Guidelines on E-waste

GENERAL REQUIREMENTS

Requirement in Benchmarking Scores

GOVERNANCE

ELICTA encourage all member companies to establish and maintain appropriate governance frameworks and reviews of their e-Waste management activities

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EXPENSE

ELCITA encourages all member companies to acknowledge that in some instances they may incur monetary expenses in the effective management of e-Waste within their premises.

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The extent of their expenditure will be based on their estimated volumes and nature of e-Waste, and the respective costs of environmentally sound recycling or other disposal of their product types.

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TARGETS

ELICTA encourages all member companies to establish internal targets for the Refurbishment or Recycling of e-Waste.

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The extent of these targets should be determined in the first instance with respect to achieving the maximum level of product Re-use or Resale or resource recovery from Recycling. 

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They should also be established with respect to the company’s size, and the volume and nature of e-Waste generated.

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ELCITA all encourages member companies to establish:

• Regular reporting and review of these targets internally, and

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• Programs aimed at increasing the volume of product being Resold, Refurbished or Recycled on a yearly basis.

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ELCITA all encourage companies to establish internal targets for their expectations of resource recovery by the Recyclers for different product types.

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LEGAL COMPLIANCE

ELCITA recommends member companies:

• Comply with local, regional, national and international legislation as they apply to their operations including the the existing E-Waste (Management and Handling) Rules 2011, and recently released draft E-Waste (Management) Rules, 2015 and

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• Maintain current records of all necessary legal permits, licenses and other legally required documentation from their partners in the EOL e-Waste process as assurance that these Partners have complied with their requirements.

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ELCITA encourages all member companies to ensure the Recyclers, Refurbishers, Transporters and other providers (collectively, referred to as the Operators) used in the delivery of their e-Waste Management Services:

• Be subject to external audit of their compliance with the applicable laws and regulations

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• Be able to demonstrate that they have implemented management structures to ensure that they stay up to date with the applicable laws and regulations

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• Maintain Environmental, Health and Safety Management Systems, appropriate to the size and nature of their operations, and provide adequate training to their staff in relation to these systems

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• Maintain compliance with International and local India Labour standards including providing fair pay, safe operating conditions, and a work place that has an absence of discrimination

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• Maintain appropriate insurances to the extent available to cover damages to third parties related to environmental issues, impacts to the health of their staff, damages to property, and for the proper closure and clean-up of the operational site as relevant to them.

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RESELLER, REFURBISHMENT and RECYCLER ENGAGEMENT

ELCITA recommend all member companies utilize Recycling partners who are approved by the approved by the Central Pollution Control Board (CPCB), the Karnataka State Pollution Control Board (KSPCB), or other State Pollution Control Boards.

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ELCITA encourages member companies to acknowledge that responsibility for the appropriate end of life management of their products rests with themselves and that engagement of Approved Recyclers does not discharge this responsibility.

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ELCITA encourages all member companies to actively manage the disposition of their products with their Recycling, Resellers, and Refurbishment partners to ensure that they are being appropriately treated.

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This management of the partners requires activities including ensuring that they are:

• Responsible for activities throughout the downstream supply chain

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• Performing their own due diligence and be accountable for all downstream flow of e-Waste including its final disposal

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• Documenting their activities including incoming and outgoing flows of collected e-Waste and its components

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• Maintaining proof of compliance through invoices, certificates, and other confirmations as necessary, and that they have targets in relation to their performance on these activities, and reporting against these

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OPERATIONAL REQUIREMENTS

Requirement in Benchmarking Scores

COLLECTION

ELCITA encourages companies to ensure collection of e-Waste be performed in a manner which helps to prevent pollution due to breakage, leakage or corrosion.

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The availability and location of collection sites should be well advertised to maximize the likelihood of collections.  To the extent possible these collection sites should be located in close proximity to the users.

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STORAGE

ELCITA encourages companies to consider storage sites for e-Waste which are:

• Separated and stored by type to ensure each type is handled in a manner which will prevent damage or loss, and

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• Equipped and maintained in a manner which prevents pollution, and other hazards due to damage, leakage and corrosion, or from inflammable components

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To the extent practical and appropriate these storage sites should be sealed, or otherwise provide protection from the weather for the products

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ELCITA encourages companies not to store products for longer than 6 months, given the risks of damage or loss.

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DATA SECURITY

ELCITA encourages companies to ensure that they take primary responsibility to ensure that sensitive data is appropriately erased from IT equipment prior to its disposal with Recyclers, Resellers, or Refurbishers.

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Companies should also require Operators involved in the refurbishment or resale of equipment and ensure appropriate data erasure processes are applied to minimize data security risks.

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REUSE OF EQUIPMENT

ELCITA encourages all member companies to ensure that any product designated for re-use be sufficiently functional to ensure that its life can be meaningfully extended.

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In addition the member companies should seek evidence from the Resellers that the equipment has been resold and not in fact otherwise inappropriately disposed off.

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TRANSPORT

ELCITA encourages companies to work with Transporters of the product to ensure that:

• e-Waste is transported in a manner that enables maximum reuse, recycling and resource recovery, and prevents pollution

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• Special precautions are considered when dealing with hazardous substances including Compact Fluorescent lamps

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• Staff are trained in the safe handling of the product

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ELCITA encourages all companies to ensure that their Transporters, or the other Operators transporting product comply with the Federal and State requirements across India.

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ELICTA encourages companies to ensure that they or the Operators they engage maintain compliance with the Basel Convention 1989 on the international trans-boundary movement of waste.  

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RECYCLING

ELCITA recommend all member companies utilize Recycling partners who are approved by the approved by the Central Pollution Control Board (CPCB), the Karnataka State Pollution Control Board (KSPCB), or other State Pollution Control Boards.

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ELCITA encourages all member companies to ensure that the Recyclers they are engaging:

• Adopt the protocols and agreed operating procedures recommended by the member companies

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• Adopt resource recovery methods that use the best available technologies

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• Remove the hazardous materials and components from the waste stream and the effective treatment of these materials in order to prevent pollution in their daily operations

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• Manage the downstream treatment of hazardous materials be conducted in a manner which best prevents adverse impacts to the environment, and ensures material recovery where possible, and

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• Use incineration, and landfilling of recyclable materials only after the reuse, refurbishment, recycling and other material recovery options have been exhausted

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ELCITA also encourages member companies to audit their Recycling Partners on a periodic basis to ensure compliance with agreed operating procedures, and to confirm that they all required licenses and permits relevant to their operation.

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