EPR- E Waste Authorization for PIBO
India’s EPR for E- Waste (2022): Shifting Responsibility, Shaping a Sustainable Future
E-Waste (Management) Rules, 2022
These rules shall apply to every manufacturer, producer refurbisher, dismantler and recycler involved in manufacture, sale, transfer, purchase, refurbishing, dismantling, recycling and processing of e-waste or electrical and electronic equipment listed in Schedule I, including their components, consumables, parts and spares which make the product operational.
The E-Waste (Management) Rules, 2022, implemented in India on April 1, 2023, introduced a revamped Extended Producer Responsibility (EPR) framework for electronic and electrical equipment (EEE) waste management.
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Introduction
E-Waste Revolution: A Sustainable Future for Electronics
The future of electronics is circular, not linear. Introducing EPR (Extended Producer Responsibility), a game-changer for E-waste (electronic waste) management in India.
Imagine a world where:
- Businesses thrive: By minimizing resource depletion and embracing a circular economy for electronics, manufacturers can tap into new markets and cost-effective solutions.
- The environment flourishes: EPR significantly reduces E-waste in landfills, minimizing pollution and protecting our planet for generations to come.
- Consumers have a choice: Responsible E-waste disposal becomes the norm, empowering individuals to make sustainable choices about their electronics.
EPR isn’t just good for the environment, it’s good for business.
- Producers take charge: By establishing collection systems and meeting recycling targets, manufacturers can demonstrate environmental leadership and build brand loyalty.
- Innovation sparks: EPR incentivizes investment in advanced recycling technologies, creating new opportunities and jobs in the green economy.
- Resource security: Recycling E-waste recovers valuable materials like precious metals and rare earth elements, reducing dependence on virgin resources and price fluctuations.
Here’s how EPR benefits everyone:
- Reduces E-waste in landfills: Keeps harmful materials out of the environment and protects our health.
- Boosts Recycling: More E-waste gets recycled, creating valuable materials for new products.
- Circular Economy for Electronics: Old electronics get a new life, reducing the need to mine virgin resources.
EPR is still evolving, but here’s what producers can expect:
- Setting Up Collection: Establishing drop-off points or partnering with recyclers.
- Meeting Recycling Targets: Hitting specific goals for the amount of E-waste recycled each year.
- Future-Proofing: Staying informed about online collection systems and EPR certificates (coming soon!).
Stay tuned! As EPR takes hold, expect a cleaner and more sustainable future for electronics.
EPR is a win-win for businesses, the environment, and consumers. This revolutionary approach paves the way for a more sustainable future for electronics, ensuring responsible disposal, resource conservation, and a thriving circular economy.
Eligibility Criteria for E-Waste PIBO
The EPR (Extended Producer Responsibility) program in India’s E-Waste (Management) Rules, 2022 assigns responsibility to various entities within the electronic and electrical equipment (EEE) lifecycle. Here’s a breakdown of the expected eligibility criteria for PIBOs (Producers, Importers, and Brand Owners):
Likely to Apply to Most Businesses Dealing With EEE:
- Production: Manufacturers of EEE in India.
- Import: Businesses importing EEE into India.
- Branding: Companies placing EEE under their brand on the market (even if manufactured by someone else).
Potential Exemptions (Details to be Confirmed):
- Minimal Quantities: PIBOs dealing with very small volumes of EEE might fall below a certain threshold (details yet to be finalized by the CPCB).
- Specific Categories: The government might exempt specific EEE categories from EPR requirements (e.g., essential medical equipment packaging).
Here’s what PIBOs can expect:
- Registration (Expected): PIBOs will likely need to register with the CPCB through an online portal (specific details and launch date to be announced).
- EPR Obligations: Fulfilling responsibilities like:
- Plastic Reduction Strategy: Developing a plan to minimize EEE packaging and explore sustainable alternatives.
- Financial Contribution (Potential): Contributing to a national or state-level fund dedicated to E-waste management initiatives (details on contribution structure awaited).
- Collection System Participation: Participating in or establishing collection systems for post-consumer EEE waste. This could involve:
- Setting up designated collection points for your brand’s EEE.
- Collaborating with waste management companies or Producer Responsibility Organizations (PROs) for collection infrastructure.
- Utilizing designated take-back mechanisms if established by the program.
- Reporting and Recordkeeping: Maintaining accurate records of EEE placed on the market and participating in data collection initiatives as mandated by the CPCB.
- Collaboration with Registered Recyclers: Partnering with recycling plants to ensure proper processing of collected E-waste.
By understanding the eligibility criteria and taking proactive steps towards compliance, PIBOs can play a crucial role in achieving a more sustainable future for E-waste management in India.
E- Waste Categories & Govt Fees
The E-Waste (Management) Rules, 2022, classify electronic and electrical equipment (EEE) into ten broad categories. Here’s a breakdown:
E-Waste Categories:
- Large Household Appliances: Refrigerators, washing machines, air conditioners, TVs, etc.
- Small Household Appliances: Vacuum cleaners, toasters, microwaves, irons, etc.
- IT and Telecommunication Equipment: Computers, printers, mobile phones, personal digital assistants (PDAs), etc.
- Consumer Electronics: Television sets and monitors, audio equipment (including hi-fi amplifiers), electronic toys and recreational equipment, etc.
- Lighting Equipment: Fluorescent lamps, LED lamps, high-intensity discharge lamps, etc.
- Electrical and Electronic Tools: Electric drills, saws, welding equipment, etc., excluding large industrial tools.
- Medical Devices: In-vitro diagnostic equipment, cardiac pacemakers, dialysis machines, X-ray equipment, etc.
- Toys and Recreational Equipment: Electronic toys and entertainment equipment including consoles, gaming equipment, etc.
- Automatic Dispensing Machines: ATMs, vending machines, etc.
- Other E-waste not otherwise specified (NOS)
The fee structure for Producer for registration on EPR Portal under E-Waste (Management) Rules, 2022
A. Grant or Renewal of EPR Registration processing fees for Producers seeking EPR registration under E-Waste (Management) Rules 2022 is given as below:
S. No. | Annual E-Waste Recycling Target | Proposed Charge (Rs.) |
1 | < 50 MT | 2500/- |
2 | 50 MT to <100 MT | 7500/- |
3 | 100 MT to <1000 MT | 1,50,000/- |
4 | 1000 MT to <5000 MT | 10,00,000/- |
5 | >5000 MT | 15,00,000/- |
Note: For Producers whose sales just started, the processing fee will be Rs. 10,000/-
B. Amendments in existing EPR registration in terms of addition of EEE items, revision in the Recycling Target, conversion from EPR Authorization (Producer granted EPR Authorization/renewed EPR Authorization in online mode) to EPR Registration etc.
The processing fee will be Rs. 10,000/-.
C. Amendment in existing EPR registration in terms of addition of EEE items, revision in the recycling target conversion from EPR Authorization (Producer granted EPR Authorization/renewed EPR Authorization in offline mode) to EPR Registration etc.
The processing fees will be Rs. 10,000/- along with additional charges as per point A above.
Documents Requirement for Registration
The main documents required to obtain EPR Authorization for E-Waste Management Business are
Before setting a plant you will be required some licenses:
- Company Incorporation
- GST Registration
- Authorization from SPCB
- Registration under PWM (Connect with team for full documentation)
Documents Required for Registration:
- GST Certificate
- Company Incorporation Certificate (for Pvt ltd / public ltd
- Authorized Signatory Aadhaar Card
- Authorized Signatory PAN Card
- Electricity Bill
- Layout Plan
- MOA (for Pvt ltd / public ltd)
- Topo map
- Water Bill
- Rent Agreement/ Property Paper
Documents required for Manufacturing of Plastic Raw Material:
- Aadhaar & PAN Card Authorized Signatory
- GST Certificate
- Valid CTE & CTO
- DIC or DCSSI Certificate
Registration Process In India
The specific registration process for PIBOs (Producers, Importers, and Brand Owners) under India’s E Waste Management Rules (2022) is still under development by the Central Pollution Control Board (CPCB) However, based on general practices for environmental registrations, here’s a likely scenario for the registration process:
1. Stay Updated:
- Official Guidelines: Once released, carefully review the official guidelines or notifications issued by the CPCB detailing the registration process, eligibility criteria, and government fees (if applicable).
2. Prepare Registration Documents:
- Gather Required Documents: Compile the documents likely needed, such as:
- Business Details (company registration documents, PAN card, GST registration)
- Facility Details (address of any E-Waste storage or sorting facilities)
- Details of E-Waste : Information on the types and volumes of E-Wate you handle (production, import, or branding)
- Waste Management Plans: Outline your plans for managing -E-Waste generated by your products (potential collaboration with waste management companies or Producer Responsibility Organizations – PROs). This might include details on collection mechanisms and responsible disposal practices.
- Financial Capability Demonstrations (potential requirement) – Documents showcasing your financial stability to ensure fulfillment of EPR obligations.
- Business Details (company registration documents, PAN card, GST registration)
3. Online Registration Portal:
- Access the Portal: Once the online registration portal becomes available on the CPCB website, use valid login credentials to access it. You might need to create an account if not already registered with the CPCB.
- Fill Out Application Form: Carefully complete the online application form, providing accurate information about your company, E-Waste activities, and proposed waste management plans. Be sure to attach all the required documents in the designated format.
4. Verification and Approval:
- CPCB Scrutiny: The CPCB will scrutinize your application and uploaded documents to ensure completeness and compliance with the regulations. They might request clarifications or additional information if necessary.
- Site Inspection (Potential): Depending on the regulations, the CPCB or designated authorities might conduct a site visit to your storage or sorting facilities (if applicable) to verify compliance with environmental and safety standards.
- Approval Notification: Upon successful verification and review, the CPCB will issue a formal notification of your registration approval
Renewal of Registration
i. PIBO shall submit the application for renewal four months before the expiry of the Registration along with the necessary documents as discussed in the previous sections.
ii. PIBO have to ensure that Annual Reports are filed by June 30 of the following year (as per EPR Guidelines) for the intervening Registration period. Application for renewal will not be processed unless all due annual
reports are filed.
iii. Findings of Audit Reports shall be taken into consideration for renewal of PIBO Registration.
iv. Registration granted to PIBO shall be renewed for a period of three years by CPCB/SPCBs/PCCs within 15 days of receipt of complete documents from the Producers& Brand Owner.
Important Considerations:
- Timeline: Be mindful of any deadlines associated with the registration process. Early preparation will ensure you have ample time to gather documents and complete the application.
- Seek Professional Guidance: Consulting with (Himsyndicate)environmental lawyers or waste management experts can streamline the registration process and ensure your application adheres to all requirements.
- Stay Compliant: Maintaining compliance with the regulations and renewing your registration periodically will be crucial for continued operation as a registered PIBO under the EPR program.
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