Extended Producer Responsibility · Data Centres & IT Parks
EPR Registration for Data Centre E-Waste and Battery Obligations
Server and UPS battery refresh cycles bring a data centre or IT park operator squarely inside the E-Waste (Management) Rules 2022 and the Battery Waste Management Rules 2022, as a bulk consumer and, where equipment is imported directly, as a producer with EPR obligations.
Screening view on your project, with the category and route named. No obligation.
What this means for data centres & it parks
The E-Waste (Management) Rules 2022 place obligations on producers, manufacturers, refurbishers and recyclers through an EPR framework administered on the CPCB portal, and separate duties on bulk consumers to channel end-of-life equipment only to registered recyclers or refurbishers and to maintain records and file returns. IT and telecommunication equipment (servers, storage, switches, routers) is squarely within the covered categories. The Battery Waste Management Rules 2022 apply a parallel EPR regime to batteries, which matters here because UPS strings, whether valve-regulated lead-acid or lithium-ion, are replaced on a predictable cycle and in substantial quantity. Where an operator imports its own equipment rather than buying through an Indian supplier, it takes on the producer's registration and EPR target rather than merely the bulk consumer's record-keeping duty, and that distinction is frequently missed.
How KIPL runs it
KIPL establishes which capacity the operator occupies for each stream (producer, importer or bulk consumer) and then puts the registration, targets and returns in place accordingly, with the physical channelisation to match. In practice the difficulties in this sector are the volume and the timing: a hall's refresh releases a large quantity in a short window, the equipment carries data that security policy requires to be destroyed before it leaves site, and the operator's own procurement often crosses the import line without the compliance team noticing. We set up the storage, data-sanitisation sequence, registered-recycler engagement and documentation so that the disposal event is routine, and align the resulting figures with the ESG disclosure the operator makes to its tenants.
- E-Waste Rules 2022
Refresh cycles generate covered waste
Servers, storage and network equipment fall in the covered categories, and a bulk consumer must channel them only to registered recyclers or refurbishers, with records and returns.
- Battery Waste Rules 2022
UPS strings are a separate regime
Lead-acid and lithium-ion UPS batteries are covered by their own EPR rules, with distinct registration, collection and reporting obligations from e-waste.
- Import route
Importing equipment makes you a producer
An operator importing its own IT equipment or batteries takes on producer registration and EPR targets, not merely bulk-consumer record-keeping.
What you receive
Written for data centres & it parks, not adapted from a template.
- 01Determination of status per stream (producer, importer or bulk consumer) under each set of rules
- 02EPR registration on the CPCB portal with the applicable target and category mapping
- 03Channelisation arrangements with registered recyclers and refurbishers, with due diligence on their registration
- 04Data-sanitisation and secure-disposal sequence aligned with the operator's information security policy
- 05Record formats and filing calendar for the prescribed returns
- 06Reconciled quantities for tenant and investor ESG disclosure
Questions from data centres & it parks
What data centres & it parks ask before appointing us.
Answered against the regulation as it stands, not as a sales pitch. If your situation is not here, ask us directly.
Ask a question →Is a data centre operator a producer or a bulk consumer under the E-Waste Rules?
It depends on how the equipment enters India. An operator that buys from an Indian supplier is generally a bulk consumer, with duties to channel end-of-life equipment to registered recyclers or refurbishers and keep records. An operator that imports servers or batteries directly falls within the producer definition and carries registration and EPR targets. Many operators do both, through different procurement routes, and need to be assessed stream by stream.
How do data security requirements fit with lawful disposal?
They have to be sequenced, not traded off. Drives are sanitised or physically destroyed under the operator's own policy before the equipment leaves site, and the recycler receives documented material afterwards. Building the sanitisation step into the disposal procedure prevents the common outcome where retired equipment accumulates in a secure store for years because nobody will authorise its release.
Are UPS batteries covered by the E-Waste Rules?
Batteries are governed by the Battery Waste Management Rules 2022, a separate regime with its own registration, EPR obligations and reporting. A campus therefore runs two compliance streams, e-waste for IT equipment and battery waste for the UPS strings: and satisfying one does not satisfy the other.
What records must be kept?
Broadly, quantities of equipment and batteries taken out of service, the registered recycler or refurbisher to whom they were sent, the transfer documentation, and the returns prescribed under the respective rules and filed on the CPCB portal. These records are also what an ESG disclosure on waste diversion rests on, so a single register serves both purposes.
What is the risk of using an unregistered recycler?
The obligation is to channel to entities registered under the rules; handing equipment to an unregistered dismantler does not discharge it, and the operator remains exposed even though the material has left the premises. Verifying registration status at the outset, and again periodically, is a small step that prevents an avoidable enforcement exposure and a reputational one with tenants.
Does an IT park landlord have obligations for tenant e-waste?
The generator's obligations rest with the tenant for its own equipment, but the landlord's own building systems, common-area IT and UPS installations are its own responsibility. Where the landlord provides a collection or storage facility for tenants, that arrangement needs to be structured so the landlord is not informally taking on handling duties it is not registered for.
Stage by stage
How extended producer responsibility actually runs, step by step.
Also for data centres & it parks
The rest of the environmental brief for this sector.
Primary sources
Verify any of this at the source.
Relevant proof
EIA for Synthetic Organic Chemical Industry
CTE/CTO application, ToR application, baseline data collection, EIA report and appraisal before the EAC: Category 5(f), the sector KIPL holds Category A accreditation in.
- Capacity
- 20 → 140 TPM
- 5(f) accredited
- Cat A
Where we do this
Extended Producer Responsibility for data centres & it parks, city by city.
Other sectors
Who else we run extended producer responsibility for.
Next step
Tell us the project, and we will tell you the category and the route.
Screening is the cheapest stage to get right and the most expensive to get wrong. We will say plainly what extended producer responsibility your data centres & it parks project needs, and what it does not.
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