EPR Registration for
Cellular Telephones: Feature Phones

EPR registration for feature phones is mandatory for every manufacturer, importer, and brand owner that places feature phones on the Indian market. Producers obtain it through the CPCB e-waste EPR portal under the E-Waste (Management) Rules, 2022; feature phones fall under category ITEW15 (Cellular telephones) in Schedule I. 

This registration is the first step in a feature-phone producer's e-waste compliance. After approval, the producer is responsible for the handsets once they become waste. It meets this by purchasing EPR certificates from CPCB-registered recyclers to cover its recycling targets, and by filing annual returns on the portal.

Understanding Cellular Telephones as E-Waste Under Category ITEW15

The E-Waste (Management) Rules, 2022, in force since 1 April 2023, list the electrical and electronic equipment covered by Extended Producer Responsibility (EPR) in Schedule I. Item code ITEW15 covers cellular telephones, shown on the CPCB portal as separate Feature Phones and Smart Phones entries, so a feature-phone producer selects the Feature Phones line. A feature phone is a basic keypad-led handset with limited apps, and at end of life it becomes e-waste containing a battery, a circuit board and small amounts of metals. The Rules require this waste to go only to CPCB-registered recyclers, and the producer is legally responsible.
A producer for ITEW15 includes manufacturers, importers, and brand owners selling under their own name, including white-label or contract-manufactured models. Sellers, including online marketplaces, who sell feature phones of an unregistered producer are also covered. No entity may do business without registration or deal with an unregistered entity.

EPR Registration for Cellular Telephones (ITEW15) at a Glance 

EPR Registration Process for Cellular Telephones on the CPCB Portal 

• Establish your producer status and category: Map your product under ITEW15 (Feature Phones) and see if you are a manufacturer, importer or brand owner.
• Register an account on the CPCB EPR Portal: Register using your business email address and phone number and log in to the portal.
• Fill out the producer application: Provide details about the entity, authorised signatory, brand name, and manufacturing and importing information, and select ITEW15 Feature Phones.
• Declare sales information: Give the quantity of feature phones you sold in previous years. This will help CPCB determine your EPR obligation.
  Upload the documents as mentioned in the next section.

Pay the requisite fee and submit the application.

• Answer the questions from CPCB: CPCB will examine the application and may ask you for any further information.
• Get the EPR registration certificate: This will mention your category, yearly targets and conditions.
• Achieve the target: Purchase EPR certificates from registered recyclers via the portal and organise consumer awareness activities.
  Submit annual returns by 30 June every year.

Documents Required for EPR E-Waste Registration for Cellular Telephones

The list of documents generally required:

• Certificate of incorporation, LLP agreement, partnership agreement or proof of proprietorship
• PAN of the company
• Certificate of GST registration
• Importer-Exporter Code (IEC) in case of importers
• Address proofs of the registered office as well as the manufacturing and warehousing facilities
• Authorisation letter with an identity proof of the authorised person
• List of all feature phone models and their brands (if any), along with the details of their trademarks
• Sales/Import figures for each year, with relevant invoice/bill of entries from customs and/or a CA's certification

Validity of EPR Registration for Cellular Telephones and How to Renew It

• Validity: The EPR registration certificate for feature phones is valid for five years from the date of issuance.
• Renewal: Apply for the renewal of the registration on the CPCB EPR portal at least 120 days before expiry of the certificate. Renew early so there is no gap in registration. 

For compliance during the whole period of five years, the producers need to:

Submit annual reports on the portal within the deadline.

• Meet the recycling target each year using EPR certificates purchased from CPCB-registered recyclers.
• Update information on the portal regarding any changes in company information, brand names and products.
• Track sales, certificates, and recycling activities for future audits by CPCB or State Pollution Control Boards.
• Non-compliance with the above criteria will lead to environmental compensation or cancellation of registration.

How ERCS Private Limited Supports EPR Registration for Cellular Telephones

ERCS Private Limited supports feature phone manufacturers, importers, and brand owners in achieving their EPR compliance:

• Category & Applicability Check: Establishing whether the concerned item falls under ITEW15 and your requirement.
• Documentation: Examining sales data & documents before submitting an application.
• Portal Registration: Submitting the application, monitoring its status, and responding to CPCB queries.
• Target Calculation: Calculating your yearly EPR requirement under  Schedule III (for established businesses) or Schedule IV (for new market entrants) based on CPCB formulas and your past sales volume. 
• EPR Certificate Procurement: Introducing you to CPCB-registered recyclers.
• Filing of Annual Return & Renewal: File annual returns before the 30th June deadline and handle renewals.

Connect with ERCS Private Limited for professional assistance regarding EPR registration for cellular phones (ITEW15).