When TechNova Electronics, a fast-growing gadget manufacturer from Pune, decided to expand its product line, it proudly displayed its old EPR Authorization certificate from 2019 on every sales brochure. But during a supplier audit in 2024, a CPCB officer asked them to upload their EPR Registration Number instead.
That’s when confusion struck. TechNova had a valid authorization, yet the CPCB portal flagged their account as inactive. The team soon realized that India’s environmental compliance system had evolved — the old manual authorization was now replaced with a digital registration framework.
If you’ve faced a similar dilemma, you’re not alone. Let’s simplify what changed, why it matters, and how your business can avoid penalties.
Understanding the Shift: From Manual Authorizations to Digital Registrations
India’s e-waste regulation has matured dramatically over the past decade. Earlier, producers and importers were required to obtain EPR Authorizations from CPCB or SPCBs before selling electrical or electronic products. The process was largely manual, involving physical forms, signed EPR plans, and recycling tie-ups.
However, with the E-Waste (Management) Rules, 2022, effective April 1, 2023, the government shifted to a centralized online system known as the CPCB EPR Portal. This marks a complete digital transformation of the country’s compliance infrastructure.
The new regime introduces:
- A single national portal for all entities — producers, manufacturers, recyclers, and refurbishers.
- Automated EPR target calculations linked to product sales data.
- Digital issuance of EPR Certificates to track recycling credits.
- Faster processing and real-time monitoring, reducing human error.
This change brings transparency, efficiency, and accountability — three things that were missing in the older authorization framework.
What Was EPR Authorization (2016–2022)?
Before 2022, companies operating in electronics manufacturing, import, or retail had to obtain an EPR Authorization under the E-Waste (Management) Rules, 2016.
This approval confirmed that the applicant had an Extended Producer Responsibility (EPR) plan in place — detailing how they would collect, recycle, and dispose of electronic waste safely.
The process was entirely offline, and every new product line or expansion required re-submission of documents and approval from CPCB or the relevant State Pollution Control Board (SPCB).
Typical contents of an authorization application included:
- Company details, GST, and import codes.
- Detailed EPR plan outlining collection channels and recycling partners.
- Proof of agreements with recyclers or PROs (Producer Responsibility Organizations).
- Annual collection targets and awareness programs.
| Parameter | EPR Authorization (Old System) |
|---|---|
| Governing Law | E-Waste (Management) Rules, 2016 |
| Mode | Offline, document-based |
| Authority | CPCB / SPCB |
| Approval Type | Written “Authorization Letter” |
| Validity | 5 Years |
| Renewal | Manual resubmission |
| Monitoring | Self-reporting by email or letter |
| Limitations | No traceability, delays, and data duplication |
While this system ensured accountability, it lacked scalability and digital verification. As the electronics industry grew, CPCB found manual verification impractical — leading to the 2022 digital overhaul.
What Is EPR Registration (Under the 2022 Rules)?
The new EPR Registration system brings every compliance activity online through the CPCB EPR Portal (eprewastecpcb.in).
This is not just an application form — it’s a complete compliance ecosystem where producers register, recyclers upload recovery data, and CPCB automatically matches both to generate EPR Certificates.
Key features of the registration regime:
- One-time online registration with digital verification.
- Automated EPR target calculation based on sales figures.
- Integrated annual return filing and certificate tracking.
- Single login for producers, recyclers, and refurbishers.
- Instant alerts for pending renewals or returns.
| Parameter | EPR Registration (New System) |
|---|---|
| Law | E-Waste (Management) Rules, 2022 |
| Mode | Online (CPCB EPR Portal) |
| Covered Entities | Producer, Manufacturer, Recycler, Refurbisher |
| Processing Time | Within 30 working days |
| Validity | 5 Years |
| Renewal | Online, 120 days before expiry |
| Verification | Digital checklist + optional video inspection |
| Data Linkage | Auto-linked to EPR Certificates & Returns |
| Monitoring | Real-time by CPCB through portal dashboard |
This automated system improves traceability and reduces compliance costs while allowing CPCB to instantly identify inactive or non-compliant producers.
Key Differences Between Authorization and Registration
| Criteria | EPR Authorization (Old System) | EPR Registration (New System) |
|---|---|---|
| Framework | E-Waste Rules, 2016 | E-Waste Rules, 2022 |
| Application Type | Offline submission | Online digital form |
| EPR Plan Review | Manual | Automated based on data |
| Renewal | Manual after expiry | Online auto-renewal option |
| Coverage | Producers only | All entities (Producers, Manufacturers, Recyclers, Refurbishers) |
| Fees | Variable, manual payment | Structured fees ₹2,500 – ₹15,00,000 depending on waste targets |
| Verification | Field visits | Digital document verification |
| Tracking | None | Real-time dashboard and reporting |
| Transparency | Limited | 100% digital and auditable |
This transition ensures that every stakeholder in India’s e-waste ecosystem is registered, traceable, and accountable.
Migrating from Authorization to Registration
If your company previously had an EPR Authorization, you must migrate to the CPCB EPR Portal to continue compliance.
CPCB has clarified that no entity can file annual returns, generate EPR certificates, or conduct business without an active registration number.
Steps for Migration:
- Log in to the CPCB EPR Portal and select “Migration from Authorization.”
- Upload previous authorization copy, PAN, GST, and sales details.
- Pay a conversion fee of ₹10,000.
- Complete digital verification and receive your new Registration Certificate.
Once migrated, all future filings, targets, and certificate transactions are handled digitally.
Failure to migrate results in suspension of your authorization and the inability to generate EPR certificates — effectively halting your product operations.
What Happens If You Don’t Register?
Non-registration is treated as a violation under the Environment (Protection) Act, 1986. CPCB has the authority to:
- Suspend or revoke your registration.
- Block access to the EPR portal.
- Impose environmental compensation or fines.
- Publish a list of defaulting producers on its official website.
In severe cases, CPCB can also direct e-commerce platforms to delist non-compliant producers until they complete registration.
Business Impact of Non-Compliance:
- Immediate halt in sales due to missing EPR numbers.
- Reputational risk during B2B procurement audits.
- Ineligibility for EPR certificate trading or offsetting obligations.
- Loss of supply contracts with major retailers and brands.
Mini Case Study: How a Small Importer Recovered
A Delhi-based startup, SmartLoop Imports, held an EPR Authorization since 2019. In 2024, while submitting its annual return, the portal showed “Authorization Expired.”
The team applied for migration, paid the ₹10,000 fee, and uploaded sales data and recycler agreements. Within three weeks, CPCB issued a digital registration certificate, restoring their account and enabling certificate generation.
This quick transition not only saved them penalties but also gave them access to a streamlined compliance system that automatically tracks their annual targets.
CPCB Registration Fees for Producers
| Annual E-Waste Target (MT) | Registration Fee (₹) | Validity | Renewal Fee (₹) |
|---|---|---|---|
| Below 50 MT | 2,500 | 5 Years | 2,500 |
| 50 – 100 MT | 7,500 | 5 Years | 7,500 |
| 100 – 1,000 MT | 1,50,000 | 5 Years | 1,50,000 |
| 1,000 – 5,000 MT | 10,00,000 | 5 Years | 10,00,000 |
| Above 5,000 MT | 15,00,000 | 5 Years | 15,00,000 |
| Migration from Authorization | 10,000 (flat) | — | — |
| Annual Maintenance (all entities) | 5,000 per year | Ongoing | — |
Why the New System Benefits Businesses
While the earlier system focused purely on documentation, the new digital regime helps businesses in multiple ways:
- Faster approvals through automated verification.
- Reduced compliance cost by removing repeated inspections.
- Easier recordkeeping with centralized storage of certificates and reports.
- Improved credibility with verifiable registration details visible to buyers and authorities.
- Smoother audits since all records are linked to the online portal.
For large manufacturers, this also simplifies collaboration with recyclers — since all transactions now generate digital EPR credits directly on the platform.
Conclusion: Embrace the New Era of Digital Compliance
The shift from EPR Authorization to Registration represents a major modernization of India’s environmental compliance system.
By adopting the new CPCB portal early, businesses not only avoid penalties but also strengthen their sustainability credentials.
Green Permits helps producers, importers, and recyclers navigate this transition — from registration and migration to target tracking and annual returns.
📞 +91 78350 06182 | 📧 wecare@greenpermits.in
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FAQs
No, all authorizations issued before 2022 must be replaced with CPCB EPR registrations.
All producers, manufacturers, importers, recyclers, and refurbishers handling electronic products in India.
Five years, after which renewal can be completed online.
Your account will be deactivated, and you cannot submit annual returns or claim recycling credits.
Yes. An annual maintenance fee of ₹5,000 applies to all registered entities.
