Extended Producer Responsibility for e-waste runs under the E-Waste (Management) Rules, 2022, in force since 1 April 2023, covering 106 categories of electrical and electronic equipment across seven schedules. Producers register on the CPCB e-waste portal and discharge year-wise recycling targets by buying portal-generated EPR certificates from registered recyclers.
The obligation has stepped up: the recycling target stands at 70 percent of estimated waste generation for FY 2025-26 and 2026-27, against 60 percent in the first two years, and reaches 80 percent from 2027-28. Certificate pricing sits inside a contested statutory band whose challenge by major manufacturers remains before the Delhi High Court.
Who registers and how the obligation is measured
Manufacturers, producers, refurbishers and recyclers must all register on the CPCB portal, and unregistered entities cannot lawfully operate. The producer’s obligation is computed from estimated waste generation: past sales deflated by the average product life of each item, not current-year sales.
| Obligation year | Target, share of estimated waste generation |
|---|---|
| FY 2023-24 and 2024-25 | 60% |
| FY 2025-26 and 2026-27 | 70% |
| FY 2027-28 onwards | 80% |
New producers carry 15 to 20 percent of recent sales, importers of used equipment carry 100 percent, and solar PV modules and cells register and store but carry no recycling target until 2034-35.
Certificates, the price band and the court case
EPR certificates are kilogram-denominated, generated by registered recyclers from verified end-product recovery, valid for around two years and traded through the portal, with CPCB’s electronic trading platform guidelines issued in January 2025.
The E-Waste (Management) Amendment Rules, 2024 banded the exchange price between 30 and 100 percent of the environmental compensation, which computes to a floor of roughly 22 INR per kilogram for most consumer electronics. Large manufacturers including air conditioning and appliance majors challenged the band before the Delhi High Court from late 2024; the Centre defended it, hearings ran through 2025, and a January 2026 interim order stayed enforcement against one petitioner. No final judgment has issued as of June 2026, and the band otherwise remains operative, so compliance planning prices certificates at the floor.
CPCB’s final environmental compensation guidelines under the e-waste rules followed on 25 August 2025, completing the shortfall side of the regime.
Refurbishing, RoHS and the moving parts
A registered refurbisher generates refurbishing certificates that defer the producer’s EPR obligation for the extended product life, a lever for brands with strong service networks. RoHS limits under rule 16 cap lead, mercury, hexavalent chromium and brominated flame retardants at 0.1 percent and cadmium at 0.01 percent; the exemption for imported parts and spares lapsed on 1 April 2025, while specific Schedule IIC equipment parts stay exempt until 2028.
What producers should do for 2026-27
- Recompute the obligation at the 70 percent target from estimated waste generation, item by item.
- Contract certificates early at floor-anchored prices rather than year-end spot.
- Track the Delhi High Court matter; a final judgment either way changes certificate economics overnight.
- Audit RoHS files now that the imported spares exemption has lapsed.
- File returns on time with recovery documentation that matches the recycler’s certificate trail.
E-waste EPR questions, answered
What is the e-waste recycling target for 2025-26?
Producers must recycle 70 percent of estimated waste generation for FY 2025-26 and 2026-27, up from 60 percent in the first two years of the 2022 Rules, rising to 80 percent from FY 2027-28. The base is past sales deflated by average product life, not current sales.
How much does an e-waste EPR certificate cost?
Pricing is banded between 30 and 100 percent of the environmental compensation under the March 2024 amendment, a floor of roughly 22 INR per kilogram for most consumer electronics. The band is under challenge before the Delhi High Court with no final judgment as of June 2026, so it remains the operative planning basis.
Who must register on the CPCB e-waste portal?
Manufacturers, producers, refurbishers and recyclers of the 106 covered equipment categories all register on the portal. Unregistered entities cannot operate, and every certificate, return and obligation runs through the portal records.
Does refurbishing reduce the EPR obligation?
Yes, by deferral. A registered refurbisher generates refurbishing certificates that push the producer's obligation out by the extended product life, which rewards brands that run genuine repair and refurbishment channels.
Do solar panels carry e-waste recycling targets?
Not yet. Solar PV modules and cells must register and store their waste under the 2022 Rules, but carry no recycling target until 2034-35, when obligations begin against the installed base.
What are the RoHS limits under the 2022 Rules?
Lead, mercury, hexavalent chromium and the brominated flame retardants PBB and PBDE are capped at 0.1 percent by weight in homogeneous materials, and cadmium at 0.01 percent. The exemption for imported parts and spares lapsed on 1 April 2025, so import files need the same evidence as domestic production.
GreenSutra manages e-waste EPR end to end, from portal registration and obligation computation to certificate sourcing and audit ready returns, through dedicated EPR registration and compliance solutions.
