If you manufacture, brand or import electrical and electronic equipment (EEE) listed in Schedule I of the E-Waste (Management) Rules, 2022, you must register as a producer on the Central Pollution Control Board (CPCB) portal and meet an annual recycling target by buying EPR certificates from registered recyclers. The obligations apply from 1 April 2023 and the targets rise each year. This checklist sets out what producers need to have in place.
1. Confirm you are a producer
The E-Waste (Management) Rules, 2022 were notified under the Environment (Protection) Act, 1986 and, according to CPCB’s FAQs, took effect on 1 April 2023. A producer is anyone who, irrespective of the selling technique (dealer, retailer, e-retailer):
- manufactures and sells EEE, components, consumables, parts or spares under its own brand;
- sells under its own brand EEE assembled or produced by others;
- sells imported EEE or its parts; or
- imports used EEE.
The Rules cover 106 EEE items in seven categories listed in Schedule I, together with their components, consumables, parts and spares. CPCB’s FAQs state that the Rules do not apply to waste batteries (covered by the Battery Waste Management Rules, 2022), packaging plastics, micro enterprises as defined under the MSMED Act, 2006, and radioactive waste.
Checklist
- Map each product and spare part to a Schedule I EEE code
- Decide which legal entity is the producer (brand owner or importer)
- Check whether you are also a “manufacturer”, which is a separate registration category
2. Register on the official portal
Manufacturers, producers, refurbishers and recyclers must register on CPCB’s E-Waste EPR portal. Dismantlers and bulk consumers do not register. Producer registration requires sales data by EEE code (Table-1), company documents such as GST and IEC details, and RoHS declarations.
Note: At the time of writing, CPCB’s e-waste EPR system is hosted at eprewaste.cpcb.gov.in and its documents are linked from cpcb.gov.in. Some older CPCB documents refer to a different, non-government domain that is now an unrelated private website. Do not enter credentials or pay fees on any site you have not reached from CPCB’s own pages.
Checklist
- Registration certificate obtained before placing products on the market
- Sales data in Table-1 consistent with GST and import records
- Amendments filed when new EEE codes are added or company details change
3. Know your EPR target
CPCB’s FAQs set out the targets as a percentage of estimated e-waste generation, which is calculated from past sales and the average life of each product:
| Financial year | Target (Schedule III) |
|---|---|
| 2023-24 and 2024-25 | 60% |
| 2025-26 and 2026-27 | 70% |
| 2027-28 onwards | 80% |
Producers who have only recently started sales follow Schedule IV instead. The FAQs state that this is 15% of 2021-22 sales for FY 2023-24, 20% of 2022-23 sales for FY 2024-25, and 20% of sales two years earlier from FY 2025-26 onwards. Importers of used EEE carry a 100% obligation on the quantity imported. Solar PV modules, panels and cells are covered by the Rules but have no recycling target; producers must store that waste up to 2034-35 as per CPCB guidelines.
Checklist
- Obligation for the current year checked on the portal for each EEE code
- Schedule III or Schedule IV basis confirmed
- Budget set for EPR certificates
4. Buy EPR certificates from registered recyclers
Producers meet their targets by purchasing EPR certificates on the portal. Key points from the CPCB FAQs:
- Certificates are generated by registered recyclers for e-waste actually recycled, expressed in four end products: gold, copper, aluminium and iron.
- A producer can buy only from recyclers registered on the portal who are registered for the relevant EEE code.
- The FAQs set a cap on purchases in a year (the obligation plus 5%, plus any leftover liability) and explain how a surplus or shortfall in gold certificates is adjusted against copper and aluminium.
The E-Waste (Management) Amendment Rules, 2024 added a price band. CPCB’s environmental compensation guidelines quote Rule 15(9): CPCB is to fix the highest and lowest prices for exchange of EPR certificates at 100% and 30%, respectively, of the environmental compensation for not meeting the EPR obligation.
Checklist
- Recycler’s registration and EEE code coverage verified on the portal
- Certificates bought within the band set by CPCB
- Metal-wise purchases reconciled with the obligation
5. Comply with RoHS limits
Rule 16 restricts hazardous substances in new EEE and spares. As per CPCB’s FAQs, maximum concentrations are 0.1% by weight in homogeneous materials for lead, mercury, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers, and 0.01% for cadmium, subject to the exemptions and transitional provisions in Schedule II as amended in July 2023.
Producers submit a RoHS self-declaration during registration and declare that technical documentation (for example, as per EN IEC 63000) is available for verification by CPCB or State Pollution Control Boards.
Checklist
- Supplier RoHS declarations and test data on file for each product
- Technical file ready for inspection
- Exemptions under Schedule II checked for older equipment and spares
6. File returns and keep records
The Rules require producers to file quarterly and annual returns on the portal. Filing timelines have been revised from time to time, so check the portal for the current due dates rather than relying on last year’s calendar. Keep sales, import and certificate records aligned, because the Rules provide for audit of registered entities.
Checklist
- Return calendar maintained for the year
- Sales data reconciled across returns, GST and import data
- Records retained for audit
7. Understand the penalties
CPCB levies environmental compensation for violations, including shortfalls in EPR obligations, under its EC guidelines, approved by the Ministry of Environment, Forest and Climate Change in September 2024. The guidelines list the provisions of the Rules for which compensation can be levied, so read them alongside your own compliance calendar rather than treating the EPR target as the only exposure.
Quick reference
| Item | What to have ready |
|---|---|
| Producer registration | Certificate covering every EEE code you sell |
| Annual obligation | Target per EEE code and basis (Schedule III or IV) |
| EPR certificates | Purchases from registered recyclers, metal-wise |
| RoHS | Self-declaration and technical documentation |
| Returns | Quarterly and annual filings on the portal |
| Bulk consumers you supply | Remind them e-waste must go only to registered producers, recyclers or refurbishers |
How Aaditech can help
Aaditech handles e-waste EPR registration for producers, including EEE code mapping, Table-1 sales data, RoHS declarations, amendments and annual compliance planning. We can also review whether the same products need BIS, BEE or WPC approvals, so that all approvals are planned together. See our EPR registration service.