EPR channelization by PRO on behalf of Producers –
Frequently Asked Questions
1. Can the PRO fulfill the EPR targets on behalf of its Member Producers?
A. Yes, as per E-Waste Management Rules (2016) and related guidelines, a PRO is authorized to procure E-Waste on behalf of its member producers and channelize it to its authorized dismantlers/ recyclers for processing.
2. How does the PRO procure and channelize e-waste?
A. PRO can procure from Bulk consumers of EEE through auctions or buyback mechanisms. Alternately, e-waste can also be procured from Informal Market sources like E-waste aggregators. E-waste is channelized as per CPCB guidelines to the authorized Dismantlers/ Recyclers part of the PRO and Producers approved EPR Plan.
3. Who pays for the costs involved?
A. The PRO buys-back specific EEE category quantities in bulk and can distribute the same among its member producers as per their individual requirements for fulfilling their respective EPR targets. The costs towards e-waste acquisition and channelization are borne by the Member Producers as per the quantities consumed by them. The costs get distributed among many producer members who are paying collectively for this channelization. This is a very efficient mechanism of EPR target fulfillment.
4. How do we ensure that the procurement and channelization happen as per process?
A. Your PRO only works with CPCB/ SPCB authorized Dismantlers/ Recyclers. Whether the procurement is being done from Bulk Consumers of EEE or from Informal Sector E-Waste Aggregators, it is ensured that the sellers are GST registered and generate a valid GST invoice for the purchase. Photographic evidence is collected for loading/ unloading of e-waste. If the total value of e-waste procured is more than INR 50,000/-, an E-Way Bill is also generated which is verifiable on the E-Way/ GST website of the Government. Your PRO also issues a transparent “Apportioning Certificate” that lists the total quantity of e-waste collected/ channelized in that lot along with EEE category and also a list of all the Producers who were allocated quantities from that lot. Along with this, other necessary documents such as a computerized weigh-bridge receipt, certificate of destruction/ recycling, Material Balance Report etc. are also issued. All documentation at each step of the process is provided to all the Member Producers.
5. How is this method different from the Producer directly buying back from the market?
A. It is always preferred and appreciated that the Producer, as a first step, should try to procure/ collect e-waste at its end, using the various Collection Mechanisms approved through its EPR plan, and then channelize it to a partner recycler for disposal. However, in cases, where the producer is unable to fulfill its EPR targets sufficiently in a given year, the PRO can assist procurement and channelization in an authorized manner through this mechanism. The goal of both mechanisms (Producer directly collecting using its collection schemes; PRO collecting and channelizing on behalf of its producer members), is same — which is to bring e-waste into the formal stream for processing, thereby reducing (or eliminating) its passage into the informal stream. There is however, a slight advantage of lowered costs when the PRO does the procurement directly. Procuring bulk quantities from our market sources gives us better bargains on material purchase prices. The benefits of lower costs are passed on to our producer members. Besides, transportation, handling and other channelization and recycling/ disposal costs get distributed among all the participating producer members, thus bringing in further cost advantages to all.