Introduction

PRO stands for Producer Responsibility Organisation. These organisations are entrusted to perform the EPR responsibilities of the producer. Any entity that wishes to focus primarily on its business and doesn’t want to put in extra effort to fulfil its EPR targets, can engage any PRO and delegate the EPR responsibility to them.

The term “PRO” has been defined in Rule 3 (dd) of E-Waste Management Rules, 2016 as — “a professional enterprise authorised or hired, collectively or individually by producers’ manufacturers, which can take up the liability for collection and transportation of E-Waste generated from the end of life of their products to ensure environmentally sustainable management of such e-waste”.

Simply put PROs are the organisations which are delegated with the producer’s EPR responsibilities. It involves the collection, transportation and management of produced waste on behalf of the Producer or their manufacturer. In this article, we will discuss in detail everything about PROs and their authorisation.

Understanding PRO and Possible Structures

As stated above PROs are simply entrusted to perform the producer’s EPR obligations. As of now, there are more than 120 CPCB (Central Pollution Control Board) certified PROs who are actively working to fulfil the EPR obligations of the engaging enterprises.

As per the applicable rule, PROs can be established through three different structures or models, which are:

PRO as a private company
PRO as a not-for-profit organisation
PRO as a state run entity or authority

Role & Responsibilities of PROs

Various functions, roles and responsibilities of PROs are as follows:

Agreement: PRO are required to get into an agreement with the engaging entity and the agreement should clearly outline the key facts of the delegation.
Collection: PROs are required to execute a proper collection approach in order to effectively collect the waste.
BuyBack: PROs can also adopt any buyback policy to effectively take back the waste.
Handling & Managing: PROs should ensure that the collected waste is properly handled and transported for effective treatment or management that too in a sustainable and environment friendly way.
EPR Planning: One of the functions of PROs is to deliver an effective EPR management plan as specified by the Rules.
Awareness Programs: PROs should also organise regular programs for the general awareness of waste collection and segregation.
Setup Collection Centers: The PROs are also required to set up centres for the collection of the waste as per the guidelines issued by CPCB
Traceability: PROs should develop effective strategies to trace e-waste and end-of-life products to effectively tackle the collection and management problems.
Ensure Capacity: All the PROs shall ensure that they have enough resources and technology to effectively collect, store, transport and channelise the waste.
Quarterly & Annual Reports: As the EPR framework requires period filing and in case the EPR responsibilities are delegated then PROs are also required to be engaged in the reporting process.

Authorisation of PROs

Before working as a PRO, any organisation first needs to get an authorisation. The authorisation for PROs is managed by the CPCB. The detailed procedure to obtain authorisation from CPCB is as follows:

The full process is digital and can be done through the CPCB official website.
The application needs to be made in Form 1B along with the required declaration and undertaking.

Along with the application, you’re also required to give a detailed EPR plan which should contain comprehensive information about the collection process, channels, record keeping and reporting.

All information related to the organisation such as CIN number, GST no., PAN no. and other required details and documents should also be submitted.

Lastly the fees of Rs. 1 Lakh shall be paid to complete the application process.

If all the provided information is true and correct, then the authorisation will be issued within 60 days. If CPCB finds any objection or requires any clarification then it will issue you the notice within 30 days of filing and you should respond to the notice within the specified time.

Validity and Renewal

Once issued, the authorisation remains valid for 5 years. The authorisation needs to be renewed by applying at least 6 months before the date of expiry of the authorisation. Moreover, the authorisation will only be renewed if the organisation has satisfactory performance and has complied with all the applicable regulations in the past. If your renewal application is accepted after the appraisal of CPCB it may renew the authorisation for a further period of 5 years.

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Understanding PRO &amp; EPR

Shabana A

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