FAQs on e-waste Disposal

FAQs FOR ELCITA MEMBERS:  DISPOSAL

a)      I need to dispose few tube light, bulbs, CFL’s etc. what do I do?

Contact ELCITA office and take their help in disposal of these. Depending upon the quantity, ELCITA may either ask you to deposit these items to their collection centers or may request the recycler to collect it from your end. There may be a cost associated to this, which the ELCITA Member may be required to pay.

 

b)      My company generates on a very small quantity or e-waste, do I need to audit a recycler?

ELCITA will be auditing some recyclers across Bangalore and would recommend you to use one of them for your disposals. ELCITA will not be involved in the commercials.

 

c)       Am I classified as a Producer or Manufacturer?

Current rule does not differentiate between Producer and Manufacturer.

The recently released draft rules differentiate between Producers and Manufacturer.

 

Producers means any person who, irrespective of their selling technique, manufactures and offers to sell electrical and electronic equipment under its own brand name OR offer to sell under its own Brand name assembled electrical and electronic equipment produced by other manufacturers or suppliers OR offers to sell imported electrical and electronic equipment.

Manufacturers means a person or an entity or a company as in the companies Act 2013 (18 or 2013), of a factory as in Factories Act 1948 (63 or 148) which has facilities for manufacturer or electrical and electronic equipment (EEE).

 

d)      If I am a manufacturer of EEE, is my production waste also part of e-waste?

YES, as per the rules, “Collection of e-waste generated during the manufacture of any electrical and electronic equipment and channelizing it for recycling or disposal”

 

e)      How do I choose a recycler? I don’t have the resources to do audit and follow up with the recyclers?

ELCITA will be auditing some recyclers across Bangalore and would recommend you to use one of them for your disposals. ELCITA will not be involved in the commercials.

 

f)       What do I need to check for in the collection Center, dismantler or recycler?

  • They should have all the required approvals from the State Pollution Control Board and should be current and not expired.
  • You should ask them to get the Registration or Passbook issued to them by the SPCB in original.
  • You should ask them to fill in the quantity of material they pick up from your facility; you should sign it, stamp it and take a copy of the same from them as your records.
  • You should ask them to give you a breakdown of material that they have recovered from their products. E.g. if you give them one desktop, how much steel, aluminum, copper, PCB, plastics etc. did the recycler get from it?
  • You have the right to ask them what they have done with the commodities they recovered? For example, who has purchased the commodities and what will they do with the materials?
  • You could ask them to give you a certificate of recycling or certificate of destruction.

 

g)      What are the requirements for the transport of e-waste?

If your recycler is not from Karnataka, you have to ask them as to how will the e-waste be collected and moved? Is it their own trucks/ tempos or hired? Do they have approvals to ply the vehicles carrying e-waste interstate?

 

h)      I am a Small / Medium sized IT company, do I need to follow these Rules? Can I not continue giving this to the scrap dealer who gives me the best return for my EOL products compared to the recycler?

NO you have to give it only to the Government Approved collection centers, dismantlers or recycler; Government has a Mandate for each industry with the exception of 3 to follow these Rules.

 

i)        Some additional Government approved recycler have approached my company and are willing to give me a better price and service compared to the recycler approved by ELCITA, can I use them?

ELCITA would recommend you to use their audited and approved recyclers only. The approval of these recyclers would have been done by proper due diligence, auditing the capability, capacity and their ability to handle variety of e-waste before they recommending them.

You are free to use any recycler you wish to use. If possible, ask the recycler to approach ELCITA for them to audit this recycler and if found worthy would not hesitate to add them to the list of approved recyclers. There would be a cost associated with the auditing of the recycler that the recycler will have to bear.

 

j)        A recycler approached me and said he could help me in de-bonding the goods for me; can I give him the responsibility of this?

The recycler can only facilitate, the import data, the FOB value, the bond register, the re-warehousing certificate, de-bong duty calculations have to be all initiated by you as you were the Importer of the items.

 

k)      The recycler is not willing to pick up small quantity of e-waste from my facility, what do I do?

You need to contact ELCITA and they can help you facilitate the disposal of your small quantity of e-waste. There may be NIL cost or a small cost involved in this.

 

For more information about any of the issues contained in this section, please contact Subha Niranjan:

Email: admin@elcita.in

Telephone: 080-4660 2222

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