Extended Producer Responsibility (EPR) Part 1 : E-Waste Management Certificate

This article is the first part of our EPR blog series. It focuses on the E-Waste Management Certificate and the process for obtaining EPR authorization in India. In the upcoming Part 2 and Part 3, we will cover EPR requirements for Plastic Waste and Battery Waste, respectively.

Introduction

Electronic waste (e-waste) is one of the fastest-growing waste streams in India, with tens of millions of tonnes generated each year. It contains toxic materials (like lead, mercury and brominated flame retardants) that can seriously harm human health and the environment if mismanaged. To tackle this challenge, India’s laws make producers responsible for their products’ end-of-life. In practice, that means any company that makes or imports electrical/electronic equipment must obtain an Extended Producer Responsibility (EPR) authorization from the Central Pollution Control Board (CPCB).

What is EPR

Extended Producer Responsibility (EPR) is an environmental policy approach that places the obligation on a producer to take responsibility for the management of a product’s waste beyond the point of sale, including waste generated during pre-production, production, and post-consumer stages until its end-of-life. The core idea is that the producer is accountable for collection, recycling, or safe disposal.

Regulatory Body & Rules

The governing body for grant and regulation of EPR is Central Pollution Control Board (CPCB) under which there are different portals for each kind of waste like Plastic waste, Battery waste, and E-waste. The rules governing E-waste are E-waste Management rules, 2022.

Who is it for

These rules apply to every manufacturer, producer, refurbisher, and recycler ;

Manufacturer: A manufacturer is any person, company, factory, or small/medium enterprise that is officially registered under Indian laws and has the facilities to produce electrical or electronic equipment listed in Schedule-I of the rules.

Producer: A producer is any person or business that sells electrical or electronic equipment (and their parts, consumables, or spares) under its own brand, whether it makes them itself, gets them made by others, or imports them including used equipment and this applies no matter how they are sold (for example, through shops, dealers, or online).

Refurbisher: A refurbisher is a person or business that repairs or rebuilds used electrical or electronic equipment (listed in Schedule-I) to make it work longer for its original purpose and then sells it in the market.

Recycler: A recycler is a person or business that processes and recycles waste electrical or electronic equipment (or their parts) to recover valuable materials like metals and other useful resources, following the facilities and guidelines set by the Central Pollution Control Board.

Validity

The validity of an E-waste Certificate is for a period of 5 years.

Renewal

After the expiry of e-waste certificate, the certificate must be renewed at least 120 days before the date of expiry.

Registration Process

Step by step guide for registering for E-Waste Management Certificate in India

1. Registration with CPCB Portal

All EPR registrations are initiated through the Central Pollution Control Board (CPCB) online portal, which serves as the central interface for submitting and monitoring compliance applications.

2. Portal-Based Application

Applicants must create a verified account and submit their registration electronically. The portal captures essential corporate and operational details, including entity type (Producer, Recycler, or Refurbisher), product categories, and market reach.

3. Documentation and Compliance

Applicants must upload all required supporting materials demonstrating corporate legitimacy, operational capability, and a robust take-back/recycling plan. These submissions should clearly establish the entity’s readiness to meet collection targets, recycling responsibilities, and ongoing reporting obligations.

4. Fee Submission and Approval

Applicable registration fees are submitted online. The CPCB/SPCB reviews the application for completeness and regulatory compliance. Upon satisfactory evaluation, the EPR Registration Certificate is issued.

5. Physical Follow-Ups Requirement

While the process is largely digital, certain applications may require physical verification or follow-ups with CPCB/SPCB offices to confirm compliance, inspect facilities, or clarify operational arrangements.

6. Ongoing Compliance

Registered entities must maintain comprehensive records of e-waste collection, recycling, and refurbishment activities. Annual returns are submitted via the CPCB portal to demonstrate adherence to regulatory targets and to maintain active registration status.

How CCC can help

Navigating EPR registration involves technical documentation, portal procedures, and coordination with authorities and recyclers. Expert assistance ensures smooth registration, mitigates risk of non-compliance, and streamlines ongoing regulatory obligations.

Benefits of E-waste Management Certificate

1. Legal Safety & Avoidance of Penalties

You comply with India’s E-Waste Rules; avoiding fines, legal issues, or shutdowns that result from non-compliance.

2. Permission to Operate & Market Access

You can legally manufacture, import, or sell electrical/electronic products in India without risk of regulatory blocks.

3. Enhanced Brand Image & Trust

Being EPR certified shows your business takes environmental responsibility seriously, which improves reputation among customers, partners, and investors.

4. Environmental Protection

Helps ensure proper handling, recycling, and disposal of hazardous materials in e-waste, reducing pollution of soil, air, and water.

5. Better Regulatory & Operational Planning

With EPR, you plan your waste-handling, collection, recycling obligations. This improves internal process control and readiness for audits.

Post EPR Certificate Compliances

1. Adherence to Approved EPR Plan

Implement the collection and channelization targets exactly as approved in the EPR authorisation, ensuring end-of-life products are collected only through authorised collection centres, dealers, take-back systems, or buy-back arrangements.

2. Collection & Recycling Targets

Achieve the year-wise recycling or collection targets specified by the Central Pollution Control Board (CPCB) and maintain verifiable proof of transfer to authorised dismantlers or recyclers.

3. Quarterly & Annual Returns

File quarterly and annual returns on the CPCB portal within prescribed deadlines, detailing quantities collected, dismantled, and recycled along with supporting invoices and recycler certificates.

4. Record Maintenance

Maintain updated records of e-waste generated, collected, stored, transported, and recycled for at least five years, keeping all transporter and recycler documentation readily accessible.

5. Authorised Recycler Engagement

Partner exclusively with CPCB/SPCB-authorised recyclers, obtain valid recycling certificates for quantities handled, and reconcile EPR credits on the portal.

6. Safe Storage & Handling

Store e-waste in an environmentally sound manner as per guidelines, ensuring proper labelling and preventing leakage of hazardous substances until handover to recyclers.

7. Consumer Awareness

Conduct regular consumer awareness programmes about safe disposal and publicise collection centre or take-back details on websites, product manuals, and packaging.

8. Renewal & Audit

Apply for renewal of EPR authorisation before its expiry and cooperate with any CPCB/SPCB inspections or audits, providing complete records when requested.

Conclusion

Getting an EPR authorization means your company stays compliant with the law while proving that you care about the environment. Therefore, CCC manages all the paperwork and compliance steps for you, ensuring a smooth journey and letting you enjoy the benefits without the regulatory hassle.