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EPR Post Compliance (E-Waste)

There are certain EPR post compliances for e-waste management which should be met in a timely manner. Get help from legal professionals at Corpbiz to ensure you don't miss out on meeting compliances.

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EPR Post Compliance (E-Waste)

E-waste management is necessary to protect and improve our surroundings and environment. Preservation of the natural environment can only be achieved by executing proper waste management strategies. An EPR e-waste authorization is necessary for proper disposal of the e-waste. It should be obtained by the producer, importer and band owner of electronics. Further, there are certain EPR post compliance (e-waste) that should be met in a timely manner. Not fulfilling the compliances in a timely manner can invite penalties or even cancellation of EPR authorization by the CPCB.

What are e-wastes?

E-waste refers to electronic items that have attained its end of life. Electronic devices like ACs, refrigerators, LED/LCD, laptops, monitors, TVs and mobile phones etc. these can be reused and recycled. E-waste contains a variety of resources like aluminium, copper, gold, palladium and silver and also few hazardous items such as cadmium, lead and mercury.

List of EPR Post Compliance (e-waste)

As per the EPR policy, state government need to keep a close watch on the makers, producers & recyclers to guarantee that they comply and adhere to the standards and also confirm that they meet targets of e-waste collection as specified under the E-waste (Management) Amendment Rules 2016. It also places the responsibility on the consumers of electronic devices to preserve the environment and protect it against the harm inflicted by such devices.

The following compliances need to be fulfilled by all producers, importers and brand owners:

  • Setting up of collection centres and implementing the mode of channelization according to the EPR plan.
  • Collection and channelization of the e-waste generated through the end of life products with the same electrical, electronic code and historical waste.
  • Maintaining form 2 records of e-waste handled and ensuring their availability at the time of inspection by the Central Pollution Control Board or the concerned State Pollution Control Board.
  • Annual return should be filed in a timely manner with the Central Pollution Control Board. In case where a producer has more than one office in a state, then such producer needs to file a single annual return having information contained therein from all locations.
  • In case of any change to the authorised Extended Producer Responsibility plan, the same should be reported to the Central Pollution Control Board in 15 days, and the decision of the CPCB should be conveyed within 60 days time.
  • If the authorised person decides to close any of the collection centres/points or other EPR plan facility, then he needs to take prior permission from the Central Pollution Control Board.
  • The applicant needs to provide sales data with annual return.
  • Revised EPR plan has to be submitted in case there are changes in the EPR plan.
  • In case of introduction of a new model of product then enclosure A of the self declaration should be submitted.
  • As provided in the EPR plan, the applicant needs to run an awareness programme and also organise a seminar.
  • When requested, the applicant should keep ready technical papers on “Restriction of Hazardous Substances” (RoHS) for inspection by the Central or State Pollution Control Board.
  • In every quarter, the applicant needs to report to the Central Pollution Control Board about the amount of e-waste of EEE code collected and recycled in the previous quarter.
  • A producer, after obtaining the EPR authorization, needs to create awareness about e-waste through the following means-
  1. Media;
  2. Publications;
  3. Posters and newspapers;
  4. Seminar;
  5. Awareness programmes;
  6. Digital promotion.
  • Further, the producer needs to provide information on hazardous constituents, information on hazards of improper handling, disposal, accidental breakage etc., instructions for safe handling and disposal of the equipment once it is used. The address, toll-free numbers, e-mail address should also be provided.

What is Extended Producer Responsibility?

Extended Producer Responsibility is a method through which electronic and polymer waste reuse, recycling and disposal is encouraged and promoted.  The manufacturer of goods should dispose of this trash under EPR. EPR regulations provide that manufacturers and producers should take responsibility to reduce waste generated by their products.

When a product completes its utility, the manufacturer should collect the waste generated by the product. It can be done by supporting the collection of waste that is generated after the consumption of their products or by ensuring eco-friendly recycling of such products. 

The e-waste (Management and Handling) Rules 2011 introduced the concept of EPR in India for the first time, whereas with the introduction of the e-waste (Management) Rules 2016, more stringent targets for collection of end of life products was introduced. It also simplified the EPR authorization process.

EPR is given by the Central Pollution Control Board (CPCB) to the manufacturers of e-waste, plastic waste and polymer waste and to bulk users of these wastes.

According to the notice by the Central Pollution Control Board, all producers of electronic and electrical equipment under the e-waste management rules 2016 need to get EPR authorization from the Central Pollution Control Board. The authorization is necessary to make sure that end of life electronic EEE generated by the producers’ product is given to authorised dismantlers or recyclers. 

Further, they should also meet all the EPR post compliance (e-waste) in order to smoothly function after receiving the EPR authorization.

How can we assist you?

Meeting EPR Post Compliance (e-waste) can be a complex and challenging task for many therefore, you need to have the assistance of a professional who can guide you and help you to meet all compliances in a timely manner. We at Corpbiz have a team of highly skilled and dedicated professionals who will assist you in meeting all the post compliances in a hassle-free manner. So connect with Corpbiz today!

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