Waste management

E-Waste Annual Returns and Compliances under EWM Rules 2016

calendar23 Feb, 2022
timeReading Time: 4 Minutes
EWM rules

Entities that fall under E-waste management rules, 2016, are obligated to ensure apt management of e-waste generated via their products to alleviate environmental hazards. Some common compliance under said rules for producers includes the procurement of waste generated via end-of-life products, apt mobilization of the same to the certified recyclers and dismantlers, proper mitigation of e-waste filing annual return, obtainment of EPR authorization, securing RoHS certification etc. The article aims to brief out e-waste annual returns requirement, and compliances under EWM rules 2016[1].  

Mandatory compliances for Manufacturers and Producer under EWM rules 2016  

  1. Every manufacturer is liable to apply for authorization under rule 13(2) (i) to 13(2) (viii) and/or 13(4) (i) of the EWM rules 2016 via form 1 (a) for;
  • Collection;
  • Storage;
  • Transportation;
  • Treatment;
  • Refurbishing;
  • Disposal of e-waste.
  1. Every manufacturer is obligated to accumulate e-waste generated during the production phase of any electrical and electronic equipment. Also, they are accountable for channelizing the same for recycling or disposal;
  2. Manufacturers must ensure eco-friendly handling of e-waste within the premises or during its transportation.
  3. Manufacturers are liable to maintain a record of the e-waste generated, handled, & disposed of in prescribed format, i.e. form 2.
  4. They are also obligated to cooperate with SPCB’s officials seeking inspection of the premises and said record.
  5. Filing of annual returns via form-3 with SPCB is mandatory for manufacturers under EWM rules.

Coming to the producers, the E-waste Management Rules, 2016 has penned down the following obligations for them

The producer of electrical and electronic equipment falling under Schedule I shall be accountable for implementing EPR with the given framework relating to;

  • Accumulation and channelization of e-waste generated via discarded products with the same electrical equipment code in accordance with the targets cited in Schedule III in EPR authorization
  • Accumulation and channelization of historical wastes generated on the date on which EWM rules come into effect in accordance with the targets cited in Schedule III in EPR authorization
  • Methods utilized for the e-waste channelization to certified dismantler or recycler shall be in line with the EPR authorization.
  • Utilization of pre-treatment process to minimize the net quantity of e-waste to be channelized for disposal in storage, treatment, and disposal unit.
  • Adherence to the general principle of EPR that seeks procurement of e-waste via dealers, collection units, PRO, exchange scheme, etc.
  • Sharing contact detail and product user documentation to consumer(s) or bulk consumer(s) via their official website for returning end-of-life products.
  • Complying with RoHS norms for the use of banned substances. (Note: RoHS certificate is necessary for seeking EPR authorization from CPCB)

Underlying Compliances for Dismantler under EWM rules 2016  

Dismantlers under E-waste rules are obligated to: 

  • Comply with CPCB’s direction relating to facility layout and processing.
  • Obtain consent from the respective SPCB
  • Ensure eco-friendly handling of e-waste within the premises or during its transportation
  • Ensure that the dismantling process does not pose any risk to human-life and the environment
  • Ensure that the dismantled e-waste undergoes apt segregation process and then mobilized to certified recycling units
  • Ensure that non-recyclable items are sent to certified disposal and treatment storage units.
  • Maintain a record of e-waste procured, dismantled, and channelized to certified facilities in form 2
  • Cooperate with SPCB’s officials to the fullest during inspection of premises and records.
  • File annual return in form 3 with respective SPCB on or before 30th June following the FY to which that return relates
  • Perform operation around dismantling only (for other processes such as recovery or refining, dismantler would require separate consent)

Compliances for Recycler under E-waste Rules 2016

Recyclers under E-waste rules are obligated to;

  • Comply with CPCB’s direction relating to facility layout and processing.
  • Obtain consent from the respective SPCB
  • Ensure eco-friendly handling of e-waste within the premises or during its transportation
  • Ensure that the recycling process does not pose any risk to human life and the environment
  • Maintain a record of e-waste procured, recycled, and channelized to certified facilities in form 2
  • Cooperate with SPCB’s officials to the fullest during inspection of premises and records.
  • File annual return in form 3 with respective SPCB on or before 30th June following the FY to which that return relates
  • Channelize residue generated during recycling to certified treatment units for disposal

Compliances for collection centres under E-waste Rules

Collection centres under E-waste rules are obligated to

  • Accumulate e-waste on behalf of producer or recycler or refurbisher or dismantler including those coming from orphaned products;
  • Comply with norms rolled by the CPCB from time to time.
  • Ensure that the collected e-waste is stored safely and eco-friendly manner.
  • Ensure eco-friendly handling of e-waste within the premises or during its transportation
  • Maintain a record of e-waste procured, recycled, and channelized to certified facilities in form 2

E-Waste Annual Returns format for producer or refurbisher or recycler or dismantler

Quantity in MT and numbers

1.        

Name & address of the producer or refurbisher or recycler or dismantler

 

2.       

Name and contact detail of the person in-charge

 

3.       

Net quantity of e-waste accumulated  or mobilized to dismantler or recycler for processing during the year for every category of electronic category cited in Schedule I

 

 

Particulars of the above

Type

Quantity

No.

 

Bulk consumers: Quantum of e-waste

 

 

 

 

Bulk consumers: Quantum of e-waste

 

 

 

 

Dismantler

  1. Quantum of e-waste processed (Code-wise)
  2. Details of components or material recouped and sold
  3. Quantum of e-waste routed to recycler
  4. Residual quantum of e-waste sent to storage, treatment, and disposal unit

 

 

 

 

Recycler

  1. Quantum of e-waste processed (Code-wise)
  2. Details of components or material recouped and sold
  3. Quantum of e-waste routed to recycler
  4. Residual quantum of e-waste sent to storage, treatment, and disposal unit

 

 

 

 

Name and address of the unit w.r.t to 3 (A)-3(D) above

 

 

Types and quantum of materials subjected to segregation or recovering process  from e-waste of different codes as applicable to 3 (A)-3(D)

type

Quantity

 

 

 

Conclusion

E-waste producers, recyclers, dismantlers under EWM rules are subjected to a long list of compliances. The margin of error here is quite low, and the chance of being penalized is considerably higher. Thus entities need to be more watchful while complying with such rules. It is advisable to seek professional help in the case where there is less clarity over any specific compliance. This way, you can bypass penalties and remain compliant as long as possible. 

Read our Article:E-Waste Dismantler Authorisation: How to get it?

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