EPR registration is a process of obtaining the approval of the Central Pollution Control Board (CPCB) or the State Pollution Control Boards (SPCBs) for the implementation of the extended producer responsibility (EPR) obligations under the E-Waste (Management) Rules, 2016 or the Plastic Waste Management Rules, 2016. EPR is a policy approach that makes the producers, importers, and brand owners (PIBOs) responsible for collecting and managing the waste generated from their products, such as electrical and electronic equipment (EEE) or plastic packaging. EPR registration is required to ensure that the waste is managed environmentally sound and that the PIBOs comply with the EPR targets, standards, and guidelines set by the CPCB or the SPCBs. EPR registration is also a legal requirement under the Environment (Protection) Act, 1986, and the E-Waste (Management) Rules, 2016, or the Plastic Waste Management Rules, 2016.
Applicable Rules/ Acts/ Regulations for EPR
The legal framework for EPR registration is as follows:
1: The Environment (Protection) Act, 1986, which is the umbrella legislation that empowers the central government to take measures to protect and improve the quality of the environment and prevent, control, and abate environmental pollution. The act also provides for the establishment of the National Environmental Appellate Authority, which hears appeals against the orders of the central government or any authority under the act. The act also lays down the penalties for contravention of the provisions of the act or the rules made thereunder.
2: The E-Waste (Management) Rules, 2016, which are the specific rules that regulate the generation, collection, storage, transportation, segregation, refurbishment, dismantling, recycling, and disposal of e-waste in India. The rules also define the roles and responsibilities of various stakeholders, such as producers, consumers, bulk consumers, collection centers, dealers, e-retailers, refurbishers, dismantlers, recyclers, and producer responsibility organizations (PROs). The rules also specify the EPR targets, the procedure for obtaining EPR authorization, the standards for environmentally sound management of e-waste, the criteria for registration of PROs, the format and frequency of reporting, and the procedure for monitoring and enforcement.
3: The Plastic Waste Management Rules, 2016, which are the specific rules that regulate the generation, collection, storage, transportation, segregation, processing, and disposal of plastic waste in India. The rules also define the roles and responsibilities of various stakeholders, such as producers, importers, brand owners, consumers, waste pickers, recyclers, local bodies and gram panchayats. The rules also specify the EPR targets, the procedure for obtaining EPR registration, the standards for plastic waste management, the criteria for registration of plastic waste processors, the format and frequency of reporting, and the procedure for monitoring and enforcement.
4: The Guidelines for Implementation of E-Waste (Management) Rules, 2016, which are the guidelines issued by the CPCB to provide clarity and guidance on the implementation of the E-Waste (Management) Rules, 2016. The guidelines cover various aspects, such as the EPR plan, collection mechanism, channelization, documentation, record keeping, reporting, verification, random sampling, testing, labeling, awareness generation, capacity building, and grievance redressal.
5: The Guidelines on Extended Producer Responsibility for Plastic Packaging, which are the guidelines issued by the CPCB to provide clarity and guidance on the implementation of the Plastic Waste Management Rules, 2016. The guidelines cover various aspects, such as the EPR plan, collection mechanism, channelization, documentation, record keeping, reporting, verification, plastic credits, eco-fee, and grievance redressal.
Eligibility/ Pre-Licensing/ Mandatory Prerequisites
1: The applicant should be a producer, importer, or brand owner (PIBO) of electrical and electronic equipment (EEE) or plastic packaging, as defined under the E-Waste (Management) Rules, 2016, or the Plastic Waste Management Rules, 2016.
2: The applicant should have a valid PAN card and GSTIN.
3: The applicant should have valid consent to establish or consent to operate or authorization or registration or license or any other document that indicates the approval of the concerned regulatory authority for the manufacture import sale or distribution of EEE or plastic packaging.
4: The applicant should have a valid agreement or MoU with the registered collection centers, dealers, e-retailers, refurbishers, dismantlers, recyclers, producer responsibility organizations (PROs), or any other entity for the collection and management of e-waste or plastic waste generated from their products.
5: The applicant should have a valid agreement or MoU with the authorized transporters for the transportation of e-waste or plastic waste as per the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
6: The applicant should have a valid agreement or MoU with the authorized treatment, storage, and disposal facilities for the disposal of hazardous wastes generated from e-waste or plastic waste as per the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
7: The applicant should have a valid agreement or MoU with the authorized testing laboratories for the testing of e-waste or plastic waste for RoHS parameters plastic identification code or any other parameter as specified by the CPCB or the SPCBs.
8: The applicant should have a valid agreement or MoU with the State Pollution Control Boards the Pollution Control Committees or the Union Territory Administration for the coordination and cooperation in the implementation of the E-Waste (Management) Rules, 2016 or the Plastic Waste Management Rules, 2016.
Documents Required for EPR Registration
The documents or information that need to be submitted along with the application for EPR registration are as follows:
A duly filled and signed application form in the prescribed format (Form 1 or Form 1A) along with a declaration and an undertaking by the applicant that the information provided is true and correct and that the applicant will comply with the E-Waste (Management) Rules, 2016 or the Plastic Waste Management Rules, 2016 and the guidelines issued by the CPCB or the SPCBs.
- An EPR plan contains the applicant’s detailed plan for achieving the EPR targets set by the CPCB or the SPCBs for the products for which the EPR obligations are to be implemented. The EPR plan should also contain the details of the collection mechanism, the channelization mechanism, the documentation mechanism, the record-keeping mechanism, the reporting mechanism, and the verification mechanism to be adopted by the applicant. The EPR plan should be prepared as per the guidelines and formats issued by the CPCB or the SPCBs.
- A copy of the consent to establish or consent to operate or authorization or registration or license or any other document that indicates the approval of the concerned regulatory authority for the manufacture or import or sale or distribution of EEE or plastic packaging.
- A copy of the agreement or MoU with the registered collection centers, dealers, e-retailers, refurbishers, dismantlers, recyclers, producer responsibility organizations (PROs), or any other entity for the collection and management of e-waste or plastic waste generated from their products.
- A copy of the agreement or MoU with the authorized transporters for the transportation of e-waste or plastic waste as per the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
- A copy of the agreement or MoU with the authorized treatment, storage, and disposal facilities for the disposal of hazardous wastes generated from e-waste or plastic waste as per the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
- A copy of the agreement or MoU with the authorized testing laboratories for the testing of e-waste or plastic waste for RoHS parameters or plastic identification code or any other parameter as specified by the CPCB or the SPCBs.
- A copy of the agreement or MoU with the State Pollution Control Boards the Pollution Control Committees or the Union Territory Administration for the coordination and cooperation in the implementation of the E-Waste (Management) Rules, 2016, or the Plastic Waste Management Rules, 2016.
- Any other document or information that may be required by the CPCB the SPCBs or the concerned regulatory authority for the appraisal of the proposed EPR plan.
