EPR Registration

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An Overview of E-Waste (Management & Handling) Rules, 2011

E-Waste (Management & Handling) Rules, 2011, were promulgated by the government in 2011 & has entered into play since 1st May 2012. To enable seamless execution of E-based waste rules and clearly outline the roles of producers under E.P.R., MoEF & CC, G.O.I. has introduced the E-Waste (Management) Rules, 2016 vide G.S.R. 338(E) dated 23.03.2016, which came into force on 01-10-2016.
All of these guidelines revolve around the concept of Extended Producer Responsibility (EPR). The E-Waste (Management) Rules, 2016, include a phase-wise collection target for the accumulation of e-based wastes, either in weight or number, that shall be thirty percent of the estimated quantity of waste produced during the first two years of rule implementation, forty percent during the third and fourth years, fifty percent during the fifth and sixth years, and seventy percent during the seventh year.
The Central Pollution Control Board, i.e. CPCB, is mandated by the E-Waste (Management) Rules, 2016, which include specific norms related to EPR, channelization, accumulation facilities, storage, transportation, eco-friendly recycling, refurbishment, and sampling of EEE for testing of RoHS guidelines.

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EPR Registration for Producer and Importer

The E.P.R. Authorization delegated to producers/importers the task of appropriately disposing or recycling post-consumer E-waste in accordance with the Plastic Waste Management Rules, 2016. E.P.R. (Extended Producer Responsibility) is an environmental and economic strategy to managing a product’s lifecycle.

It includes prevention, proper disposal, and systematic recycling. There are primarily three types of authorization, specifically

Authorization for import
Manufacturing approval
Authorization at the wholesale level

It is vital to remember that the manufacturing permit is the most difficult to obtain because it requires substantial infrastructure and training expenditure. For Indian or international makers or importers of electronic devices for E-waste management, the E.P.R. certification is a legal requirement.

Why Government introduced E.P.R. Authorization?

With the rapid increase in e-waste, G.O.I. reviewed the current legislative choices and found that handing responsibility to makers and importers may be the best method to address such a situation.

Extended Producer Responsibility, in general, refers to a policy-based strategy in which makers are held accountable for the smooth treatment or disposal of post-consumer products.

E.P.R. strives to ensure:

Improved waste prevention at the source
Environmentally friendly product manufacturing
E-waste recycling and management that is seamless

Two sorts of electrical and electronic devices namely:

IT and telecommunications-related items
Televisions, refrigerators, air conditioners, washing machines, mercury-containing lights, and other consumer electronics

Potential benefits of EPR registration

The following benefits are available to EPR registration holders:

Increased market trust as a result of the commitment to minimise e-waste
Access to a clear framework that ensures successful e-waste management at a cheap cost
Improve coordination with allied units for e-waste disposal.
Give a credible image to the international market.

How to apply for EPR Authorization?

Every manufacturer requesting E.P.R. authorization must submit an application in the required format, namely Form-1 of the E-Waste (M) Rules, 2016. The application must be filled out completely and accompanied by any required papers.
According to the E-Waste (M) Rules, 2016, the applicant must submit a completed application to the Member Secretary of the Central Pollution Control Board.
Form-1 should include the legal information about the accumulation and channelization of e-waste as specified in sections 2.1.1 to 2.1.7.

Documents Required for EPR Authorization

Legit address of the proof producers/importer
Copy of G.S.T. certification reflecting the address of the business place
Copy of business certification granted by R.O.C.s or Directorate of Industries or Local Body, or DGFT
Copy of Certificate / Document
Items details such as the batch number and model number
Details of electronic goods offered to market (in chronological orders reflecting quantity, number and weight etc. ) during last ten years
Valid BIS registration
Copy of I.S.I. mark or BIS registration number, if applicable
Details related to the Reduction of Hazardous Substances (RoHS) compliance
Estimated generation of WEEE
Extensive EPR plan encompassing detail relating to collection method, challenization of e-waste, website information, etc.
Details of upcoming awareness programs.
Budget for accumulation & challenization schemes
Self-declaration related to RoHS compliances
Declaration regarding the management of technical documents on RoHS as per EN50581.
Legal consent granted by the concerned department/ministry for selling their product
Copies of agreement with dealers, collection centres, and recyclers
Copy of agreement with TSDF (in case of CEEW5)
Copy of agreement with PRO (if applicable)

Shedding light on the Extended Producer Responsibility Plan

Plan for Increased Producer Responsibility (E.P.R.- Plan) E.P.R. Plan generally functions as an implementation plan of the producer linked to collection, processing, and channelization of e-waste created at the facility.

Improved waste prevention at the source
Environmentally friendly product manufacturing
E-waste recycling and management that is seamless

The plan for EPR aims to

Estimate the quantity of E-waste generated from the consumer's end.
The broad plan for collecting and channelling e-waste with the same E.E.E. code to approved recyclers.
Budget estimate for flawless EPR implementation
Plan strategies for raising awareness about e-waste prevention and management.
Compel the manufacturer to assure RoHS compliance and provide a declaration together with the relevant paperwork.

Manufacturers have the right to revise their EPR plan on a timely basis and provide information to the relevant body, namely the CPCB. In such cases, the E.P.R. permission is amended.

Rights of the License Holder After Registration

The CPCB expects licence holders to comply with the following conditions under the E-waste (management) Regulations, 2016.

The producer must respect to the authorized EPR plan.
The accumulation process or mechanism should be established in compliance with the EPR strategy that has been approved.
The producer should keep documentation for e-waste channelization. Recyclers are likewise likely to adhere to this criteria.
Producers are required to keep electronic waste records, as defined in Form 2 of these rules, and to produce such records to the CPCB during the inspection.
Producers must file a yearly return in the required form, namely form 3, with the CPCB on or before the 30th June following the fiscal year to which the returns pertain.
Registration holders must keep technical documentation on RoHS for inspection purposes.
Introduction of new items requires prior notification to the relevant authority via Enclosure A.
The inclusion of RoHS information on product brochures or booklets is a legal requirement.

Contact Lockene for a hassle-free EPR authorization.

As can be seen from the foregoing, the EPR permission requires a large amount of documentation and possibly some level of field-based knowledge, given the number of compliances that must be met.

At Lockene you will have access to the following benefits:

Expert professional assistance from Lockene
Licenses are delivered quickly and smoothly within the time frame agreed upon.
Identification of applicable compliances and legality for registration on the spot