Overview of EPR Fulfilment in E-Waste Management

The rapid urban development, expansion of industrial activities, the advancement of information and communication technologies, and the human desire for new electrical and electronic products have increased the volumes of electrical and electronic waste (e-waste) generation. The adoption of the extended producers’ responsibility (EPR) principle as a mitigation strategy for e-waste management has gained impetus over the past few years.

Extended producer responsibility (EPR) has been a widely used policy approach for e-waste management. E-waste, if handled and disposed of in an inefficient manner, can lead to an extremely damaging impact on human health and the environment. This is mainly because e-waste comprises hazardous constituents such as lead, cadmium, brominated flame retardants, chromium, or polychlorinated biphenyls (PCBs) that contaminate soil, water, and food. All e-waste is valuable because it contains metals such as iron, copper, tin, nickel, zinc, lead, gold, silver, and palladium. PCBs consist of rare and precious metals such as rhodium, ruthenium, palladium, osmium, iridium, and platinum, collectively known as the Platinum Group Metals (PGM). India has a very high rate of e-waste collection because of its valuable content. Unfortunately, most e-waste collection and recycling is done by informal or unorganized labor in highly environmentally degrading ways, posing serious health risks.

Important terms related to EPR Fulfilment in E-Waste Management

Electrical and Electronic Equipment

It means equipment that is dependent on electric current or electromagnetic field in order to become functional and also the equipment for the generation, transfer, and measurements of electricity.

E-waste

It means electrical and electronic equipment that includes solar photo-voltaic modules or panels or cells, whole or in part discarded as waste and also rejected from manufacturing, refurbishment, and repair processes.

Extended Producer Responsibility

It means the responsibility of any producer of electrical or electronic equipment to meet recycling targets by registered recyclers of e-waste to ensure environmentally sound management of such waste.

Target

It means the quantity of e-waste to be recycled by a registered recycler by the producer in fulfilment of extended producer responsibility.

Who is eligible to apply?

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

E-waste rules would not be applicable to the following:

• Battery waste as defined by the Battery Waste Management Rules, 2022
• Plastic packaging, as defined by the Plastic Waste Management Rules 2016
• Micro-enterprise as defined in the Micro, Small and Medium Enterprises Development Act, 2006
• Radioactive wastes that is covered under the Atomic Energy Act of 1962

Fees for registration under EPR Fulfilment in E-Waste Management

The Central Pollution Control Board may charge such registration fees and annual maintenance charges from the entities looking for registration under these rules on the basis of the capacity of e-waste generated, recycled, or handled by them as laid down by the Central Pollution Control Board with the approval of the Steering Committee.

Sale, Transfer, and Storage of E-Waste

Every manufacturer, producer, refurbisher, and recycler may store e-waste for up to 180 days and must keep a record of the sale, transfer, and storage of e-waste and make these records available for inspection and e-waste storage. The Central Pollution Control Board may extend the said period up to 365 days in case the e-waste is required to be specifically stored for the development of a process for its recycling or reuse.

Documents required for EPR Fulfilment in E-Waste Management

• 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

Management of e-waste has been a challenge for a developing country like India; however, the scenario is gradually improving. Some of the challenges of EPR Fulfilment in E-Waste Management are-

Cherry-picking

While the E-waste Rules cover both IT waste (computers, mobile phones, etc.) and Consumer Electronics (CE) (televisions, refrigerators, washing machines, air conditioners, and lamps), there is a large misperception that e-waste is only about IT waste – predominantly computers and mobiles. Unsurprisingly, cherry-picking – whereby only the positive value fractions are recycled – is abundant. Negative value fractions, such as CRT TVs or lamps, are not found attractive and are, therefore, not accepted by many recyclers.

Minimal Compliance

From large multinational original equipment manufacturers (OEMs) to small importers of electrical and electronic equipment (EEE), companies are focused on keeping compliance costs for e-waste management at the minimum possible and willing to cut corners where possible.

Lack of Sufficient Regulatory Capacity

Businesses' response to e-waste management in India has been almost completely driven by compliance. In the absence of other drivers like consumer demand, environmental leadership, and resource efficiency, businesses tend to design their response to keep compliance costs as low as possible. The lack of sufficient regulatory capacity at central and state levels, in terms of manpower and financial and non-financial resources, also contributes to businesses' decisions to bank on the possibility of escaping with minimal compliance.

Lack of Awareness

Business response to e-waste regulations has also been impacted by a lack of awareness about the negative externalities of environmentally unsafe e-waste management practices. This lack of awareness is not just restricted to key decision-makers in businesses but also extends to consumers – which in turn impacts consumer behaviour – while dealing with e-waste.

Benefits of EPR Fulfilment in E-Waste Management

If well-designed and implemented, EPR can provide significant environmental, economic, and social benefits. Some of the benefits of EPR Fulfilment in E-waste Management are

Promotes Innovative and Sustainable Business Models

EPR promotes innovative and sustainable business models around waste management product design and material alternatives. These business models can provide considerable environmental benefits by offsetting the production of new products and materials and, at the same time, promoting competitiveness and job creation.

Decrease in the Extraction of Virgin Resources.

An EPR legislation may set targets on reuse, recycling, and use of recycled content for producers, importers, and brand owners. Meeting this requirement will reduce the mismanagement of waste and foster the recovery and recycling of waste into secondary raw material.

Innovation and Design for the Environment

Since EPR asks the industry to take back products at the end of the product life, it incentivizes the development of designs that boost their recyclability and lessen the effect of products that stay in the waste stream EPR implementation mechanisms can also integrate incentives toward design for the environment.

Job Creation

Creates jobs and supports economic development by providing opportunities for waste collection, processing, and marketing. Job opportunities in the waste management sector are created by the establishment of collection centers and recycling facilities. EPR compliance promotes the development of a formal recycling industry, which employs thousands of people involved in e-waste management.

Responsibilities under EPR Fulfilment in E-Waste Management

Responsibilities of the Manufacturer

All manufacturers shall have to:

• Register on the portal
• Collect and recycle e-waste generated during the manufacturing of any electrical and electronic equipment.
• Submitting annual and quarterly returns using the format specified on the portal by the end of the month that follows the relevant quarter or year, whichever comes first.

Responsibilities of the Producer

The producer of electrical and electronic equipment would be held responsible for:

• Registration on the portal
• Obtaining and implementing extended producer responsibility targets
• Creating awareness through media, publications, advertisements, posters, or any other means of communication
• Filing annual and quarterly returns in the prescribed format on the portal on or before the end of the month following the quarter or year to which the return relates.

Responsibilities of the Refurbisher

All Refurbishers shall have to:

• Register on the portal
• Collect the e-waste generated during the refurbishment process, hand it over to a registered recycler, and upload the information to the portal.
• Ensure that the refurbished equipment complies with the Ministry of Electronics and Information Technology's Compulsory Registration Scheme and the BIS’s standards framed for this requirement.
• File annual and quarterly returns in the mentioned format on the portal by the end of the month following the quarter or year to which the return relates.

Responsibilities of the Recycler

All Recyclers shall have to:

• Register on the portal
• Ensure that the facility and recycling processes adhere to the standards or guidelines established by the Central Pollution Control Board from time to time.
• Ensure that any fractions or materials that cannot be recycled in its facility are sent to the appropriate registered recyclers.
• Ensuring that the residue generated during the recycling process is disposed of in an unauthorized treatment storage disposal facility.
• Maintain a record on the portal of e-waste collected, dismantled, recycled, and sent to registered recyclers, and make all records available for verification or audit as needed. Producer Responsibility Organizations (PRO) and their role in waste management.

Role of Producer Responsibility Organizations (PRO) in Waste Management

PRO is referred to as a "professional organization authorized or financed collectively or individually by producers that can take responsibility for collecting and channeling generated e-waste from the "end-of-life" of their products ensuring environmentally sound management of such e-waste." PROs play a pivotal role in properly implementing EPR. PROs can help with local-level implementation of EPR where ULBs may lack expertise and help producers/ brand owners meet their EPR objectives and legal requirements for the same. PROs must integrate and deal with a wide variety of stakeholders ranging from the government to brand owners, waste collectors, and waste generators. Hence, they will help in the creation of a more transparent and robust system wherein accountabilities can be shared by various stakeholders. The PRO helps producers achieve collection targets, makes the process of collection and End-of-life management transparent, allows for tracking of waste, and conducts awareness generation. In the Indian context, a typical PRO may provide the following services:

• Improve waste channelization and flow by developing methods for the collection of waste by integrating the informal sector.
• Establish and operate waste collection centres and drop-off points and implement take-back schemes.
• Overseeing the waste value chain and traceability from waste collection from various points to waste storage and transportation.
• Ensuring environmentally sound dismantling and recycling of e-waste.
• Keeping an inventory of waste handled and developing various compliance documentation
• Induce behavioural change via awareness programs at individual and bulk waste generators
• Help producers with filing quarterly and annual returns.

Statistical Data

Fig. E-Waste Recycling Target (by weight)

Source- E-Waste-Management-Rules-2022

 

2023 -2024	60% of the amount of an EEE that was introduced to the market in the year Y-X, where 'X' represents the product's average life and Y represents the Years
2024 -2025	60% of the amount of an EEE that was introduced to the market in the year Y-X, where 'X' represents the product's average life and Y represents the Years
2025 -2026	70% of the amount of an EEE that was introduced to the market in the year Y-X, where 'X' represents the product's average life and Y represents the Years
2026-2027	70% of the amount of an EEE that was introduced to the market in years Y–X, where Y stands for the Years and "X" is the product's average life
2027-2028	80% of the quantity of an EEE placed in the market in year Y-X, where ‘X’ is the average life of that product and Y represents the Years
2028-2029 onwards	80% of the quantity of an EEE placed in the market in year Y-X, where ‘X’ is the average life of that product and Y represents the Years

How can Corpbiz assist you?

Corpbiz offers assistance in determining how EPR Fulfilment in E-Waste Management could benefit your business. Effective EPR Fulfilment in E-Waste Management solutions will expand as businesses expand. Corpbiz is at the forefront of this trend and will be a partner in assisting businesses in achieving their objectives. 

At Corpbiz -

• We help with complex Registration Processes.
• We help in planning your EPR fulfilment process by examination of your total production quantity & type of plastic used for packaging, measuring the achievability, targets, and study challenges while unlocking easy solutions.
• We provide assistance with all legal documentation requirements to initiate the EPR fulfilment proces