E-Waste Management Authorization

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What is E-waste?

E waste or electronic waste is a kind of waste generated from discarded obsolete electronic products or parts such as computers, televisions, cell-phones, a piece of a motherboard etc. E-waste can be extremely harmful as it can lead to various detrimental diseases due to coming in direct contact with numerous dangerous chemicals like lead, chromium, polychlorinated biphenyls {PBCs}, inhalations of toxic fumes, or from accumulations in the soil, water or food.

Major sources of e-waste include wastes from IT companies, houses, and improper disposal of electronic and associated parts from any other such sources.

Applicable Laws

  • E waste {Management and Handling} Rules, 2018- effective from 1st may 2012
  • Hazardous Waste Management Rules (Effective previously before E waste {Management and Handling} Rules)
  • Environment Protection Act, 1986
  • Hazardous Waste {Management, Handling and Trasboundary} Rules, 2003
  • Hazardous Waste {Management, Handling and Movement} Rules, 2003
  • Management of E waste guidelines, 2008
  • Electronic waste handling and disposal draft law, 2013

E waste {Management and Handling} Rules, 2011

  • Effective from 1st May 2012
  • Introduction of new concept - Extended Producer Responsibility {EPR}

E waste {Management and Handling} Rules, 2016

  • Effective from 1st October 2016
  • Introduction of new concept - Manufacturer, Dealer, Refurbisher And Producer Responsibility Organization {PRO}

E waste {Management and Handling} Rules, 2018

  • Amendment notification came out on 22nd March 2018

Definitions of Important Terms

  • Extended Producer Responsibility {EPR}: It is an environmental protection strategy to vigilante any activity which might harm the environment in any way.
  • Manufacturer: Manufacturer or producer is the entity producing electronic products
  • Dealer: The Dealer is an entity or agent who deals with electronic machinery or equipments
  • Refurbisher: Refurbisher is an organization an entity who refurbishes old electronic machinery or equipments
  • Producer Responsibility Organization {PRO}: As per the rule 3 (dd) the Producer Responsibility Organization {PRO} is a professional organization which is authorized to freely collect and channelize e waste generated from various sources

Government Bodies Involved in E-Waste Management Authorization

  • Central Pollution Control Board {CPCB} governed by Ministry of Environment, Forest and Climate Change. Government of India
  • Ministry of Electronics and Information Technology {MeitY}
  • State Pollution Control Board (Every state have different Pollution Control Board)

E-Waste Management Certifications

  • ISO 14001-2004 Certification: The ISO 14001 provides framework for implementation of an effective Environment Management System {EMS} and provided guideline for organizations to follow.
  • ISO 9001-2008 Certification: The ISO 9001 certification focuses on meeting customer’s expectations and paying attention to the customer. Becoming ISO 9001 certified means your organization has complied with all the requirement of the ISO 90001.
  • OHSAS 18001-2007 Certification: Occupational health and safety management certification is an international standard and it provides companies with framework to identify, control, and decrease the risks associated with health and safety within the workplaces. Taking the OHSAS will reflect that you are concerned about your employees’ health and safety and consider it as a priority within your organization.
  • UNFCCC Authorization: The United Nations Framework Convention on Climate Change {UNFCCC} is an internationally recognized environment treaty which is adopted by almost all the countries of the world. It was first launched in 1994. 197 countries agree to these standards.
  • E Waste Recycling Authorization from State or Central Pollution Control Board
  • Responsive Recycling Certification {R2}: R2 certification is issued by third party certifying bodies. It is intended for electronic recyclers. The companies who wish to become R2 certified should ensure that they comply with the R2 Standards. After complying with all the standards the company can contact the certifying bodies to get the R2 Certificate. The certifying body conducts an audit, and issues the certificate after successful completion of the audit. The R2 standards are specified under the R2 Technical Advisory Committee {TAC}.
  • The Recycling Industry Operation Standard {RIOS}: The RIOS is an integrated environmental, quality, health and safety management system certification. This certification ensures the effective management of systems and strengthens the health and safety programs. All recyclers including electronic or non electronic recyclers need to get this certification.
  • The Basel Action Network {e-Stewards}: It is a comprehensive set of performance requirements especially for the electronics recyclers and asset recovery sector. This standard holds the ISO 14001 and R2 practices within it. It is a community level certification based on standards build by the Environment Community and industry members called as e-Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment. It is an internationally recognized standard.

Who are Eligible for taking EPR Authorization?

The following needs the EPR Authorization

  • Electronic Producers
  • Consumers or bulk Consumers
  • Collection centers { Electronic }
  • Electronic Dismantlers
  • E waste Recyclers
  • IT and Telecommunication Companies
  • Consumer Electrical And Electronic Equipment {EEE}

Exemptions for taking EPR Authorization

The CPCB clarified the non-applicability of EPR Authorization as per the E-Waste Management Rules, 2016 in its notification dated 6th June 2019. As per CPCB the following are the cases when EPR Authorization in not required;

  • When the Electrical and Electronic Equipments {EEE} {including spare consumables, components} are not listed in the Schedule I of the E-Waste Management Rules, 2016
  • For importing Electrical and Electronic Equipments for the purpose of selling to EPR Authorized producers provided that the importer submits the following necessary papers;

    •   Copy of the EPR Authorization of the producer for whom the importer is importing

    •   And the letter of EPR Authorized producer that the importer is importing on their behalf

    •   Copy of the agreement with EPR Authorized producer for whom the importer is importing

  • For importing spares (either old or new) by the actual users(warranty service providers)
  • Also, Consumers or bulk Consumers who import Electrical and Electronic Equipments {EEE} provided that they must submit a self declaration on stamp paper stating that they do not intend to sell any of the imported products
  • Also, manufacturers of Electrical and Electronic Equipments for the purpose of selling to EPR Authorized producers provided that the importer submits the following necessary papers;

    •   Copy of the EPR Authorization of the producer for whom it is imported or manufactured

    •   And the letter of EPR Authorization of the producers stating that the EEE product is produced or imported on behalf of the EPR Authorized producer

    •   Copy of the agreement with EPR Authorized producer for whom it is imported or manufactured

Steps to get EPR Authorization

The following are the steps for making an application for EPR Authorization;

  • Fill the Form 1 of E waste management rules, 2016
  • Visit the CPCB official website
  • Follow the Final Guidelines on Implementation of E waste Rules, 2016 to fill the form

necessary papers Required to get EPR Authorization

The necessary papers needed for getting the EPR Authorization are as follows;

  • EPR Plan
  • Self declaration stating the compliance of Reduction of Hazardous Substance {ROHS} as a the procedure of processing the application
  • Copies of agreement with dismantlers, recyclers, treatment, storage and disposal facilities {TDFSs}, etc.
  • Declaration for the availability of the technical necessary paper as per the EN 50581 of EU
  • Copy of licenses/ permissions from the relevant government body for marketing products or doing business such as;

    •   GST Details

    •   Copy of incorporation certificate

    •   PAN Details

    •   And copy of IEC in case of importers

  • List of producers attached with the dismantler or recycler including the producer’s collection targets
  • A self attested copy of the authorization of dismantler or recycler

Benefits of getting the E-Waste Management Authorization

Not all agencies or related bodies are allowed to deal with e waste in any way. So getting the e-waste management authorization empowers you to deal with it. The major benefits of getting certified are as follows;

  • E-waste management by a certified agency assures the individuals, businesses and government bodies that the e-wastes are disposed in a safe and responsible way
  • It ensures mental health and safety compliance
  • It enhances community relations
  • Also, it increases customer’s confidence
  • It reduces accidents and injury frequency rates
  • It enhances insurability potential
  • It lowers processing and product cost

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