Overview of EPR Fulfilment in E-Waste Management
The rapid urbanization, industrial expansion, advancements in information and communication technologies,
and the increasing consumer demand for new electronic products have led to a significant rise in
electrical and electronic waste (e-waste). To address this challenge, the adoption of Extended Producer
Responsibility (EPR) has become a prominent strategy for managing e-waste in recent years.
EPR is a widely implemented policy approach for e-waste management, aiming to mitigate the harmful
impacts of improper handling and disposal. E-waste contains hazardous substances like lead, cadmium,
brominated flame retardants, chromium, and polychlorinated biphenyls (PCBs), which can contaminate soil,
water, and food, posing serious risks to human health and the environment. Additionally, e-waste is rich
in valuable metals such as iron, copper, tin, nickel, zinc, lead, gold, silver, and palladium. PCBs also
contain precious metals, including rhodium, ruthenium, palladium, osmium, iridium, and platinum, known
as the Platinum Group Metals (PGM). In India, the high rate of e-waste collection is driven by its
valuable content. However, much of this collection and recycling is conducted by informal sectors, often
in environmentally harmful ways, leading to significant health risks.
Important terms related to EPR Fulfilment in E-Waste Management
- Electrical and Electronic Equipment
Refers to devices that rely on electric
current or electromagnetic fields to operate, as well as equipment used for generating,
transferring, and measuring electricity.
- E-Waste
Refers to electrical and electronic equipment, including solar
photovoltaic modules, panels, or cells, that has been discarded, either in whole or in part, as
waste or rejected during manufacturing, refurbishment, or repair processes.
- Extended Producer Responsibility (EPR)
Refers to the obligation of producers of
electrical or electronic equipment to achieve recycling targets through registered e-waste
recyclers, ensuring the environmentally responsible management of such waste.
- Target
Refers to the specific amount of e-waste that a registered recycler must
process on behalf of the producer to meet EPR obligations.
Who is eligible?
The entities shall register on the portal in any of the following categories:
Manufacturer- Producer
- Refurbisher
- Recycler
Non-applicability of the E-waste rules under EPR Fulfilment in E-Waste Management
The E-waste rules do not apply to the following:
- Battery waste, as
outlined by the Battery Waste Management Rules, 2022
- Plastic packaging, as
specified by the Plastic Waste Management Rules, 2016
- Micro-enterprises, as
defined by the Micro, Small, and Medium Enterprises Development Act, 2006
- Radioactive waste,
which falls under the Atomic Energy Act, 1962
Fees for registration under EPR Fulfilment in E-Waste Management
The Central Pollution Control Board may impose registration fees and annual maintenance charges on
entities seeking registration under these rules. The fees will be based on the volume of e-waste
generated, recycled, or managed by the entities, as determined by the Central Pollution Control Board
with the approval of the Steering Committee.
Sale, Transfer, and Storage of E-Waste
Manufacturers, producers, refurbishers, and recyclers are allowed to store e-waste for up to 180 days.
They must maintain detailed records of the sale, transfer, and storage of e-waste and make these records
available for inspection. The Central Pollution Control Board may extend this storage period up to 365
days if the e-waste needs to be stored for the development of recycling or reuse processes.
Documents required
- Trade Name / Company
Name
- Legal Name
- Mobile Number
- Official e-mail id
- CIN / Incorporation
Certificate (if available)
- GST
- IEC (if available)
- PAN of company (if
available)
- PAN of Authorized
Person
- Postal Address
- Name of the
Authorized Person and Address, Company E-mail ID, and Telephone Numbers
- List of electrical
and electronic equipment from the list of notified EEEs, along with their
codes for which Registration is required.
Challenges of EPR Fulfilment in E-Waste Management
Managing e-waste presents significant challenges for developing countries like India, although
improvements are underway. Some key challenges in EPR fulfillment for e-waste management include:
- Cherry-Picking
The E-waste Rules cover both IT waste (e.g., computers, mobile
phones) and Consumer Electronics (e.g., televisions, refrigerators, washing machines, air
conditioners, and lamps). However, there is a common misconception that e-waste primarily
involves IT waste. Consequently, cherry-picking occurs, where only valuable components are
recycled, while less desirable items, such as CRT TVs or lamps, are often ignored by many
recyclers.
- Minimal Compliance
Companies, ranging from large multinational original equipment manufacturers (OEMs)
to small importers of electrical and electronic equipment (EEE), often aim to minimize
compliance costs for e-waste management and may cut corners to achieve this.
- Lack of Sufficient Regulatory Capacity
In India, the approach to e-waste
management is largely driven by compliance rather than factors like consumer demand,
environmental leadership, or resource efficiency. The insufficient regulatory capacity at both
central and state levels—due to limited manpower and resources—also leads businesses to opt for
minimal compliance.
- Lack of Awareness
A significant challenge is the lack of awareness regarding the
harmful effects of improper e-waste management practices. This issue affects not only key
business decision-makers but also extends to consumers, influencing their behavior in dealing
with e-waste.
Benefits of EPR Fulfilment in E-Waste Management
When effectively designed and implemented, Extended Producer Responsibility (EPR) can offer substantial
environmental, economic, and social benefits. Some of the key benefits of EPR fulfillment in e-waste
management include:
- Encourages Innovative and Sustainable Business Models
EPR drives the adoption of
innovative and sustainable business models that focus on waste management, product design, and
alternative materials. These models can deliver significant environmental advantages by reducing
the need for new products and materials, while also enhancing competitiveness and creating new
job opportunities.
- Reduces the Need for Virgin Resource Extraction
EPR legislation may establish
targets for reuse, recycling, and the incorporation of recycled content for producers,
importers, and brand owners. Meeting these targets helps prevent waste mismanagement and
supports the recovery and recycling of waste into secondary raw materials, reducing the reliance
on virgin resource extraction.
- Promotes Eco-Friendly Innovation and Design
EPR encourages industries to take
back their products at the end of their lifecycle, incentivizing the development of designs that
enhance recyclability and reduce the environmental impact of waste. EPR implementation can also
include incentives for environmentally conscious product design.
- Creates Employment Opportunities
EPR fosters job creation and supports economic
development by generating opportunities in waste collection, processing, and marketing. The
establishment of collection centers and recycling facilities under EPR compliance promotes the
growth of a formal recycling industry, employing thousands of people involved in e-waste
management.
Responsibilities under EPR Fulfilment in E-Waste Management
- Manufacturer Responsibilities
- Register on the designated portal.
- Collect and recycle e-waste generated during the manufacturing of electrical and
electronic equipment.
- Submit annual and quarterly returns using the prescribed format on the portal by the
end of the month following the respective quarter or year, whichever is earlier.
- Producer Responsibilities
- Registering on the portal.
- Achieving and implementing extended producer responsibility (EPR) targets.
- Raising awareness through media, publications, advertisements, posters, or other
communication methods.
- Submitting annual and quarterly returns in the prescribed format on the portal by
the end of the month following the relevant quarter or year.
- Refurbisher Responsibilities
- Register on the portal.
- Collect e-waste generated during the refurbishment process, hand it over to a
registered recycler, and update the portal with the relevant information.
- Ensure that refurbished equipment complies with the standards set by the Ministry of
Electronics and Information Technology's Compulsory Registration Scheme and the
Bureau of Indian Standards (BIS).
- File annual and quarterly returns in the specified format on the portal by the end
of the month following the applicable quarter or year.
- Recycler Responsibilities
- Register on the portal.
- Ensure that their facility and recycling processes comply with the standards and
guidelines established by the Central Pollution Control Board.
- Send any non-recyclable fractions or materials to appropriate registered recyclers.
- Ensure that residues from the recycling process are disposed of at authorized
treatment, storage, and disposal facilities.
- Maintain records on the portal of e-waste collected, dismantled, recycled, and sent
to registered recyclers, and make these records available for verification or audits
when needed.
Why Choose SeaRoot
SeaRoot offers expert guidance in helping businesses understand how EPR Fulfillment in E-Waste Management
can benefit their operations. As businesses grow, the demand for effective EPR solutions will also
increase, and SeaRoot is positioned as a leading partner to assist in achieving these goals.
At SeaRoot, we simplify complex registration processes and provide tailored support in planning your EPR
fulfillment journey. This includes analyzing your total production quantity, types of materials used,
and setting achievable targets while identifying challenges and offering practical solutions. Our team
also handles all the necessary legal paperwork to ensure a smooth initiation of the EPR fulfillment
process, allowing businesses to focus on their growth while staying compliant with regulatory
requirements.
Frequently Asked Questions
1.What kinds of products are covered under EPR for e-waste management?
EPR covers a wide range of electrical and electronic equipment, including IT products (computers,
mobile phones, etc.) and consumer electronics (televisions, refrigerators, washing machines,
etc.).
2.How long can e-waste be stored by manufacturers, producers, or recyclers?
E-waste can be stored for up to 180 days. In special cases where storage is required for the
development of recycling or reuse processes, the Central Pollution Control Board may extend this
period to 365 days.
3.What are the responsibilities of a producer under EPR?
Producers are responsible for registering on the portal, meeting EPR targets, raising awareness
through various media, and submitting annual and quarterly returns regarding their e-waste
management activities.
4.What happens if an entity does not comply with EPR guidelines?
Non-compliance with EPR guidelines can result in penalties, legal actions, or the revocation of
licenses by the Central Pollution Control Board or other regulatory authorities.
5.How does EPR contribute to environmental sustainability?
EPR promotes recycling, reduces the need for extracting virgin resources, and encourages the
design of eco-friendly products, thereby minimizing the environmental impact of e-waste.
6.How are registration fees determined for EPR compliance?
Registration fees and annual maintenance charges are determined based on the volume of e-waste
generated, recycled, or managed by an entity, as per the guidelines set by the Central Pollution
Control Board with approval from the Steering Committee.
