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Who Needs Extended Producer Responsibility (EPR) Authorization

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Introduction: Extended Producers Responsibility

India is a rapidly growing market in the field of Electrical and electronic products such as computers, Mobile, Printers, Scanner, refrigerators, LEDs, TV, transformers, capacitor, etc. Electrical and electrical equipment contain a plethora of toxic components including cadmium, lead, and mercury it affects nearly every system in the human body, Polybrominated flame retardants, barium, and lithium even the plastic casing of electronic products contain polyvinyl chloride.

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Manufacturers and brand owners (Producers) are compelled to follow the rules of Extended Producers Responsibility(EPR) producers have the responsibility to manage electrical and electronic equipment after its “End of life” thus the producers are responsible for their products once the consumer discards them.

The producer may analyze their individual requirements and design a collection or product take-back system as they deem appropriate as long as it facilitates the channelization of E-Waste for environmentally sound management.

Producers are responsible for the collection center for the collection of electrical and electronic waste from individual and bulk consumers and channel the waste to collection centers or recyclers/dismantlers. Electronic Equipment contains a toxic component that is harmful to the human body

The producer may opt to implement EPR on his own individually or collectively. There can be two definite types:-

  • Individual Producer Responsibility– IPR means where producer implements Extended Producers Responsibility(EPR) managed on his own by setting up his own authorized collection centers 
  • Collective Producers Responsibility- CPR where producers may authorize common collection centers (CCC) independently or by joining an association as a member. Producers importing electrical and electronic equipment listed in the schedule-I may take authorization from the State where the landing port is located.

The producer may manage a system directly or with the help of any professional agency on his behalf for the collection and channelization system of E-waste by involving relevant stakeholders such as consumers, bulk consumers, NGOs, the informal sector, resident associations, retailers, dealers, etc.

Step-by-Step Process of Extended Producers' Responsibility by Producers:-

Established Collection centers

  • Environmentally sound management related to E-waste including the Collection of e-waste is of prime important work. Collection centers can be open to collect E-waste individually or jointly or it can be a society registered under societies act or a designated agency or a company or an association, thus there is enough scope for evolving various ways in which a collection center can be set up and functional.

Environmentally Sound Dismantling and Recycling of E-waste

  • The E-waste  gathered from  information technology and telecommunication equipment such as Centralized data processing, Mainframes, Minicomputers, Personal computing, Personal computers including Central processing units with input and output devices, Laptop computers including Central processing units with input and output devices, Notebook computers, Notepad computers, Printers including cartridges, Copying Equipment, Electrical, and electronic typewriters, User terminals and systems, Facsimile, Telex, Telephones, Pay telephones, Cordless telephones, Cellular telephones, Answering systems including TVs can contain up to 60 different elements of which some are valuable some are hazardous/toxic and some are both
  • Environmentally friendly recycling/Re-Processing of e-waste begins with dismantling where the gathering of hazardous substances/chemicals is reduced followed by recycling and recovery of the material of economic value and the disposal of the residue in the Treatment Storage & Disposal Facility.
  1. Electrical and Electronic Products for disposal in Treatment, Storage and Disposal Facility, a pre-treatment is necessary to immobilize the mercury and reduce the volume of waste to be disposed of.
  2. Extended Producer Responsibility - Authorization should comprise a general scheme for the collection of Waste Electrical and Electronic Equipment from the Electrical and Electronic Equipment placed on the market earlier, such as through dealers, collection centers, Producer Responsibility Organizations, buy-back arrangements, exchange schemes, Deposit Refund System, etc. whether directly or through any authorized agency and channelizing the items so collected to authorized recyclers;
  3. A producer has the responsibility to provide contact details such as an address, e-mail address, toll-free telephone number, or helpline numbers to consumer(s) or bulk consumer(s) through their website and product user documentation so as to facilitate the return of end-of-life electrical and electronic equipment;
  4. The producer has the responsibility to create  awareness through media, publications, advertisements, posters, or by any other means of communication and product user documentation accompanying the equipment, with regard to
  • Information on the address, e-mail address, toll-free telephone numbers or helpline numbers, and website;
  • Information on hazardous constituents as specified in sub rule1 of rule 16 in electrical and electrical equipment;
  • Information on hazardous of improper handling, disposal, accidental breakage, damage, or improper recycling of e-waste
  • Instructions for handling and disposal of the equipment after its use, along with the Do’s and Don’ts
  • Affixing a visible, legible, and indelible symbol given below on the products or product user documentation to prevent e-waste from being dropped in garbage bins containing waste destined for disposal;
  • Means and mechanism available for their consumers to return e-waste for recycling including the details of the Deposit Refund Scheme, If Applicable For more information Please Visit EPR Authorization
  1. The producer shall opt to implement Extended Producer Responsibility individually or collectively. In individual producer responsibility, the producer may set up his own collection center or implement the take-back system or both to meet Extended Producer Responsibility. In a collective system, producers may tie up as a member with a Producer Responsibility Organization or with e-waste exchange, or both. It shall be mandatory for the individual producer in every case to seek Extended Producer Responsibility - Authorization from Central Pollution Control Board(CPCB)
  2. The producer has the responsibility to provide information on the implementation of the Deposit Refund Scheme to ensure the collection of end-of-life products and their channelization to authorized dismantlers or recyclers if such a scheme is included in the Extended Producer Responsibility Plan. Provided that the producer shall refund the deposit amount that has been taken from the consumer or bulk consumer at the time of sale, along with interest at the prevalent rate for the period of the deposit at the time of take-back of the end-of-life product;
  3. Import of electrical and electronic equipment shall be allowed only to producers having Extended Producer Responsibility authorization 
  4. Maintaining records in the prescribed form of the e-waste handled and making such records available for scrutiny by the Central Pollution Control Board or the concerned State Pollution Control Board (SPCB)
  5. The producer has the responsibility to file annual returns in Form-3, to the Central Pollution Control Board (CPCB) on or before the 30th day of June following the financial year to which that return relates. In the case of the Producer with multiple offices in a State, one annual return combining information from all the offices shall be filed.
  6. The Producer shall apply to the Central Pollution Control Board for authorization in the prescribed Form which shall thereafter grant the Extended Producer Responsibility -Authorization in Form 1(AA).
  7. Operation without Extended Producer Responsibility-Authorization by any producer, as defined in this rule, shall be considered as causing damage to the environment. For any information Please Call or visit  Corpseed E-Waste Management.

And Some Other Steps:

  • Picking shed
  • Disassembly
  • First Size Reduction Process
  • The second Size Reduction process
  • Over-Band Magnet
  • Non-metallic and metallic components Separation
  • Water separation

This portion of the site is for informational purposes only. The content is not legal advice. The statements and opinions are the expression of author, not corpseed, and have not been evaluated by corpseed for accuracy, completeness, or changes in the law.

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Author
Vinay Thakur is Managing Partner in Corpseed. He focused on payments, digital transformation, and financial technology for over 15 years and holds strong expertise on fintech startups, banking innovation, and investors with a keen understanding of...
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