Brief about EPRA

Extended Producer Responsibility (EPR) refers to the responsibility of Indian manufacturers and importers of electronic products to manage e-waste. To carry out this responsibility, an EPR certificate is mandatory, and it is issued by the Central Pollution Control Board (CPCB) under the Ministry of Environment, Forest and Climate Change (MoEFCC), Government of India. The certificate enables the manufacturers and importers to manage e-waste generated from their products after the end of their useful life.

How to obtain EPR Authorization in India?

The manufacturer or importer of electronic and electrical products must submit documentary evidence of their e-waste management plan and an agreement with a recycling agency.

At NAC, we offer complete support in obtaining EPR registration by managing documentation and other formalities to obtain the EPR certificate.

EPRA E-Waste

The government of India enacted the first law in 2011, based on the principle of Extended Producer Responsibility (EPR), which mandates the manufacturer to manage the final stage of their product's life in an eco-friendly way, ensuring environmentally sound management. The EPR certificate or license is compulsory for every producer or importer of electric or electronic equipment, which encourages manufacturers to produce environmentally friendly products. The Central Pollution Control Board (CPCB) under MoEFCC, Government of India issues EPR Authorization.

Under the E-Waste (Management) Rules, 2016, all manufacturers of Electrical and Electronics (EEE) products/equipment listed in Schedule 1 are responsible for collecting, recycling, and disposing of their product's final stage from an authorized dismantler/recycler. Manufacturers and importers must tie-up with authorized recyclers to dispose of E-Waste and submit plans related to estimated dump quantity and the disposal method adopted in CPCB to obtain the EPR Certificate. In summary, the manufacturer is responsible for the ultimate recycling, reuse, or disposal of their product.

On November 2, 2022, the Ministry of Environment, Forests, and Climate Change issued the E-Waste (Management) Rules 2022, which will be effective from April 1, 2023. This regulation mandates all manufacturers, producers, refurbishers, and recyclers to register on the portal and collect e-waste generated during the manufacturing, refurbishing, or disposal of any electrical and electronic equipment to ensure its recycling or disposal. The entities must register on the portal under the appropriate category such as manufacturer, producer, refurbisher, or recycler. If an entity falls into more than one category, they must register separately under each category. Business cannot be conducted without registration.

Entities must file annual and quarterly returns in the prescribed format on the portal before the end of the month following the quarter or year to which the return relates. These regulations apply to all manufacturers, producers, refurbishers, dismantlers, and recyclers involved in the manufacture, sale, transfer, purchase, refurbishment, dismantling, recycling, and processing of e-waste or electrical and electronic equipment listed in Schedule I.

The Central Pollution Control Board may charge registration fees and annual maintenance fees on entities seeking registration under these rules based on the capacity of e-waste generated, recycled, or handled by them, as determined by the board with the approval of the Steering Committee.

Producers of electrical and electronic equipment listed in Schedule I must first register on the portal to obtain and implement extended producer responsibility targets as per Schedule III and IV. Producers who have extended producer responsibility plans under the E-Waste (Management) Rules, 2016, must migrate under these rules according to the procedure established by the Central Pollution Control Board with the approval of the Steering Committee

Required Documents

Documents for Address Proof

• Legal Address Proof of the Manufacturer / Importer:
• Copy of GST document indicating the address of manufacturing unit.
• Certificate of Inc.
• Import Export Code letter.

Product Details including Model Numbers and Production / Import History

• Details of electrical and electronic equipment placed on market year-wise during previous 10 years (Quantity, number and weight etc.).

Documents for CPCB Certification

• Copy of PAN
• Name of the Authorized Person (signatory), full address with e-mail, telephone number, copy of Aadhar Card etc.
• KYC of Manufacturer / Importer Company (like phone numbers, e-mail address, website information, etc.)
• List of all offices
• Details of E-Product (product name, brand name, model no., volume, etc.)
• Awareness Plan, implementation methodology and Budget for EPR and allied initiatives
• Flowchart for Collection of E-Waste and its Transportation to Recycler
• Estimated generation of e-waste item-wise and estimated collection target for the forthcoming year(s) including those being generated from their service centres
• Copies of agreement with Dealers, Collection Centre, Recyclers, Treatment, Storage and Disposal Facility, etc.

Registration Process

Process of EPR Authorization is divided into following steps:

• Step-1: Application with required enclosures
• Step-2: Review of Application by CPCB
• Step-3: Submission of additional information, if required by CPCB
• Step-4: Grant of Certificate by CPCB

EPRA – Plastic Waste

Registration of Producer, Importer & Brand Owners through Plastic EPR Portal as per Plastic Waste Management Rules 2016

On February 16, 2022, an amendment to the Plastic Waste Management (PWM) Rules was issued by the Ministry of Environment, Forest and Climate Change (MOEF&CC). The amendment enforced Extended Producer Responsibility as per the rules and guidelines set out in Schedule II. As per Clause 10.1 of the Guidelines, producers, importers, and brand-owners (PIBOs) are required to follow the regulations and standards outlined in Schedule II. Clause 10.2 specifies that the Central Pollution Control Board (CPCB) will complete the Standard Operating Procedure for registration and the action plan pro-forma. Pollution Inventory and Reporting Officers operating in more than two States/UTs are required to obtain EPR registration from CPCB, while the remaining PIBOs must be registered with the appropriate State Pollution Control Boards (SPCBs) or Pollution Control Committees (PCCs) as per the rules specified in the document.

In order to comply with the amendment notification, CPCB has initiated development of a portal that includes the following modules;

• EPR Registration for PIBOs
• Registration of PWPs
• Trading & Settlement of EPR obligations by PIBOs
• Filing of Annual Returns by stakeholders
• Levying of Environmental Compensation
• Third Party Audits
• Training/ Capacity Building of stakeholders

Categories of plastic packaging under EPR

1. Category I: Rigid Plastic Packaging
2. Category II: Flexible Plastic Packaging of single layer or multilayer (more than one layer with different types of plastic)
3. Category III: Multilayered plastic packaging (at least one layer of plastic and at least one layer of material other than plastic)
4. Category IV: Plastic sheet or like used for packaging as well as carry bags made of compostable plastics.

Required Documents

• PAN, GST, CIN, IEC (for importer) of the Company
• Aadhar/ PAN of Authorized person
• DIC Registration (if unit registered with DIC)
• Process flow diagram (for producers only)
• Consents issued by SPCB/ PCC (if unit has a production facility)
• Scanned copy of signatures of authorised persons.
• Covering letter
• Document regarding any other information which the unit wishes to provide

EPRA FOR BATTERY WASTE

Introduction

The demand for batteries has skyrocketed in recent years due to various reasons, including government support for EV-based businesses to reduce dependence on fossil fuels. With batteries being used in numerous applications, battery waste has become a significant concern worldwide.

In response to this, the Indian government has implemented the Battery Waste Management Rules in August 2022 to ensure responsible environmental management and handling of waste batteries. These rules replace the Battery (Management and Handling) Rules of 2001 and were published by the Ministry of Environment, Forests, and Climate Change on 22 August 2022.

The most important highlights of the New Batteries Waste Management and Handling Rules include:

1. EPR (Extended Producer Responsibility): The government has mentioned that the producers and importers of batteries come under the Rules and are liable to enroll in the collection & recycling of waste batteries for reuse purposes.
2. Centralised EPR Portal: The Indian government has introduced a new online portal, making it easier for producers and recycling agencies to exchange EPR Certifications.
3. Batteries Waste Recycling Standards: As per the new rules, the government has specified a minimum percentage recovery of materials from waste batteries. Eventually, this will also help in the innovation of waste battery recycling technologies.
4. Strict Rules for Violations: If any importer or producer is found violating the EPR (Extended Producer Responsibilities) for waste batteries, has to face heavy penalties as environmental compensation & the collected fines will be put for the collection and recycling of waste batteries.

APPLICABILITY:

The regulations for used battery management apply to all entities involved in the collection, segregation, transport, refurbishment, and recycling of all types of batteries, including manufacturers, distributors, and consumers. These regulations cover all kinds of batteries, including portable, electric vehicle, automotive, and industrial batteries

However, these rules do not apply to batteries used in equipment intended for essential security interests, such as weapons, ammunition, war materials, and batteries specifically designed for military purposes. The regulations also do not apply to equipment intended for launch into space.

DOCUMENTS REQUIRED FOR THE EPR CERTIFICATION OF BATTERIES WASTE INCLUDE:

• GST certificate
• Importer Exporter Code (IEC)
• Proof of address (Electricity bill, rent or lease proof)
• CIN number
• Form 1 for EPR authorization
• KYC documents of authorized signatory
• Battery Composition
• End Use of Battery

NAC EXPERTISE IN OBTAINING THE CERTIFICATION

NAC is a leading service provider in India for BIS/CRS, BIS/ISI, EPR P, E & Batteries Waste, WPC, and other approvals, authorizations, and certifications. We have completed a decade-long journey in the market, serving numerous clients with the highest success ratio in the industry

Our team of experts is highly experienced and skilled in assisting you throughout the entire process, from documentation to filling and providing support until the final approval is obtained. Our experts ensure a hassle-free process for all the legalities and formalities involved, making the entire process easier for our clients.