Meaning and Analysis of EPRA

Extended Producers’ Responsibility Authorization (EPRA)

  • Extended Producer Responsibility Authorization (EPRA) is permission granted by Central Pollution Control Board (CPCB) to Producers for managing Extended Producer Responsibility as per E-Waste (Management) Rules, 2016. Where producers include all the manufacturers, importers and brand owners, bulk consumers, and dealers of Electronic and Electrical Items. Extended Producer Responsibility Authorization (EPRA) issued by the Central Pollution Control Board (CPCB) for items included in Schedule I of E-Waste (Management) Rules, 2016.

Why is Extended Producers’ Responsibility Authorization required?

  • Extended Producer Responsibility (EPR) defines the life-cycle of products mentioned in Schedule I of E-waste (Management) Rules,2016 manufactured and distributed by the Dealer, Bulk consumer, Producer, and Importer
  • Extended Producer Responsibility (EPR) encourages a cradle-to-cradle approach to recover, recycle and reuse discarded products to make new products by way of managing materials, meaning products and packaging discarded by the consumer to reduce our impact on the environment.
  • Reuse and recycling of waste are comparatively more energy efficient than manufacturing from new materials and as the costs of collection, processing, and recycling are shifted from consumers to the producers of the Product, this outlook encourages the industry to be more innovative in product and packaging design.

Who needs Extended Producers’ Responsibility Authorization?

The business entities falling under the purview of E-waste (Management) Rules, 2016 are the manufacturers, producers, dealers, e-retailer, refurbished, dismantler and recycler consumers, bulk consumer, collection centers, involved in manufacturing, sale, transfer, purchase, collection, storage and processing of e-waste or electrical and electronic equipment listed in the Schedule I of E-waste (Management) Rules 2016, including their components, consumables, parts and spares which make the product operational.

What are the documents required for EPRA Application?

  1. Pan card Aadhar card of Authorized Person
  2. GST certificate
  3. Certificate of Incorporation (CIN)
  4. Sales record from the last 10 years or the start of business, whichever is later
  5. Website Address
  6. Authorization Letter except for Proprietorship
  7. Import Export Code (IEC) certificate

What is the procedure for EPRA Application?

The applicant is required to submit the documents required, along with the application, in a prescribed format to the Central Pollution Control Board (CPCB). The EPR Plan for the collection of the E-Waste is also submitted along with an agreement with the authorized E-Waste recycler. After the application is submitted, the CPCB may issue clarifications/modifications to the application. After these queries are answered to the satisfaction of the Central Pollution Control Board (CPCB), the EPR certificate is issued.

What is the cost of the EPRA certificate?

There is no Government fee for EPRA Application, though the applicant is required to submit the recycler agreement, which may incur some costs. If an external agency is hired, it may charge you accordingly. 

What is the applicability of EPRA Rules?

The business entities falling under the purview of E-waste (Management) Rules,2016 are the manufacturers, producers, dealers, e-retailer, refurbished, dismantler and recycler consumers, bulk consumer, collection centers, involved in manufacturing, sale, transfer, purchase, collection, storage and processing of e-waste or electrical and electronic equipment listed in the Schedule I of E-waste (Management)Rules 2016, including their components, consumables, parts, and spares which make the product operational but shall not apply to

  1. Used lead acid batteries as covered under the Batteries (Management and Handling) Rules, 2001 made under the Act
  2. Micro enterprises as defined in the Micro, Small and Medium Enterprises (MSME) Development Act, 2006
  3. The waste originating out of radio-active substances is covered under the provisions of the Atomic Energy Act, 1962.

What are the exemptions under Extended Producers’ Responsibility Authorization rules?

  1. The items which are not included in Schedule I
  2. The Import of EEE (Electrical and Electronic Equipment) is for the purpose of selling to EPR Authorized Producers
  3. Import of Spares (old and new) by actual users from Original Equipment Manufacturers (OEM) for the purpose of warranty replacement.
  4. Self-use
  5. Manufacturers of Electrical and Electronic Equipment (Including their spare components and consumables) listed in Schedule I of E-waste (Management) Rules, 2016. If they are manufacturing and /or importing exclusively for EPR-authorised Producers.

What are the compliances for EPR Certificate Conditions?

  1. Maintain Sales Records in Form-2 of these rules and make such records available for scrutiny by Central Pollution Control Board (CPCB) as and when directed.
  2. File an annual return in Form-3 to Central Pollution Control Board (CPCB) on or before the 30th day of June following the financial year to which that return relates to.
  3. File quarterly report to the Central Pollution Control Board in respect of the amount of waste collected and recycled.
  4. Organize Consumer awareness programs as submitted in the EPR plan.

Written By -Maharshi Shukla and Gourav Bavishi