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Under the E-Waste Management Rules 2016, these are the following definitions:

Bulk Consumers

Bulk users of electrical and electronic equipment such as Central Government or State Government Departments, public sector undertakings, banks, educational institutions, multinational organizations, international agencies, partnership and public or private companies that are registered under the Factories Act, 1948 (63 of 1948) and the Companies Act, 2013 (18 of 2013) and health care facilities which have turnover of more than one crore or have more than twenty employees.

Producer (manufacturer, distributor, importer)

  • Manufactures and offers to sell electrical and electronic equipment and their components or consumables or parts or spares under its own brand
  • Sells under its own brand, assembled electrical and electronic equipment and their components or consumables or parts or spares produced by other manufacturers or suppliers
  • Offers to sell imported electrical and electronic equipment and their components or consumables or parts or spares


Any person who is engaged in recycling and reprocessing of waste electrical and electronic equipment or assemblies or their components and having facilities as elaborated in the guidelines of Central Pollution Control Board.

Producers Responsibility Organization (PRO)

A professional organization authorized or financed collectively or individually by producers, which can take the responsibility for collection and channelization of e-waste generated from the ‘end-of-life’ of their products to ensure environmentally sound management of such e-waste.

PRO acts as a bridge between the bulk consumer and the recycler. It collects material from bulk consumers/consumers and channelizes it to authorized dismantlers/recyclers on behalf of the producers.



Material Flow (Blue)

Electronic and electrical waste is sold/donated as scrap by consumers of electronic products such as corporates and individuals. This material is collected through our extensive logistic and operations network enabling us smooth collection from corporates and households across the country. Moreover, we have also launched over 15 collection/drop-off points in the country where consumers can drop off their old electronics. Material further flows from producers i.e., manufactures, importers and distributors as scrap to the PRO.

This material once collected by the PRO i.e., Hulladek Recycling is segregated and stored in the warehouse. It is further transported to licensed recyclers and dismantlers of electronic products that resort to environmentally sound methods of disposal.

Certification Flow (Yellow)

Once the material is safely disposed in 45-60 days, the recycler issues a certificate of recycling as proof of disposal. This certificate is further shared with producers as proof of material channelized. This certification helps them fulfill their compliances. These documents are often shared with bulk consumers as a part of their CSR (Corporate Social Responsibility) obligation.

Financial Flow (Orange)

The material collected by bulk consumers/consumers is often sold to the PRO as scrap. This material is further sold off to recyclers based on the current value of raw materials present in the item(s). As a PRO, is channelizing this waste on behalf of the producers, these producers pay a consultation fee to the PRO for their services.