, and properly managed, leaving a cleaner, healthier environment for future generations.

So, if you're ready to join the ranks of businesses leading the charge towards a greener future, it's time to embrace EPR Compliance. Let your passion for sustainability shine through as you take control of your waste generation, reduce your environmental impact, and set an example for others to follow. We at corpseed

Create a world where waste is minimized, resources are conserved, and future generations can thrive. Come Embrace EPR Compliance with us as we become catalyst for positive change. Our range of services pertaining to Extended Producer Responsibility (EPR) includes the following: EPR Plastic, EPR Battery, and EPR Tyre.

In this article, we will be talking about EPR Compliances for E-Waste which have to be followed by those businesses that are responsible for generating e-waste.

Highlights EPR Compliances for E-Waste

• Assistance with online credits
• Facilitate Portal Management
• Conduct Waste channelization
• Offer Strategic Consulting 

What is E-Waste?

Rule 3(l) of E-Waste Management Rules, 2022 defines E-Waste:-

“E-Waste means electrical and electronic equipment, including solar photo-voltaic modules or panels or cells, whole or in part discarded as waste, as well as rejected from manufacturing, refurbishment and repair processes.”

When an electrical or electronic product is discarded because of non-working or fault in any part of that product, it usually goes for refurbishment or repair but even if it is rejected from there then it is called e-waste. The latest amendment to the rules also included solar photo-voltaic modules, panels and cells in this definition that were not covered before due to their connection with solar energy. There may be confusion in your mind that electrical and electronic denotes the same thing then why they are written separately here, I would like to clarify that electronic devices are those devices that are involved in the transportation and controlling of electrical energy while on the other hand electrical devices transform electrical energy into some other form of energy that we consume. For example, An electrical Bulb converts electrical energy into light energy that we use in our daily life.

EPR Compliances are divided into categories based on the type of waste. One of them is E-Waste. It is also further classified into various types and every waste is listed in the first schedule of E-Waste Management Rules, 2022. It includes 106 types of different items divided into seven different categories as follows:-

• Information Technology & Telecommunications Equipment
• Consumer Electrical & Electronics & Photovoltaic Panels
• Large & Small Electrical & Electric Equipment
• Electrical & Electronic Tools except for Large Stationary Industrial Tools
• Toys, Leisure & Sports Equipment 
• Medical Devices except for Implanted & Infected Products
• Laboratory Instruments

Role of EPR Annual Compliance for E-Waste

EPR Compliance for E-Waste plays a very significant role to keep our environment neat and clean while also relieving the government from the expenditure of doing so. Specifically, E-Waste is very harmful to the environment considering the damage it can cause to human health. It usually includes very harmful chemicals and toxic substances which have to be disposed of very carefully and responsibly. In the lack of doing so, they can be exposed to the soil, the water, or the air. It can further result in the contamination of crops planted nearby, and water pollution in the rivers flowing nearby. It can also pollute the air if disposed of in the open or burnt and that air can further make people living nearby sick. Mercury, Lead and Cadmium are some of those substances which can cause fatal damage to human beings.

Hence it becomes very necessary for the pollution-controlling bodies to make strict rules on the disposal of such waste and monitor them properly as well as punish the polluters if they do not comply with the rules prescribed.

Scope of EPR Compliance for E-Waste Management 

The E-Waste Management Rules 2022 applies to those producers, manufacturers, recyclers and refurbishes who deal in the production, manufacture, recycling and refurbishing of electrical, electronic and solar photo-voltaic waste. It prescribes rules for the collection, transportation, disposal and overall management of e-waste. The regulatory body is Central Pollution Control Board, which not just prescribe rules but also register all producer, manufacturer, recycler and refurbishes. These people in business have to report to CPCB whenever they deal with e-waste and share detailed data about the same. They are also bound to not deal with any unregistered entity of such kind.

In this article, we are talking about EPR Compliances for E-Waste Management and hence these rules are not applicable to those who are involved in plastic waste, battery waste, radioactive waste or any other hazardous waste. We have discussed these wastes in a different article based on the separate rules prescribed by the government.

EPR Compliances provided in the E-Waste Rules made the management of e-waste very organised in every manner. 

• From Producers to recyclers and from collection to disposal, every process is monitored by Central Pollution Control Board. It ensures safe transport, storage and disposal of e-waste and mitigates any possibility of an accident.
• Also in an unfortunate incident when an accident occurs, the reasons and responsible parties can be easily tracked because of the compulsory data submission on the web portal by all involved entities. 
• It also has provisions to punish those who don’t comply with the rules of proper e-waste management. It motivates the parties to follow the prescribed procedure and avoid any costs they may incur in incidents of non-compliance. And this finally results in a safe environment for all when the stakeholders do their duty with honesty and in compliance with the rules.

Businesses that generate e-waste through their products, have to fulfil various responsibilities as prescribed by the E-Waste Management Rules, 2022. Some of the major responsibilities under EPR Compliance for E-Waste are given below.

The Manufacturers are required to fulfil the following responsibilities:

• To register on the portal.
• To collect e-waste generated from the manufacturing of electronic and electrical equipment.
• To ensure the recycling of collected e-waste if it is recyclable.
• To ensure the disposal of collected e-waste if it’s not recyclable.
• To file annual returns.

The Producers are required to fulfil the following responsibilities:

• To register on the portal.
• To obtain and implement EPR Targets under EPR Compliance for E-Waste
• To migrate their EPR plans from earlier 2016 rules to new rules of 2022.
• To create awareness about waste management through media, publication advertisements, posters or any other communication mediums.
• To file annual returns.

The Refurbishers are required to fulfil the following responsibilities:

• To register on the portal.
• To collect e-waste generated from the process of refurbishing.
• To direct the collected e-waste to the registered recycler.
• To submit details of collected e-waste on the portal.
• To ensure that the equipment is refurbished as per the compulsory registration scheme of the Ministry of Electronics & Information Technology.
• To ensure that the equipment is refurbished as per the standards of the Bureau of Indian Standards.
• To file annual returns.

The Recyclers are required to fulfil the following responsibilities:

• To register on the portal.
• To ensure that the facility and recycling process is following the guidelines prescribed by the CPCB.
• To ensure that if some materials are not recycled on their plant, they have to be redirected to the respective registered recycler.
• To ensure that the residue generated from the recycling process is disposed of in an authorized treatment storage disposal facility.
• To maintain the records of e-waste on the portal for verification and audit purpose.
• To file annual returns.
• To create awareness for recycling through media, publications, advertisements, posters and other communication mediums.

The Bulk Consumers are required to ensure that the e-waste generated by them is handed over to the registered producer, refurbisher or recycler.

Requirements of EPR Compliance for E-Waste

You must be involved in a business of any kind where you produce, sell and distribute the products that are specified in the EEE category and thereby generate e-waste at the end of their life. If you qualify for this condition then you can move on to the registration process of your company with the CPCB which is the first step towards the fulfilment of your EPR targets by following the EPR Compliance for E-Waste.

For registration, you should use the portal managed by the CPCB and respective State Pollution Control Boards or Pollution Control Committee in Union Territories. The Process may differ for different regions. CPCB charges a fee for registration and an annual maintenance fee from the producers, manufacturers, recyclers and refurbishers, who registers themselves on the portal. SPCB & PCC maintains this data and monitors these businesses, their products and recycled e-waste. SPCB & PCC of different states share the latest updates and news regarding rules and procedures on their respective websites.

The requirement for the documents applicable to go through the various processes of EPR Compliance for E-Waste including registration, authorization, certification etc. may differ from region to region but there are some common documents that are generally required for EPR Compliance. The list is given below:-

• Proof of Possession of Premises or Rent Agreement or Lease Deed
• Copy of incorporation certificate 
• MoA of the Company
• Board Resolution
• GST Details
• Pan Details
• EPR Plan under EPR Compliance for E-Waste
• Self-Declaration for compliance with the reduction of Hazardous Substances
• Copies of agreement with dismantlers, recyclers and TSDF (Treatment & Storage Facility)
• Self-Attested copy of Authorization of Dismantlers/Recyclers
• List of producers attached with dismantlers and recyclers along with producers’ collection targets
• Copy of IEC in case of importers along with Excel sheet of a list of imported products

Self-Declaration must be given as per the prescribed format given in the guidelines and procedures for processing applications. EPR plan is a plan submitted by the producer at the time of applying for EPR - Authorization in which the producer is required to provide details of e-waste regarding how he is going to channelize it to achieve the targeted collection.

Some states may specify more documents and details to be submitted while going through various EPR Compliance for E-Waste processes. In Delhi, a certificate has to be acquired from the concerned body and submitted to prove that the location is in conformity with the master plan of Delhi. In Goa, a Site clearance Certificate must be obtained from a local body.

The Ministry of Environment, Forest and Climate Change notifies of rules for the calculation of extended producer responsibility after every few years. These are a few rules that have to be considered for the calculation of extended producer responsibility under EPR Compliance for E-Waste. 

A producer has to go through the following process, but with Corpseed we fulfil EPR Compliance, which cover- 

• Online Credits:- Minimizing EPR credits to achieve the lowest possible cost (Final price is contingent upon the overall Quantity).
• Portal Management:- We specialize in providing extensive data to the CPCB EPR Portal Management in relation to annual compliance, relating to the transfer of EPR credits, and the submission of sales/purchase invoices for both preceding and ongoing years.
• Waste Channelization:- Our team of specialists is committed to assisting your company in effectively redirecting all waste generated within your organization, enabling you to achieve your net-zero and sustainability objectives.
• Strategic Consulting:- Our team of skilled professionals is equipped to offer invaluable perspectives, legal support and guidance to assist you in effectively managing your EPR objectives.

Year-by-Year Renewal of EPR Obligations under EPR Compliance for E-Waste

Producers can only purchase a limited amount of EPR Certificates in a financial year. This limit includes its current year’s EPR liability, any carried forwarded EPR liability of the previous year, and five per cent of the current year’s EPR liability. These certificates can be submitted to the CPCB on a quarterly basis along with the quarterly returns of the producer. The future EPR obligations of the producers are adjusted by the CPCB as per the submitted EPR certificates. Adjustment rules are different for EPR certificates purchased from recyclers and refurbishing certificates purchased from refurbishes. If there is any liability left on the producer after complete adjustment at the end of the current financial year, the remaining EPR obligation/liability, under EPR Compliance for E-Waste, is carried forward to the next year.

Consequences/Punishments in Case of Non-Compliance with the EPR Compliance of E-Waste

The Central Pollution Control Board can punish any stakeholder in case they do not comply with the applicable rules and regulations regarding the management of E-Waste. The event of non-compliance may include the following occurrences:-

• Hiding any information or furnishing false information to get the registration.
• Not complying with the rules prescribed for the reduction of hazardous substances.
• Not complying with any other rule prescribed in the E-Waste Management Rules, 2022.

Note: Kindly complete your EPR product recycling target given by the Central Pollution Control Board for Last Financial Year to save your company from Obligations by avoiding penalties, as Environmental Compensation is up to 5,000 INR per MT.

We at Corpseed have a team having extensive knowledge relating to various horizons of Environmental Laws and Regulations. We perform desk-based research, documentation, and coordination to help clients in establishing their businesses and fulfilling the compliances as prescribed by the applicable rules. We provide the following EPR-related services:-

Our Unique Selling proposition (USP) 

• Freedom from getting dependent on a few recyclers for waste management. We have multiple Recyclers on-boarded with us, this help our client in reducing risk of recyclers monopolies
• Best and lowest recycling per kg rates for post-consumer waste management
• Best and highest collection per kg rates for pre-consumer waste management
• Freedom to change recycler for any state at any point of time if not satisfied with their services
• Implement best practices followed worldwide by fortune 500 companies to manage waste as per
• EPR & Waste management rules given by MoEFCC & CPCB for all waste categories (Plastic,
• E-waste, Battery, Tyre or Used Oil) in India
• Legal support in any notice or penalties if raised by SPCB/CPCB/MoEFCC