EPR Registration

Did you know that India generates and disposes of around 25000 tonnes of plastic waste every day into the environment? According to the 1989 Basel Convention, India made a commitment towards environmental safety and protection along with other global accords that focused on the principle of responsibility among participating nations.

Registering for EPR (Extended Producer Responsibility) for plastic waste and imports is crucial to align with India's environmental laws. By acquiring this certification, businesses play a role in minimizing the environmental effects of e-waste, fostering sustainable practices, and supporting the recycling of precious materials. With India generating over 50 million tons of e-waste annually, EPR registration is key to addressing the escalating e-waste challenge.

Therefore, the Government of India stepped up to bring a legal mechanism to enforce environmental responsibility by laying guidelines for effective waste disposal for recycling and reusing that included the use of resourceful organizations with an awareness of the value of trash, and strict punishment for default of legal provisions, which also birthed the concept of EPR. Read further to know more about EPR registration, its types, benefits, documents required, and the process of obtaining registration.

EPR, or extended producer responsibility, refers to an approach for preventing, removing, and recycling plastic and electronic trash that is both inexpensive and environmentally friendly. The Fourth Amendment to Plastic Waste Management Rules 2016 implemented EPR authorization to enable producers, brand owners to dispose of wastes in an environmentally sound manner and recycle plastic and e-waste, making them accountable, and those in breach are deemed accountable to regulate plastic and electronic waste following the conclusion of the product's life cycle.

Since, suppliers, manufacturers, and brand owners have the most control over designing, managing, and handling products, thus they are in a better position to embrace waste management in such a way that it minimizes its negative impact on the ecosystem in its entirety. The Central Polluting Control Board CPCB, which is part of the Government of India's Ministry of Environment, Forests, and Climate Control, is the authority for granting registration and overseeing compliance of regulations by liable persons.

• Importers
• Producers
• Brand owners

1. EPR Registration for E-Waste: EPR's E-Waste policy mandates manufacturers and importers to manage electronic items sustainably, reducing environmental and human health impacts. Producers are required to cover expenses for recycling and disposal, promoting sustainable and easier-to-manage products. EPR Registration for E-Waste transfers responsibility for managing electronic waste from taxpayers and consumers to producers, who are responsible for the environmental impact of their products.
                                            
2. EPR Registration for Plastic Waste: Plastic Waste Management Rules, 2016 established the Extended Producers Responsibility EPR regime, requiring producers, importers, and brand owners to take responsibility for their plastic packaging waste. This includes proper processing through recycling, reusing, or end-of-life disposal methods, promoting environmentally friendly practices, and reducing landfill waste. Further, Supporting EPR registration for plastic waste can reduce negative effects on the environment, decrease waste, and promote sustainability by promoting ethical business conduct and product lifecycle ownership.

3. EPR Registration for Battery Waste: Manufacturers, importers, and producers of batteries must obtain an EPR certificate for battery waste. Both the companies producing the batteries and those importing batteries or related equipment are required to register for EPR. This regulation applies to all battery types, regardless of their size, use, or composition.

4. EPR Registration for Waste Tyres: Under the Hazardous & Other Waste Management  Amendment Rules 2022, any organization or person engaged in the manufacturing, distribution, sales, reuse and recycling, and import of waste tires is held responsible for EPR Registration for Waste Tyres and related compliances.

5. EPR Registration for Used Oil: The government of India has also extended responsibility towards the oil either crude or synthetic producers and importers, collectors and recyclers have been made responsible for the management and disposal of oil wastes in an environmentally safe manner. Under the Hazardous Wastes Management Rules, the above-mentioned persons and business entities have been obligated to obtain EPR registration and fulfil compliances under 2022, which will be applicable from April 2024.

EPR encourages business entities to develop solutions for recyclable and lasting products while reducing regulatory constraints on manufacturers as a means of combating planned depreciation. Other than this, here are the key benefits of EPR Registration:

1. Encourages Responsibility Towards the Environment: EPR certification lowers the need to burn or dump electronic waste and plastic waste, which can be detrimental to human beings whenever consumed. Accordingly, businesses may formulate products that are less complicated for reuse or disposal after the conclusion of their useful lives by considering the complete product lifecycle.
    
2. Reduces the Cost of Compliance: With EPR registration, businesses can lower the cost of complying with EPR rules by employing environmentally friendly product designs and reducing the total amount of packaging used.  In addition, they could also join with other businesses to share the expense of end-of-life management.
    
3. Saving Business Costs and Increasing Productivity: By adhering to EPR registration and relevant guidelines, businesses can save their business costs and achieve long-term financial savings. Furthermore, through the application of sustainable product designs and minimal packaging costs, businesses could also lower their manufacturing costs and improve their efficiency.
    
4. Boosts Brand Value: EPR registration reflects a company's unwavering commitment to environmental protection and ethical corporate practices, which is essential for building a strong brand image in the modern era when customers favour environmentally and socially conscious businesses. Hence, companies may enhance their reputation and confidence among customers through EPR registration, which will boost client retention and competitiveness in the market.

• GST  Registration Certificate
• MSME Registration Certificate
• Importer Exporter Code, IEC Certificate
• Sales Purchase invoice for the financial year
• Certificate of Incorporation/Partnership Deed
• Mobile Number and Email of Authorized Person
• Scanned copy of signatures of authorized persons
• Scanned copies for the KYC of authorized signatory
• NOC or Consent Letter from State Pollution Control Board
• Flowchart or diagrams for processes, required for producers only
• Permits, Approvals by SPCB for business units with production facilities 

                                   

1. Create a Login ID on the CPCB portal: To acquire login credentials, applicants need to fill in certain basic details such as name, email ID, and phone number to register themselves on the Central Pollution Control Board CPCB Portal. For application purposes, separate application pages have been created for manufacturers, brand owners, and importers, separate application pages have been created.
    
2. Application Verification: But before filling out any form PIBOs must check the electronic devices list under schedule-I and the specified plastics subcategory in management rules when submitting an online application. If your operations generate either the plastic waste or electrical and electronic waste that have been listed, then you should start the EPR Authorization process.
    
3. Filling and Submit Application: Every PIBO undertaking business operations in only one state must make an application to the State Pollution Control Board, whereas where any PIBO is operating or handling operations in more than one state must apply to the Central Pollution Control Board. The relevant form must be filled out duly along with all necessary attachments.
    
4. Processing of the Application: On the receipt of the EPR application, the State/Central authority will thoroughly check and verify the application and if found complete in all respects, shall proceed with further or otherwise shall raise inquiry, and upon determining that the concerned PIBO has an efficient system to manage EPR in the country, will suggest awarding EPR India Registration by CPCB.
    
5. Grant of the CPCB EPR Registration: The PIBOs will receive their EPR registration certificates from the CPCB once the complete application has been verified. 

Renewal of Application of EPR Registration

The EPR Certificate for E-Waste is valid for 1 year and can be renewed further. For renewal, the renewal application prescribed in Form 1 should be filled in Form 1 by submitting the form at least 60 days before the expiration of the EPR registration along with the documents approval from the State Pollution Control Board, Pollution Control Committees, or other recognized entity attesting to the correct disposal and handling of hazardous wastes, and compliance with effluent and emission requirements.

Time Involved in Getting EPR Registration

If the application is complete in all respects, it may take up to 35-45 days to acquire CPCB EPR registration. However, the application will be denied if it is shown to be insufficient or to include any errors.

EPR Registration Fee or Cost

EPR registration fees may differ based on factors such as the type of waste and geographic location. They are intended to cover administrative costs associated with the registration process. According to government guidelines, here is the typical fee structure:

                                            

• Waste Generated in TPA: Less than 1000 - EPR Application (Govt) Fees: ₹10,000
• Waste Generated in TPA: Between 1000-10,000 - EPR Application (Govt) Fees: ₹20,000
• Waste Generated in TPA: More than 10,000 EPR Application (Govt) Fees: ₹50,000

You can receive the EPR registration certificate within 25 to 30 days after completing the submission process. It will be valid for 1 year.

Validity & Cancellation of EPR Registration

A new EPR registration will be valid for 1 year, while a renewed registration will be valid for 5 years. The Producer Importer Brand Owner must submit their renewal application, along with the necessary documents, at least four months before the registration expires. If any documents submitted by the PIBO are found to be false, their EPR Plastic Waste registration may be canceled or suspended at any time.

In addition to enhancing your company's brand, promoting sustainability, and minimizing waste, compliance with EPR requirements can have other positive effects on the business itself. If the restrictions apply to your business, starting operations without a valid EPR registration would be against the regulations if your items or operations fall under their purview. If not, both the corporate company and the approved individual will be subject to fines and legal action. Therefore, choose a trusted and reliable source like Agile Regulatory who will assist you to get EPR registration and compliance without any penalties.