Handbook on E-Waste Recycling

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www.corpzo.com HANDBOOK For HANDBOOK For E E- -Waste Recycling Business Waste Recycling Business

ACCELERATING ACCELERATING BUSINESS BUSINESS EVOLUTION EVOLUTION ABOUT US ✓ We are Corporate Finance & Compliance Advisory organization having our presence across the globe aiming to ease compliance and assist in business evolution. ✓ We ensure that your business is up to pace with todays hyper- dynamic corporate legal and tax structure(s) ✓ We take care of your compliance, so you can focus on your business. ✓ We are a corporate compliance organisation with expertise at providing bespoke solutions compliance, auditing, tax management advisory. encompassing management, finance, waste and ✓ We have helped more than 6000 business in our journey so far. ✓ We have facilitated more 5000+ clients in attainment of there business licences and registrations and more than 150 clients in obtaining SEBI/RBI licences for financial businesses like NBFC, Payment Gateway etc) throughout India. ✓ We assist 100+ business in their day in day out accounting, book-keeping, tax management and audit functions.

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E-Waste Scenario Electrical & electronic waste (e -waste) is one of the world's fastest rising discharges in the current times. According to a recent estimate, ✓ Consumers discarded 53.6 million tonnes worth of electronics in 2019, globally up 20 percent in 5 years. But only 17.4 percent was recycled sustainably. ✓ India generates about 3 million Tonnes (MT) of e-waste annually and ranks third among e-waste producing countries, after China and the United States. Reports state that it might rise to 5 million tonnes by 2021. ✓ With COVID-19 keeping people indoors and on devices, the usage of electronics is only getting higher. ✓ The way forward for consumers could be the 4 R method of reuse, repair, recycle, and research. Most of the e-waste generated in India is recycled through the informal sector with low capacity and insufficient processing technologies which leads to deterioration of the environment due to excessive emissions generated by such recyclers. India needs a highly sustainable and sufficient e -waste recycling ecosystem in order to achieve end -to -end recycling. The major source of generation of E-waste are used electrical and electronic equipments like computers, mobile cell phones, personal stereos, including large domestic appliances such as refrigerators, air conditioners, etc., which are not fit for their originally intended usage and are meant for recovery, recycling or disposal. E-wastes involve more than a 1000 distinct substances, all of which are toxic and potentially detrimental to the environment and human health, unless they are treated in an environmentally sustainable way. The high rate of product obsolescence is a relevant factor for increased e -waste generation. Notwithstanding appropriate recycling and treatment services, these chemicals make their manner to scrap dealers and the supply chain of dismantlers that are in the informal sector. The dismantling activities are performed in a dangerous manner which leads to major environmental and safety problems. The National Environmental Policy, 2006 (NEP) was formed with an aim to promote sustainable development and the need to encourage the reuse/recovery/recycling of useful waste materials, thereby preserving natural resources and reducing waste destined for final disposal to ensure that all waste is managed environmentally sound. The NEP further advocates giving the informal sectors legal status and strengthening. Given the high recyclable capacity of e -waste and comprehensive recycling activities in the informal sectors, the recycling policies in units must be channelled using environmentally sound technology.

Rationale & Scope of E- Waste Guidelines E -waste Recycling Plant is an industrial enterprise on its own requiring clearances from different agencies to build and run the facility. Throughout the light of the need to control environmental pollution, the environmental clearances have become important among the various clearances today. Those facilities are to be built within the organized sector. However, to provide the unified plant with a support system, the operations currently conducted in the informal sector must be modified or dovetailed. This will enable the informal sector to be brought into the mainstream of the economy and would facilitate compliance with the law. The proposed mechanism for the e -waste facility is only an illustrative concept and during the construction of such facilities specific details must be sorted out. The' E -waste recycling facility guidelines' are in accordance with the existing' Environmentally sound e -waste management guidelines' provided by the Ministry of Atmosphere and Forests, the Government of India and the Central Emissions Control Board (CPCB). These can be interpreted in accordance with the CPCB guidelines and every other advice / best practices / standards etc., also recommended by the Indian government. The purpose of these guidelines is to provide advice to all those who are setting up an e- waste recycling facility in order to become familiar with the procedures and clearances needed for such facility. These instructions are essentially a framework and reference manual for e - waste facility establishment and operations. The guidelines only provide information on the basic requirements and procedures for setting up a facility like this. The basic specifications can differ for each facility, based on the procedure used. All processes and mandatory criteria shall be in compliance with the law and regulations which apply at the time the application is processed. The guidelines shall apply to all those who intend to set up e - waste recycling facilities in the formal sector and use environmentally sound recycling technologies to recover from e-waste the precious and other metals. The rules shall not extend to such fluorescent lamps which are processed.

Current E-Waste recycling Practices The electronics sector has emerged as Indian industry's fastest growing segment both in terms of production so exports. In the telecommunications and IT industry, the share of computer services has increased from 38.7 per cent in 1998-99 to an aggregate of 61.8 per cent in 2003 - 04. The transition in the IT sector coincided with liberalization, and the opening up of Indian markets along with a change in India's import policies against electronics, leading to import substitution of indigenously manufactured equipment. The Indian Computer industry is growing at a compounded annual growth rate of 25 per cent, according to estimates made by the Manufacturers ' Association of Information Technology (MAIT). The growth of electrical and electronic products, usage rates and higher obsolescence rates lead to higher e - waste generation. The growing obsolescence of electronic products is also contributing to the tremendous import of used electronics. The generation of e - waste has significant economic and social impacts and the e - waste recycling industry also experiences an exponential growth. According to the estimate from the 2007 MAIT-GTZ evaluation, 3.30,000 metric tons of e - waste are produced in India annually and are expected to reach 4.70,000 metric tons by 2011. Nevertheless, only 19,000 metric tons of e - waste are estimated to be recovered and the majority of the e - waste can not be held accountable. There is no large - scale coordinated e - waste recycling system operating in India, and a number of small and medium - sized e-waste dismantling and recycling units are distributed in urban peri - urban areas of the cities. Although most of these services are in the informal sector, some of the recycling systems for e - waste is reported with the CPCB. Sixty - five Indian cities contain more than 60 per cent of India's total e - waste. Ten states produce 70 per cent of India's total e - waste. Maharashtra ranks first in the list of e - waste producing states in India followed by Tamil Nadu , Andhra Pradesh, Uttar Pradesh , West Bengal, Delhi, Karnataka, Gujarat , Madhya Pradesh and Punjab. Mumbai ranks first among the top ten e - waste generating cities, followed by Delhi , Bangalore, Chennai , Kolkata, Ahmedabad, Hyderabad, Pune, Surat and Nagpur. In Chennai and Bangalore two small e - waste dismantling facilities are in place. Throughout India, there is no large - scale organized e - waste recycling facility, and all recycling is in the unorganized sector.

1. Project Planning E-wash recycling plant is an industry activity itself requiring the permission of the creation and operations of the facility from several authorities. In the organized sector such facilities must be established. The process starts with the planning of the project and the creation of the draught document in line with the planned operational and business plans for the project. The planning of the projects, purchase of land, and required permits to be acquired from the authorities concerned in whose competence the unit is to be established, should be implemented in accordance with each State's regulations. The environmental Clearances are among the numerous clearances required today for establishing an E-Waste Recycling Facility. The Detailed Project Report (DPR) of the facility should include the comprehensive details of the requirements and the initial outlay for the same. The intention behind these guidelines is to facilitate in the process of seeking such clearances. environmental compliance

2. COMPLIANCE REGIME Environment Clearance: - E-Waste recyclers fall under schedule I of Environment Impact Assessment notification of 2006 and hence require Environmental Clearance (EC). ✓ ✓ Pollution Control Board Consent: - E-Waste Recycling Unit needs to obtain Consent to establish prior to Establishment of the Unit and Consent to Operate before commencing operation of the Unit. ✓ ✓ Hazardous Waste Authorisation: - E-Waste constitutes hazardous materials and is classified under hazardous wastes under Hazardous Wastes (Management and Handling) Rules. ✓ ✓ Recycler Permission/License: - E-Waste recyclers has been listed in Schedule iv and shall be registered with the Central Pollution Control Board (CPCB) in accordance with the Chapter III, Rules 8-10. ✓ ✓ Factory License: - Every manufacturing and industrial unit obtain a Factories License in accordance with the provisions of the Factories Act. (Click to Read More) ✓ ✓ Fire NOC: - A company is a legal entity and a legal entity established under the Law. Hence a company is a form of the organization having broad legal potential and that may own property and also incur debts in its own name. (Click to Read More) ✓ ✓

3. Environment clearance The EIA notification dated September 2006 notified under the Environment (Protection) Act, 1986 lays down process for the establishment of a recycling facility for e-waste recycling which are much similar to Treatment Storage Disposal Facility (TSDF). Any person establishing an E-Waste recycling plant shall seek the permission of the respective State Pollution Control Board if the facility is likely to emit waste or trading effluent into a stream, sewer or on a property or is likely to cause any type of Air Pollution in excess of the prescribed standards. Any industry specified in the schedule I of Environment Impact Assessment notification of 2006, shall mandatorily attain Environmental Clearance. 3.1 DOCUMENTS REQUIRED For Environmental Clearance 1. Prescribed application forms I & XIII (to be downloaded from the concerned Board’s website or available free of cost from any of the office of the Board and should be submitted in triplicate along with the prescribed consent fee.) 2. Project Report 3. Land/shed possession certificate 4. Location Map 5. EIA & EMP Reports (for industries listed in Schedule I of the EIA notification) 6. Water & materials balance 7. Proposed Pollution Control measures for water, air and solid and hazardous wastes 8. Detailed Layout map

4. Pollution Control Board Consent According to the provisions of the Water (Pollution Prevention and Control Act), 1974 and Air (Pollution Prevention and Control Act, 1981, an entrepreneur forming or running a business or industry and is discharging / emitting contaminants into any resources of water or land / air is required to obtain the permission to pollute the atmosphere water / air known as the Pollution Control Consent comprising of CTE & CTO. i. Consent for Establishment (CTE). An industrial unit's Consent for Establishment (CTE) as the word implies is prerequisite prior to any industry or process being established. Without CTE no industrial operation is permitted to begin. The CTE shall be collected from the State Pollution Control Board (State Board) concerned, through section 25 of the Water Act (Pollution Prevention and Control Act, 1974). As a first step, and in compliance with Rule 32 of the Water (Pollution Prevention and Control) Rules 1975, a proposal for grant of CTE should be sent to the State Board in Form OG/XIII (ref Appendix I). Details relating to the position of the building, whether it is in a permitted industrial estate or private land or transformed ground, etc., must be furnished along with other documents relating to the possession or leased place, rented etc. Information relating to the manufacturing product, manufacturing process, raw materials used, water audit, waste produced, waste treatment operators i. Consent for Operate (CTO) The Authorization for Service (CTO) must be secured 45 days before the industrial Unit is commissioned. Once the unit has been created, the entrepreneur will submit to the Pollution Control Board concerned for authorization in prescribed forms along with respective documents mentioned below.

4.1 CTE & CTO Consent to establish Consent to Establish (NOC) is a an approval which is to be mandatorily attained from respective State Pollution Control Board before commencement of the construction or establishment activities on the site of the applicant. A CONSENT TO ESTABLISH FIRST STEP CONSENT TO ESTABLISH is the primary step towards establishment of an industry SECOND STEP Once CTE is received the applicant should apply for a consent to operate the establishment CONSENT TO OPERATE B Consent to operate Consent To Operate (CTO) is followed by the CTE. No business prescribed under the Water Act 1974 and Air Act 1981 shall begin its production activities before getting this consent or NOC

4.2 DOCUMENTS REQUIRED for Pollution Control Consent 1. Form I and Form XIII. (appendix I) 2. Project Report 3. Lease Agreement/Ownership Documents of the Property 4. Location Map 5. Site Plan / layout map for the Proposed Unit 6. EIA & EMP Reports (for industries listed in Schedule I of the EIA notification) 7. Details of Water Pollution, Air Pollution & Hazardous pollution and measures proposed to reduce/minimize/manage them 8. Details of Plant and Machinery 9. Detailed Process of Recycling 10. Audited balance sheet. 11. Environmental Statement affidavit on Rs.100 stamp paper. 12. Prescribed consent fee in the form of DD. 13. Copy of Executive Summary 14. Copy of EIA Report & Form I 15. TOPER Sheet Extract 16. Detailed Project Report 17. Clearance of High Level Committee (If EC is Applicable) The facility should be inspected by the SPCB and upon being satisfied, the CFO is issued. The unit is not permitted to operate till the CFO is issued

4.3 Conditions of issuance of Pollution Board Consent The facility should be inspected by the SPCB and upon being satisfied, the CTO is issued. The unit is not permitted to operate till the CTO is issued. iii. Authorization for Handling Hazardous Wastes E - waste was included as a form of waste in the 2008 changes to the Hazardous Wastes (Management and Management) Laws, because e - waste contains hazardous constituents. In addition to that, e - waste handling includes dangerous operations. Under these laws, by submitting the application form (Form-I) set out in Appendix III, all individuals managing e - waste are expected to obtain authorisation. iv. Registration as Recyclers The 2008 changes to the Hazardous Wastes (Management and Handling) Regulations have included e - waste as a waste type. All E - Waste recyclers shall be registered with the Central Pollution Control Board (CPCB) The category of e - waste is classified under the categories of toxic recyclable waste in Schedule IV of E-waste recycling regulations. Under these rules all those participating in e - waste recycling to go through the tedious registration procedure including those active in dismantling operations. Under the laws on hazardous waste as well as under the Basel Convention, e - waste has been classified as hazardous waste since it is known to contain various hazardous components such as cadmium , lead, asbestos, brominated flame retardants and polychlorinated bi-phenyls etc.

4.4 PROCESS for Pollution Control Board Consent STEP 1 Preparation of Applications in Forms I & XIII Submission of Application to be accompanied with requisite Consent Fee to Regional Office (RO) of jurisdiction STEP 2 Acknowledgement of Receipt of Application STEP 3 Application scrutinyand seeking clarification STEP 4 Site Inspection & Inspection Report STEP 5 STEP 6 Scrutiny by concerned/designated SPCB officer EIA report scrutiny by SPCB (Only for Projects Requiring Environment Clearance) STEP 7 Public Hearing (Only for Projects Requiring Environment Clearance) STEP 8 STEP 9 Technical Advisory Committee Review of Application Consent committee. Clearance Committee based on technical advisory STEP 10 Issue/Refusal of Consent based on Technical Advisory Committee and the following Documents STEP 11

5. HAZARDOUS WASTE AUTHORISATION As per the rule Hazardous And Other Wastes (Management and Transboundary Movement) Rules, 2015 “Hazardous waste” means any Waste that, due to characteristics such as physical, chemical, biological, reactive, radioactive, flammable, explosive or corrosive, cause hazard or is likely to cause a threat to health or the environment, whether alone or in contact with other waste or substances, and includes- (i) wastes defined in column (3) of Schedule I; (ii) wastes equal to or greater than the concentration limits; specified for components of Class A and Class B of Schedule II or any of the features defined in Class C of Schedule II; and (iii) wastes listed in Part A of Schedule III for the importation or exportation of certain wastes or wastes not defined in Part A but exhibit hazardous features specified in Part C of Schedule III; APPLICABILITY: Hazardous Waste Authorisation is applicable on the following: 1.Occupier Occupier' in relation to any factory or premises implies a person who has control over the factory or premises affairs and includes the person in possession of the hazardous or other waste in relation to any hazardous waste or other waste; 2. Importer ofHazardous Waste 3. Exporter of Hazardous waste For the management of hazardous and other wastes, an occupant shall take the following steps:- a) prevention; b) minimization; c) reuse; d) recycling; e) recovery, utilization of co-processing; f) safe disposal.

5.1 Grant of Hazardous Waste Authorisation Any 'Occupier' of the facility involved in the handling, generation, collection, storage, packaging, transportation, use, treatment, processing, recycling, recovery, pre- processing, co-processing, using, selling, transfer or disposal of hazardous and other waste shall be required to apply to the State Pollution Control Board and obtain an application in Form 1 within a period of sixty days from the date of publication of these rules. The applicant has to accompany the application with CTE (Consent to Establish) and CTO (Consent to Operate) of the organization while applying under this regulation Storage of hazardous and other wastes.- (a) the occupier of the facility can store hazardous and other wastes for a period not exceeding ninety days and keep records of selling, transfer, storage, recycling, recovery, pre-processing, co-processing and use of such wastes and make them available for inspection. Provided State pollution control board may extend the said period of 90days for particular cases mentioned in Hazardous And Other Wastes (Management and Transboundary Movement) Rules, 2015. DOCUMENTS REQUIRED: ✓ ✓ CIN(certificate of incorporation) Aadhar card of authorized person ✓ PAN copy of authorized person in case of company/LLP ✓ ✓ MOA GST certificate of Organisation ✓ ✓ AOA Rent/lease/ proof of ownership ✓ ✓ Board resolution for appointing Factory license/trade license ✓ Electricity bill an authorized person ✓ Layout/plan

5.2 PROCESS for hazardous waste authorisation STEP 1 Preparationof Applications in Forms I Submission of Application to be accompanied with requisite Consent Fee to Regional Office (RO) of jurisdiction STEP 2 STEP 3 Acknowledgement of Receipt of Application STEP 4 Application scrutiny and seeking clarification Site Inspection & Inspection Report followed by scrutiny by designated officer of the respected SPCB STEP 5 Issue/Refusal of Consent based on Inspection Report & Scrutiny STEP 6

6. Recycler Registration According to the E-Waste (Management) rules, 2016, An E-Waste recycler is a person or entity engaged in the business of recycling, reprocessing and / or recovery of electronic waste i.e. electrical & electronic equipments, components or assemblies. PRE-REQUISITES ✓ Suitable wastewater treatment equipments shall be installed ✓ Suitable air pollution control equipment shall be installed in the unit. ✓ The space of the plant shall be suitable to carry out manual dismantling (if applicable). ✓ Equipment to control or minimize Noise pollution shall be installed in the unit. ✓ The workers involved in the recycling process shall be properly equipped with safety gear or equipments. ✓ A valid agreement with TSDF operator shall be executed to ensure proper handling collection, storage and transportation of residues, floor cleaning dust and any hazardous material. SPACE REQUIREMENTS It is essential to understand the space requirements in order to establish a recycling plant. The preferred area requirements for setting up an E-Waste recycling Units shall be as follows: ✓ A recycling plant with a recycling capacity of 1 Metric Tonnes per day shall have a minimum area of 500 Sq. Mtrs. ✓ In a similar fashion a plant with a production capacity of 10 Metric Tonnes per day shall preferably have a minimum area of 5000 Sq. Mtrs.

7. ENVIRONMENT MONITORING AND COMPLIANCE “Guidelines for Environmentally Sound Management of E- waste” published by the Ministry of Environment and Forests specify in detailed guidelines, best practices and the requirements for establishment and operation of an e-waste recycling facility. These guidelines also provide the Best Available Technology and the Global scenario to facilitate the e-waste recycler to get an insight into the requisite system. Chapter 7 of these Guidelines state the requisite guidelines for handling e-waste, procedures for setting up and management of the e-waste recycling facility and the compliance requirements applicable under the existing regulations.

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Handbook on E-Waste Recycling