EPR Authorization

EPR stands for Extended Producer Responsibility. As per the EPR Rules of India, EPR Registration is mandatory for producers, importers, brand owners and manufacturers that are involved in the products generating e-waste, plastic waste, battery waste or tyre waste. They need to get the EPR Certificate to compensate for the waste caused by their products in the market. This policy is based on the polluter pays principle. It supports the idea of sustainable development and keeps the waste generation of the country in check.

The producers need to get EPR Authorization and remove the waste caused by them and the same shall be reported to CPCB every year. This eases the burden from the shoulders of the central and state government as it doesn’t have to worry anymore about the effort and money that the waste management would have taken. What if one doesn't follow the EPR? Well, without EPR Certification, no entity in India to who’s its applicable can run the business activities legally and violation of rules and regulations concerning EPR can result in penalties.

What is EPR Authorization?

In this period where environmental considerations are increasingly central, tackling the waste management problem is a critical step towards building a sustainable future. 

EPR authorization is an important part of this ecosystem, we will explore what it means and why it is necessary. An Extended Producer Responsibility (EPR) permit is a license issued by the Central Pollution Control Board(CPCB) to manufacturers, importers, and brand owners (PIBOs) of electrical and electronic equipment (EEE). The EPR Authorization is mandatory and issued for the ecological treatment of generated electronic waste. Industrialized countries are implementing the EPR legislative strategy to promote and encourage the reuse, recycling, and ecological disposal of e-waste. Extended producer responsibility ensures that the responsibility for the disposal of e-waste lies with the producer of the goods. Under EPR programs, manufacturers and importers are legally responsible for the collection, recycling, and safe disposal of their products at the end of their useful life. The permitting process usually involves obtaining approval from the Central Pollution Control Board (CPCB) or relevant national pollution control agencies, which define specific goals and deadlines for waste management and recycling. The EPR permit is an important part of India's efforts to meet its waste management challenges, promote recycling, and reduce the burden on landfills and the environment. This is in line with the country's broader goals of sustainability and a cleaner environment.

• EPR Registration for Plastic Waste Management
• EPR Registration for E-Waste Management
• EPR Registration for Battery Waste Management
• EPR Registration for Tyres Waste Management
• EPR Registration for Used Oil Management

epr-for-plastic-waste-management#epr-for-e-waste-management#epr-for-battery-waste-management#epr-for-waste-tyres#epr-for-used-oil

What is EPR Authorization for Plastic Waste?

As per the Plastic Waste Management (Second Amendment) Rules, 2022, EPR authorization is mandatory for every producer, importer, and brand owner (PIBOs) of Plastic Packaging. Here, both the ‘Primary Packaging’ and ‘Second Packaging’ come under the ambit of Plastic Packaging. Where the former refers to the plastic product itself and the latter means the package which contains the product. These rules mandate PIBOs to register through the online centralized portal developed by the Central Pollution Control Board (CPCB). The motive behind this is to bring improvement, accountability, traceability, and transparency in the fulfilment of EPR Obligations.

Note - PIBOs who operate in more than two states need to register with CPCB and those operating in one or two States/UTs need to be registered with the concerned State Pollution Control Boards (SPCBs).    

What is EPR Authorization for E-Waste?

As per the E-Waste (Management) Rules, 2022, it is the responsibility of every manufacturer, producer, refurbisher, dismantler, and recycler to ensure environmentally sound management of the Waste Electrical and Electronic equipment. For producers, this may include establishing collection centers, a take-back program, or both, as well as having agreements in place with authorized recyclers or dismantlers through a Producer Responsibility Organization (Recognized by the producers in their EPR authorizations).

What is EPR Authorization for Waste Tyres?

Seeing the growing amount of waste tyres and their poor management, the Indian government added the provision of EPR authorization for waste tyres in the Hazardous and Other Waste (Management and Transboundary Movement) Amendment Rules 2022. Under these rules, every entity involved in the production, manufacturing, sale, recycling, or import of waste tyres is responsible for the management of the waste tyres they generate in a safe manner. The motive behind this is the same, protecting the environment and public health from the harmful effects that unmanaged waste tyres can have.  

What is EPR Authorization for Waste Batteries?

As per the Battery Waste Management (BMW) Rules 2022, every producer, including manufacturers and importers of batteries is obliged to follow the Extended Producer Responsibility compliances for the battery they introduce in the market. Besides this, the producers are also required to meet the prescribed targets for the collection and recycling of waste batteries. 

As per these rules, the entities are required to take back the used battery while providing the customer with a new one, and the customers are required to sell the used batteries to the authorized dealer only. Here, The Extended Producer Responsibility (EPR) mandates producers the recycling or refurbishment of waste batteries and prohibits the disposal of the same. However, they are also given an option to authorize other entities for the same purposes. 

What is EPR Authorisation for Used Oil?

The Extended Producer Responsibility (EPR) is also applicable to used oil. It is the oil derived from crude or synthetic oil that has become contaminated as a result of its usage. The producer of base oil and lubrication oil, collection agents of used oil, recyclers and importers of used oil must obtain EPR Authorisation for Used Oil before managing the used oil. The recent amendment to the Hazardous Waste Management Rules included the Used Oil under the EPR regime, but it will only be applicable from April 2024. Under these rules, the mentioned stakeholders need to register on the CPCB portal, fulfil EPR responsibilities and complete EPR Targets as calculated year on year.

How to get an EPR Certificate in India?

The manufacturer/importer of information technology & Electronic products has to provide documentary evidence for the E-waste management plan and agreement with Recycling assistance.

Corpseed provides complete support in EPRA Registration by managing documentation and formalities in getting EPR Certificate.

Aim and Role of EPR Policy

The following are the main aims of Extended Producer Responsibility (EPR) Certification:

• To cover the costs of the products’ end-of-life
• To provide incentives for eco-design
• To achieve resource efficiency
• To assure that recycling is of high quality

Extended Producer Responsibility Policies

Extended producers in India have been established to deal with E-waste and plastic waste, as well as waste batteries and Waste tyres. The Extended Producer emphasizes on the following: -

• According to environmental policy, the stated producer is responsible for decreasing environmental impact and managing the product and its waste over the product's entire life cycle.
• The Central Pollution Control Board has been mandated by Rule 13 (1) (Management) Rules, 2016 to grant, renew, or refuse Extended Producer Responsibility (EPR)-Authorization to producers.
• The Central Pollution Control Board (CPCB) has issued guidance on the implementation of the EPR, including precise instructions for producers and other stakeholders on authorizing, channeling, collection, storage, transportation, environmentally sound disassembly, recycling, and refurbishing.

Who Requires EPR Registration?

As per the E-waste Management Rules 2022, Plastic Waste Management Rules 2022, Battery Waste Management Rules 2022, and Waste Tyre Management Rules, the EPR Authorization is mandatory for those entities that are producing, importing, or brand owners of electronics goods, plastic packaging, lead-acid or lithium-ion batteries, or Tyre Producing respectively. Here, Producers are the parties who initially place a product subject to EPR program standards within the applicable jurisdiction, either via domestic manufacturing or through importation.

EPR certificate has yielded significant results in recent years, in fact, we can say, it has proved to be a game changer for India’s waste management. With EPR authorization, businesses can comply with the regulations and norms prescribed under the waste management rules and avoid any legal consequences. Being an effective environmental approach, Extended Producer Responsibility offers the right path to the entities for a well-organized and sustainable handling of their waste.

Let’s take a look at the major benefits of an EPR certificate:-

• Improves Environmental Compliance

Complying with environmental regulations does not depend on one’s choice. Any business with applicable environmental regulations must comply with them, otherwise, face legal penalties that can negatively impact its day-to-day activities and even lead to closure. Here with EPR authorization, a business can improve environmental compliance and secure itself from incurring fines that would otherwise occur. 

• Better Management of Waste

EPR and its guidelines issued by the CPCB offer businesses a clear understanding concerning the collection, transportation, storage, treatment, recycling, or disposal of their waste. Here, businesses can do the management of all types of waste, be it battery, electronic, tyre, or plastic, alongside ensuring no harm is done to the pollution and the general public. Besides this, it creates a culture of recycling by encouraging producers to adjust their packaging, design, and ways to make products easily recyclable at the end of their life cycles.  

• Reduce Waste Management Costs

It doesn’t like businesses don’t want to manage their waste, many times, they just fail to do it even after spending tons of resources and the reason is the absence of a well-organized path and efficient waste management system. EPR registration mandates businesses to put comprehensive measures in place for effective waste handling, alongside reducing overall expenditures to a great extent. 

• Create a Positive Brand Image

Companies spend millions on advertising and marketing to make a good impression among their targeted audience and here, having an EPR authorization can work in their favor. With it, a business can create a positive brand image in the market, which can further help it strengthen customer relations by establishing credibility with them.

• Saves Money for the Government Exchequer

The extended producer responsibility policy, or we can say, EPR registration in India seeks to establish a more equitable waste management system in which individual entities, rather than general taxpayers, bear the cost of the management of the waste they’re responsible for. This means it can save a substantial amount of money for the Government exchequer, which can come in handy for other development projects for the welfare of the people.

Under the waste management rules of the country, there are certain roles and responsibilities that every entity to whom EPR is applicable, including producers, dealers, collection centers, refurbishers, and dismantlers must follow. 

Key Responsibilities of Producers under EPR Authorization

• Effective collection and recycling/disposal of waste generated due to ‘end of life’ goods.
• Put in place an effective waste channelization system for the waste, including that collected from distributors and authorized service facilities. 
• Provide contact information, including address, email id, and toll-free contact number on its website.
• Create awareness about waste management through different mediums, including media, advertisements, publications, posters, user manuals, etc.
• Provide details about the arrangements with dealers, collection centers, PRO (Producer Responsibility Organization), exchange schemes, etc to collect E-waste.
• Ensures disposal of hazardous waste, especially that contains mercury and lead, in a Treatment, Storage, and Disposal facility (TSDF).
• Filing of annual and quarterly returns as per the prescribed format.

Key Responsibilities of Collection Centres under EPR Authorization

The primary responsibility of Collection Centres is to collect waste, including that generated by orphaned products, on behalf of the producers and recyclers, and at the same time, ensure the collection process happens in compliance with the regulations and guidelines of CPCB (Central Pollution Control Board).

Note:- Orphaned products are products that are non-branded or assembled or produced by a company that has closed its operations.

Key Responsibilities of Dealers under EPR Authorization 

In simple terms, dealers are the entities that buy or receive waste from the producers for sale. 
When the responsibility to collect waste from end consumers comes under their purview, they must ensure to do it in an environmentally friendly way as prescribed under the rules. Such as by providing end consumers with boxes, bin bags, or a certain demarcated area, etc for depositing the generated waste. Thereafter, they also must make sure that the transportation process of the collected waste to the collection centers or recyclers/dismantlers designed by the producers does not harm the environment in any aspect.

Here, a PRO (Producer Responsibility Organization) can play a significant role as it can help producers meet the collection targets, set up collection points, implement take-back schemes, carry out awareness programs, channel the waste, file annual and quarterly returns, etc.

Note:- PROs (Producer Responsibility Organizations) must have a written agreement with the producer(s) defining the PRO's role and responsibilities for waste management.

Key Responsibilities of Refurbishers under EPR Authorization 

• Collection of waste generated during the refurbishing process (Process to improve the quality of used goods) and depositing it to the registered recycler.
• Provide the details regarding the collection of waste on the EPR portal.
• Ensure the refurbished products meet the prescribed standards of quality and safety.
• Filing of annual and quarterly returns as per the prescribed format.

Key Responsibilities of Recyclers under EPR Authorization 

• Make sure the waste recycling plant and the operations involved comply with the standards and guidelines of the Central Pollution Control Board. 
• Ensure the residue that remains after the recycling process gets disposed of in an authorized TSDF (Treatment, Storage, and Disposal Facility).
• Maintain accounts on how much E-waste is collected, dismantled, recycled, and sent to the registered recycling facility and make sure of their availability for purposes, like  verification, audit, etc.
• Filing of annual and quarterly returns as per the prescribed format.
• Receive and recycle the waste products (excluding radioactive materials) not listed in Schedule I of E-Waste (Management) Rules 2022. Uploading the details concerning the same on the EPR portal. 
• Create awareness about waste management through different means of communication. 
• Keep an account for the waste that is not recycled or disposed of and upload the information regarding the same on the EPR portal.

The producers, importers, and manufacturers should obtain EPR authorisation from the Central Pollution Control Board in order to ship the notified waste to the market in the form of their products. You must have the following basic documents based on the kind of waste, to submit your EPR application and obtain the registration certificate-

• ID Proof
• Address Proof
• GST Details
• PAN Details
• CIN Details
• EPR Plan
• Process Flow Diagrams
• Estimate of Waste Generation
• Consent by SPCB or PCC
• DIC Registration
• Declaration of RoHS Compliance
• Copy of Agreement with the Recyclers, Dismantlers and Disposal Facilities
• Import Export Code
• Authorization of Recyclers and Dismantlers

The documents are prescribed by the respective rules of e-waste, plastic waste, battery waste and hazardous waste separately. The producers need to figure out the waste generated by their products and then finalize the document set required for their particular application of EPR Authorization.

Every manufacturer seeking E.P.R. approval must submit an application using the required form, Form-1 of the E-Waste (M) Rules, 2016. The application must be completely filled out and accompanied by any required papers. The applicant must submit a duly completed application to the Member Secretary, Central Pollution Control Board, as per the E-Waste (M) Rules, 2016. Sections 2.1.1 to 2.1.7 of Form-1 should provide the legal information about the collection and channeling of e-waste.

How to apply for an EPR Registration?

• Documentation:- Ensure you have all the documents required for EPR authorization.
• Application Form:- Apply for the EPR authorization through the online registration of CPCB. Application forms can vary as per the type of applicant, like producers, recyclers, and manufacturers. 
• Form Fill-Up and Submission:- Enter and submit all the required information in the application form, and alongside, upload the asked documents. 
• Verification:- The CPCB officials will evaluate the submitted information and the documents for verification purposes. If there are any discrepancies, you can rectify them within 25 days of the submission of the application form.
• Grant:- If approved by the CPCB officials, then you will be granted an EPR authorization within 120 days from the date they receive the application form.
• Refusal:- The CPCB officials can reject the application if it violates any of the CPCB regulations. The application will be completely returned if you fail to respond within 45 days of the rejection or cannot provide the information that most likely led to the rejection. Before completely rejecting the application, CPCB will give you a chance to be heard within one month of the day the application is returned.

The point to be noted here is that CPCB can also revoke your EPR authorization if it finds you in violation of the regulations and norms prescribed under the environmental and waste management rules of the country. Within 25 days of such action by CPCB, you would receive a notification informing you of the same. Here, you would also get a chance to contest the cancellation of your EPR authorization. 

Format of the EPR Authorization Application

PART-A

• Full name and address including respective phone numbers and e-mail addresses of the producers.
• Authorized person’s full address, email, and fax number.
• Details mentioning all electrical and electric equipment produced and placed in the market year-wise for the period equal to its end life as per the provisions mentioned by the CPCB.

PART-B

Approximate generation of E-waste along with an estimated collection target in the form of a table (mentioned on the CPCB website).

PART-C

• A detailed overall scheme to achieve the obligations of EPR plus targets.
• The scheme shall mention all used as well as wasted electrical and electronic equipment.
• It could be through any dealer or centers, Producer Responsibility Organization (PRO), etc.

The format of the scheme should be like this

1. General Scheme of Collecting e-waste
2. Flow-chart and segregation of the e-waste
3. Information on the website.

• Approximate costs of EPR and any other initiative or campaign. 

PART-D

• Compliances related to the Reduction of Hazardous Substances, if applicable.
• If being submitted, the producer shall self-attest a relevant declaration.
• A declaration stating and mentioning all technical documents.

PART-E

Essential documents needed

• EPR Scheme with relevant details
• Agreement Copies with Dealers, Collection Centres, Recyclers/dismantlers.
• Photocopy of the DGFT license
• Relevant ROHS Self-Declarations.

Running a business on the track of growth not only demands infrastructure or capital but also compliance with the rules and regulations of the country. And that’s not optional as their violation can bring legal troubles to your door. This is where Corpseed ITES comes into the picture. Being India’s most trusted environmental and legal consultancy provider, Corpseed has teams of professionals with years of experience and expertise working in the industry. For all your business needs, Corpseed acts as a one-stop solution. 

Why Should You Choose Us? 

• Experts with extensive knowledge of environmental laws and regulations
• Assistance in Documentation 
• Guaranteed Delivery of Permits/Licenses/Authorization within a limited time frame
• Always true to our words
• History of smooth and affordable services

To connect with Corpseed, you can give us a call or raise an inquiry on our website. Our agent will provide you with a free consultation and sort out all the queries you have.

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