EPR Registration – Authorization Process

Who will be registered for EPR?

According to E-waste rules 2016, the EPR authorization is Central Pollution Boards Responsibility. The CPCB controls the registration and the approval of EPR of different industries and companies.

EPR registration ensures that the product manufacturers are responsible for the entire life cycle of the product. Read the article till the end to know how to register and what are the requirements for authorization.

Why is EPR necessary?

Through authorization and registration, the government provides Extended Producer Responsibility to the manufacturer of the product so that:

  1. They follow a proper business model and channelize the waste generated in markets. 
  2. Producers are liable to collect back the electronics from the consumers through a buyback scheme.
  3. Producers and manufacturers ensure the proper collection and processing so that the waste does not harm the environment.
  4. They avoid improper handling of waste and dangerous dumping.
  5. They take responsibility for adopting proper recycling methods or get the waste recycled from authorised agencies.
  6. Reduce the degradation of the environment and harmful impacts on human health.

How does EPR registration work?

  • To register for EPR, the applicant needs to fill a form, and another way is through various online websites.
  • The company needs to form a proper EPR plan according to the guidelines mentioned by the CPCB.
  • Submission of declarations consisting of:
  • Self-declaration for compliance of Reduction Of Hazardous Substances (RoHS)
  • Technical documents according to the restrictions on the use of any harmful substance.

The copies of agreements with the cooperating agencies:

  • The recyclers
  • The dismantlers
  • Treatment storage and disposal facilities
  • The company should have proper licenses and permissions from relevant departments and ministries for the marketing of products and business.
  • A proper list of all the producers attached to the recycling agencies along with their authorization copies.
  • After the submission of the application, the verification takes place by the State and Central Pollution Control Board.
  • The information in the application has to be correct and verified before submitting. CPCB can cancel your EPR certificate if the details are incorrect.

EPR requirements for registration

Extended Producer Responsibility applies to all the manufacturers, producers, importers, bulk consumers, dealers, e-retailers involved in sales and waste processing. 

The company looking for EPR registration need to be:

  • Liable for collection and recycling of e-waste
  • Responsible for following the guidelines and fulfill the requirements or engage a Producers Responsibility Organization (PRO)
  • Punctual in submitting the import and sales data according to the target set by CPCB.
  • Regular in submitting the quarterly data of sales once the EPR is issued.
  • Prompt in conducting at least two seminars yearly for spreading awareness in the general public for the hazardous effects of e-waste.

The introduction of EPR made the businesses accountable for the products they place in the market. The producer can take the lead in the management of the EPR schemes according to them. They can ensure compliance with a proper set up for collection and recovery targets. Thus, the registration for EPR is not only a crucial step to save the environment, but it can lead to better business opportunities in the future.

How do I Register For EPR?

India’s mission to curb the environmental impacts of electronic waste started in 2011 when they recognized the alarmingly high rates of unprocessed e-waste and its detrimental effect on workers and the environment. Hence, they released EPR guidelines for producers to start holding them accountable. 

The EPR guidelines were unfinished and were tediously painful to process through back in 2011. However, they were revised with a much better version of guidelines that clearly state rules and regulations that serve as helpful directions for companies to fulfill their debt to their environment. 

Back in 2011, the process of registration was not centralized and not available pan India. But, that, too, has changed with the new guidelines and actions taken in 2016. It has become easier than ever for corporations to register for EPR. If you’re wondering how to go about the procedure, keep reading. 

Scope of EPR for businesses

Before diving into the process of registering for EPR, you must know the roles and duties that it entails. Managing such waste entails working with the government, and hence, you should know where the government’s duties end and where your duties begin. 

Every producer, manufacturer, recycler, or brand owner needs to instate frameworks and mechanisms for the waste collection system based on Extended Producer Responsibility. Also, they must involve State Departments for Urban Development, be it individually or jointly, through their distribution channel or the concerned local authorities.

The organizations mentioned above need to do it because The State Pollution Control Board or the Pollution Control Committee have the power to cancel your license renewal. They will go ahead with it unless the producer shows the existence of an action plan endorsed by the Secretary in charge of Urban Development of the concerned State or Union Territory for the establishment of the waste management system. 

Procedure for registering 

The following are the steps you need to follow – 

  1. Fill the requisite form that forms I, II, or III depending on the nature and the scale of your business.
  2. You require a lot of attachments to complete the document verification part. Ensure you attach all the mandatory paperwork. 
  3. Get the documents checked, verified, and signed by the authorized officer. 
  4. Submit the form to the concerned SPCB or the pollution board.
  5. Talk and follow their directions by following up with the concerned department. They will go through your documentation and point out any changes you may need to make, if any. 
  6. If the form is complete, clear, and accurate, the concerned department will grant you the certificate without any issues. 

List of required documents

You require all the following documents to use an attachments/proof with the form – 

  1. Aadhar card of the owner/authorized personnel
  2. PAN copy of the owner/authorized personnel
  3. GST certificate of the organization
  4. Rent/lease to use as proof of ownership
  5. Factory license/trade license
  6. Electricity bill
  7. Layout/plan of the unit 
  8. CIN(certificate of incorporation) in case of companies/LLPs
  9. Memorandum Of Association (MOA)
  10. Articles of Association (AOA)
  11. Board resolution for appointing an authorized person

Ensure that all the documents mentioned above are up-to-date and do not show any discrepancies when cross-referenced with each other.