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EPR Registration for Producer and Importer

The E.P.R. Authorization is a responsibility vested with producers/importers to properly dispose or recycle post-consumer E-waste as per the Plastic Waste Management Rules, 2016. E.P.R. stands for "Extended Producer Responsibility" is an environmental & economic approach to administering the product's lifecycle.

It encompasses the prevention, proper disposal & systematic recycling. Primarily there are three categories of authorization, viz

  • Import authorization
  • Manufacturing authorization
  • Wholesale authorization

It is important to note that the manufacturing authorization is most cumbersome to secure as it seeks ample infrastructure and training investment. The E.P.R. certification is a legal compulsion for Indian or overseas manufacturers or importers of electronic items for E-waste management.

Why Government introduced E.P.R. Authorization?

With the soaring increase in e-waste, G.O.I. has examined the prevailing policy options & concluded that entrusting manufacturers and importers with responsibility could be the best way to combat such a situation.

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In general, Extended Producer Responsibility refers to a policy-based approach under which manufacturers are vested with responsibility for seamless treatment or disposal of post-consumer products.

In a nutshell, E.P.R. seeks to ensure;

  • Better prevention of waste at the source
  • Production of environmental-friendly products
  • Seamless recycling & management of e-waste

Two categories of electrical and electronic equipment namely:

  • IT & Telecommunication-based item &
  • Consumer electronics such as Televisions, Refrigerators, A.C., Washing Machines, mercury-containing lamps, etc

An Overview of E-Waste (Management & Handling) Rules, 2011

  • E-Waste (Management & Handling) Rules, 2011, were promulgated by the government in 2011 & had come into play since 1st May 2012. To ensure seamless implementation of E-based waste rules & clearly describe the duties of producers in E.P.R., MoEF & CC, G.O.I. in the purview of E-Waste (Management and Handling) Rules, 2011, has unveiled the E-Waste (Management) Rules, 2016 vide G.S.R. 338(E) dated 23.03.2016 which came into effect on 01-10-2016
  • These rules encompass every manufacturer, consumer, accumulation facility, dismantler, & Recycler engaged with the manufacturing, trading, and processing of electronic goods cited in schedule – I of these Rules.
  • All these rules revolve around Extended Producer Responsibility (EPR). Target-based approach for EPR's implementation has been inculcated in the E-Waste (Management) Rules, 2016, which render phase-wise collection target to the manufacturer for the accumulation of e-based wastes, either in weight or number, which shall be thirty per cent of the estimated quantity of waste produced during first two years of rules' implementation followed by 40% during 3rd and 4th years, fifty per cent during 5th & 6th years & 70th during 7th year onwards.
  • The E-Waste (Management) Rules, 2016 mandate the Central Pollution Control Board i.e. CPCB which entails specific norms related to EPR, channelization, accumulation facilities, storage, transportation, eco-friendly recycling, refurbishment, & sampling of EEE for testing of RoHS guidelines.

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Potential benefits offered by EPR registration

The EPR registration holders access the following benefits;

  • Improved goodwill in the market owing to the commitment to reducing e-waste
  • Access to a definitive framework that ensures effective management of e-waste with low cost
  • Ensure better coordination with allied units for e-waste handling
  • Provide a credible image for international market

How to apply for EPR Authorization?

  • Every manufacturer seeking E.P.R. authorization should make an application in the prescribed application, viz Form-1 of the E-Waste (M) Rules, 2016. The said application should be duly filled and accompanied with requested documentation.
  • As per the E-Waste (M) Rules, 2016, the applicant must furnish the duly filled application to the Member Secretary, Central Pollution Control Board.
  • Form-1 should entail the legit details related to the accumulation & channelization of e-waste as mentioned in sections 2.1.1 to 2.1.7.

Key Documents required for the EPR Authorization

  • Legit address of the proof producers/importer
  • Copy of G.S.T. certification reflecting the address of the business place 
  • Copy of business certification granted by R.O.C.s or Directorate of Industries or Local Body, or DGFT
  • Copy of Certificate / Document
  • Items details such as the batch number and model number 
  • Details of electronic goods offered to market (in chronological orders reflecting quantity, number and weight etc. ) during last ten years 
  • Valid BIS registration 
  • Copy of I.S.I. mark or BIS registration number, if applicable
  • Details related to the Reduction of Hazardous Substances (RoHS) compliance
  • Estimated generation of WEEE
  • Extensive EPR plan encompassing detail relating to collection method, challenization of e-waste, website information, etc.
  • Details of upcoming awareness programs.
  • Budget for accumulation & challenization schemes
  • Self-declaration related to RoHS compliances
  • Declaration regarding the management of technical documents on RoHS as per EN50581.
  • Legal consent granted by the concerned department/ministry for selling their product
  • Copies of agreement with dealers, collection centres, and recyclers
  • Copy of agreement with TSDF (in case of CEEW5)
  • Copy of agreement with PRO (if applicable)

Casting light on the role of Extended Producer Responsibility Plan*

Extended Producer Responsibility Plan (E.P.R.- Plan) E.P.R. Plan generally serves as an implementation plan of the producer related to accumulation, processing, and channelization of e-waste produced at the facility.

The EPR plan seeks to; 

  • Pinpoint estimation of E-waste quantity generated from the consumer's end
  • The outline scheme for systematic accumulation & channelization of e-waste with same E.E.E. code to authorized recyclers
  • Estimated budget for seamless implementation of EPR
  • Outline schemes for creating awareness for e-waste prevention and management
  • Compel producer to ensure conformity with RoHS compliance and make a declaration for the same with requested documentation.

The manufacturers have the right to revise their EPR plan on a timely basis with the information to the concerned authority, i.e. CPCB. In such scenarios, the E.P.R. authorization seeks amendment.

Post-registration Obligations for the License Holder

In the purview of E-waste (management) Rules, 2016, CPCB seeks license holders to comply with the following requirements;

  • The producer must stay in line with the approved EPR plan.
  • The accumulation methodology or mechanism should be set up in accordance with the approved EPR plan.
  • Documentation for e-waste channelization should be maintained by the producer. Note: Recyclers are also liable to follow this condition
  • Producers are obligated to maintain records, in form 2 of these rules, of electronic waste and present such records before CPCB during the inspection.
  • Producers must file yearly return in the prescribed form, viz; form 3 to the CPCB on or before 30th June following the F.Y. to which that returns relates.
  • Registration holders should maintain technical documentation on RoHS for the purpose of inspection.
  • Launch of new products seek the prior intimation to the concerned authority via Enclosure A
  • The inclusion of RoHS information on the brochure or booklet of the products is a legal mandate.

Connect with CorpBiz for the Hassle-free obtainment of EPR Authorization

As it is obvious from the above, the EPR authorization seeks ample paperwork and perhaps some degree of field-based knowledge considering the corpus of compliances present.

At CorpBiz, you will be able to access the following benefits: 

  • Exhaustive professional-based support from CorpBiz’s experts
  • Swift and Seamless delivery of license in the agreed time span
  • On point identification of applicable compliances and legalities for registration

Frequently Asked Questions

E.P.R. is an abbreviated term of an Extended Producer's Responsibility. E.P.R. certificate acts as a mandatory legal consent for Indian Manufacturer / Importer for E-waste management. E.P.R. authorization is accorded by the Central Pollution Control Board (CPCB).

Common documents required for E.P.R. registration includes I.E.C. certificate, E.P.R. Plan, copy of agreements, and P.A.N. Card.

E-waste (Management) rules, 2016.

Central Pollution Control Board.

Indeed, BIS registration is one of the fundamental documents required for filing forms related to E.P.R. authorization.

RoHS stands for "Restriction of Certain Hazardous Substances" directive pertaining to the usage of hazardous substances in electrical and electronic equipment. It was introduced by the European parliament, and it aims to curtail the excessive use of hazardous substances in electronic products through the inculcation of various guidelines.

With extended producer responsibility, the good maker finances the cost of product disposal and recycles. This might take the form of physically accumulating the products at the end of their service life.

As per E-Waste (Management) Rules, 2016, an applicant seeking to obtain EPR registration needs to apply in the prescribed form known as Form 1.

EPR Plan that serves as a management framework for a producer to administer e-waste effectively and seamlessly.

Form 3 is a standard form that is use to file an annual return with CPCB

Under such a situation, the concerned authority may cancel the registration.

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