Introduction: Responsibilities of Producers & Manufacturers under E-Waste 

Electrical or electronic devices that are discarded and can no longer be used constitute e-waste. This includes discarded televisions, refrigerators, computers, laptops, mobile phones, chargers, motherboards, etc. technology is developing at a very fast pace, as a result, e-waste is also increasing at an equal pace.

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To deal with this increasing volume of e-waste, MoEF & CC introduced the E-Waste (Management and Handling) Rules of 2011 which were replaced by E-Waste Management Rules, 2016. In the sustainable management of e-waste, various stakeholders’ like- manufacturers, producers, collection centers, dealers, refurbish, consumers, dismantlers, recyclers, state governments are involved. All of them have different responsibilities. Here responsibilities of manufacturers and producers are discussed. 

Responsibilities of Manufacturer

• A Manufacturer should apply for authorization from the concerned SPCB in Form 1 (a). SPCB issues authorization in Form 1 (bb).
• During and after the process of manufacturing the generated e-waste should be collected by the Manufacturer. The generated e-waste should be dispatched for recycling or disposal.
• While storing or transporting e-waste, it is the responsibility of the manufacturer to ensure that no damage is caused to the environment.
• A manufacturer must keep the records of e-waste generated, handled, and disposed of in Form 2. These records are to be kept open for scrutiny by SPCB.
• Before 30th June, annual returns are to be filed in Form 3, to the concerned SPCB. 

Responsibilities of Producer

Producers producing electrical and electronic equipment (EEE) mentioned in Schedule I have the following responsibilities: 

The concept of Extended Producer Responsibility (EPR) has been introduced in these rules. Implementing EPR principles is the Producer’s responsibility. EPR has the below-mentioned framework:

• Collecting and directing the generated e-waste as per the EEE code specified in Schedule I.
• The process of directing e-waste from service centers to authorized recycler or dismantler shall be as per EPR Authorization, which should comprise of a general scheme for the collection of waste and channelizing it to authorized recycler or dismantler. In the case of mercury-containing lamps or other fluorescent lamps, for which recyclers are not available, the direction may be from collection centers to Treatment, Storage, and Disposal Facility (TSDF).
• In the case of disposal in TSDF, disposal is necessarily preceded by pre-treatment to disable mercury and reduce the volume of waste.
• In order to facilitate end-of-life EEE, Producers must provide contact details on their website and through product user documentation to the consumers or bulk consumers.
• The producer can implement EPR individually or collectively. In the case of individual producer responsibility, the Producer might set up his own collection center or execute a take-back system. If the producer opts for a collective system, getting tied up with an e-waste exchange or a PRO as a member is an option. In the case of an individual producer, it is mandatory to obtain EPR-Authorization from the CPCB. 
• Spreading mass awareness through different means of communication. The equipment is to be accompanied by product user documentation which shall contain the following information-

1. Toll-free/helpline numbers, website, address, and e-mail address
2. Hazardous constituents in EEE
3. Risks of improper handling, disposal, accidental breakage, damage or improper recycling of e-waste
4. Do’s and Dont’s for handling and disposal of equipment 
5. Details of deposit refund scheme and other means available to return e-waste
6. Affixing a visible, legible, and indelible symbol on the products or product user documentation to prevent e-waste from being dropped in garbage bins containing waste destined for disposal

If the Producer has included a deposit refund scheme in the EPR plan, it is mandatory to give information regarding its implementation.

Only the Producers possessing EPR-Authorization, are allowed to import EEE.

The records of the handled waste must be maintained in Form 2 and kept open for scrutiny by CPCB or concerned SPCB. 

Annual returns are to be filed in Form 3 to CPCB by 30th June.