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EPR Compliance for E-Waste Management
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Introduction

EPR compliance for electronic waste necessitates the proper disposal and recycling of electrical & electronic equipment, taking into consideration –

  • Information technology and telecommunication equipment
  • Consumer electrical and electronic photovoltaic panels
  • Large and small electrical and electronic equipment
  • Electrical and electronic tools
  • Medical Device
  • Laboratory instruments

EPR mandates electrical and electronic equipment producers to meet specific recycling targets, utilizing registered recyclers. To comply with this policy, producers must provide detailed information regarding the constituents and components of their equipment, along with a declaration of hazardous substance reduction in user documentation.

CPCB conducts random inspections and periodic audits, either directly or through a designated agency, to verify compliance by producers, manufacturers, refurbishers, dismantlers, and recyclers with hazardous substance reduction provisions. To promote a conscientious approach to waste management, manufacturers must systematically collect electronic waste arising from the production of any electrical or electronic equipment. This collected waste must undergo proper recycling or disposal procedures. The manufacturer is mandated to employ advanced technologies or methodologies that enhance the recyclability of the end product.

EPR is a crucial initiative towards ensuring sustainable waste management and reducing the environmental impact of electronic waste. To ascertain adherence to these guidelines, manufacturers must submit comprehensive annual and quarterly returns in the prescribed format through the designated portal. The submission deadline for these returns is set for the end of the month, succeeding the respective quarter or year, underscoring the importance of timely compliance.

Responsibility Of the Manufacturer

  • Manufacturer means a person or stakeholder or company as defined in the Companies Act 2013 a factory as defined in the Factories Act 1948 or small and medium enterprises as defined in Micro, Small, Medium Enterprises Development Act 2006 which has facilities for the manufacture of electrical and electronic equipment as specified in schedule 1.
  • All manufacturers shall have to register on the portal.
  • As per the regulatory compliance, all manufacturers must undertake the responsibility of collecting the electronic waste that is produced during the manufacturing and production of any electrical or electronic equipment.
  • The collected waste must be properly recycled or disposed of. The manufacturer shall use the technology or methods to make the end product recyclable.
  • To ensure compliance, manufacturers must file annual and quarterly returns in the prescribed format on the designated portal. The annual returns must be filed in Form 3, to the concerned state pollution control board on or before the 30th of June following the financial year to which the return relates.

Responsibility Of the Recycler

  • Simultaneously, all recycling entities must adhere to the standards outlined by the Central Pollution Control Board in their facilities and recycling procedures.
  • Compliance extends to the timely submission of annual and quarterly returns by the end of the month following the respective quarter or year to which the return pertains.
  • All recyclers shall have to maintain a record of e-waste collected, dismantled, recycled, and sent to registered recyclers must be recorded on the portal, and all records must be made available for verification or audit as and when required.
  • All recycling stakeholder are required to ensure that their facilities and recycling processes align with the standards set forth by the Central Pollution Control Board.
  • File the annual return in form 3 to the concerned state pollution control board on or before the 30th day of June following the financial year to which that return relates.

Conclusion

To comply with EPR guidelines, electronic waste producers must keep detailed records of the creation and disposal of E-Waste. This requirement not only ensures compliance but also establishes a clear record of the life cycle of electronic products, promoting accountability under EPR mandates. Keeping such records is crucial, as it helps to maintain transparency and provides a clear trail of the electronic product’s life cycle.

The execution of extended producer responsibility is delineated through the acquisition of an Extended Producer Responsibility certificate from a duly registered recycler, with the subsequent submission forming an integral part of the quarterly return filing process.

CPCB Shell

  • Prepare and issue guidelines and standard operating procedures for collection, storage, transportation, segregation, refurbishment, dismantling recycling and disposal of e-waste under rules from time to time and also issue necessary forms/returns for implementation of these rules.
  • Integrate all stakeholders with the centralized digital system.
  • Submit an annual report to the Ministry.
  • Enforcement of provision regarding reduction in the use of hazardous substances in the manufacture of electrical and electronic equipment.
  • Interaction with the IT industry to reduce hazardous substances.
  • Set and revise targets for compliance with the reduction in the use of hazardous substances in the manufacture of electrical and electronic equipment from time to time.
  • Ensure ROHS compliance and its certifications through a recognized lab and its mandatory checks.

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