EPR Registration for
Printers, including Cartridges

EPR Registration for Printers, including Cartridges (ITEW6) is intended for companies that produce, import, and sell printer products in India under the E-Waste (Management) Rules, 2022. The scheme places responsibility on producers to address the environmental issues associated with e-waste generated throughout the life cycle of such items.

For these purposes, eligible producers must register on the CPCB EPR Portal and comply with the corresponding EPR obligations. These include choosing the right EEE category, providing the necessary information about the company and products, fulfilling EPR obligations, and ensuring that e-waste is properly recycled through authorised recycling channels.

What are Printers, including Cartridges (ITEW6)

The printers, including the cartridges (ITEW6), are categorised under Information Technology and Telecommunication Equipment (ITE) in Schedule I of the E-Waste (Management) Rules, 2022. These items include printers designed to produce documents, images, or other information, along with their corresponding cartridges. The producers and importers of the specified ITEW6 category must fulfil all relevant EPR requirements to ensure proper recycling of e-waste.

ITEW6 is used to identify printers and cartridges as a category of electrical and electronic equipment.

Key Highlights of EPR Registration for Printers, including Cartridges

The average lifecycle for products classified as ITEW6 is set at 10 years. CPCB's average-life figure is used to calculate the EPR target:

Step-by-Step Process for EPR Registration for Printers, including Cartridges

The steps to be followed under the e-waste to obtain EPR Certification for printers, including cartridges:

• CPCB EPR Portal Registration: Manufacturers need to register themselves on the CPCB EPR Portal. Under the e-waste management guidelines, all producers/manufacturers, recyclers, and refurbishers are required to register on this portal.
• Submit Application and supporting Documents: All required documents, including the Incorporation Certificate, PAN, and other product information, must be submitted. For printer cartridges, select the code ITEW6 and mention the total number of products sold in metric tonnes. It could also include the details of awareness plans.
• Submit Registration Fees: After submitting the application, pay the registration fees as per the CPCB fee structure.
• CPCB Scrutiny: CPCB evaluates the application on the portal according to its SOP. If documents or information are missing, the application is returned with deficiencies, which must be corrected and resubmitted through the portal 
• Receipt of EPR Registration: You shall receive the EPR Registration Certificate upon approval of the application, in accordance with the CPCB guidelines and other conditions.
• Obligation Fulfilment under EPR: Post-Registration, it becomes mandatory to comply with e-waste recycling obligations. It includes co-operation with the CPCB-registered recyclers and the generation of EPR certificates for recycled e-waste.
• Return Filing: The annual returns shall be filed through the CPCB EPR Portal.

Documents Required for EPR certificate for printer cartridges

The documents may vary depending on whether the applicant is a manufacturer and producer or another entity. The general documents required to be submitted through the CPCB EPR Portal are as follows: 

• Incorporation certificate of the company
• PAN card of the company
• GST certificate, if applicable
• Details of the authorised individual handling EPR Compliance
• Details of products falling under ITEW6
• EEE Product and quantity details (reported in metric tonnes)
• Details of Schedule I category falling under the registered products
• Sales/Imports details of the relevant products
• RoHS compliance self-declaration
• Awareness Plan (creating awareness regarding e-waste disposal)
• Declaration on availability of RoHS technical documents 
• Any other information requested by CPCB during scrutiny of application

Validity & Renewal of EPR E-Waste for Printers, including Cartridges 

Registration under Extended Producer Responsibility (EPR E-Waste registration for Printers, Including Cartridges ITEW6) remains valid until the expiry period specified by the CPCB under the E-Waste (Management) Rules and Regulations.

• Validity: The validity period for EPR registration for Electrical and Electronic Equipment (EEE) under the E-Waste (Management) Rules, 2022, is 5 years.
• Renewal: Once 5 years have expired, registration may be renewed on the CPCB EPR Portal.
• Updating of Information: Upon renewal of EPR registration, producers may need to update information related to products, recycling operations, etc.
• Continued Compliance: Producers must continue to comply with EPR targets throughout the registration's validity period.
• Timeline Recommendation: It is recommended that an application for renewal be submitted several months (90-120 days) before the expiry date to prevent any suspension of operations or compliance.
• Non-Renewal of EPR Registration: Non-renewal of EPR Registration will cause issues in continued compliance with EPR activities.

It is important to note that the 5-year validity applies to the registration, not to the EPR certificates; the EPR certificates are valid for 2 years from the end of the financial year in which they were generated.

Penalties for Non-Compliance

• Monetary environmental compensation levied by CPCB/SPCB for shortfall in recycling targets or non-registration.
• Potential action under the Environment (Protection) Act, 1986, including legal proceedings for continued non-compliance.
• Risk of being barred from selling/importing printers, including cartridges, in India until compliance is restored.

How Can ERCS Private Limited Help You Obtain ITEW6 EPR Registration

ERCS assists the business in every aspect of the EPR Registration process for printers, including cartridges (ITEW6), from eligibility determination to CPCB registration and beyond.

1. Correct Classification & Eligibility Assessment: We do an eligibility assessment and the correct classification of printers and cartridges as per the E-Waste category that applies to you, including ITEW6.
2. Sales Data & EPR Target Calculation: We analyse your sales data and product weight data to come up with the correct calculation of EPR targets.
3. Complete CPCB Application: We file your EPR application along with the necessary documentation, product details, awareness plan and fee through the CPCB portal.
4. EPR Certificate Sourcing: We help you buy EPR certificates on the CPCB portal from registered recyclers authorised for ITEW6 and file them against your annual obligation
5. Post-Registration Compliance: We help with your returns, amendments, renewal and CPCB correspondence in order to keep your registration compliant.