Cerebra Integr. Management Discussions


As Indias e-waste problem grows, with 1.1 million tonnes of e-waste generated in 2019-20—just after China and the USA, the government has taken specific measures towards formalising the e-waste recycling space in the country. Replacing the E-Waste (Management) Rules, 2016—that made it compulsory for dismantling and recycling units to get authorisation from the concerned departments—are the E-Waste (Management) Rules, 2022, that kicked in from April 1, 2023.

The latest rules introduce the new Extended Producer Responsibility (EPR) regime that will apply to every manufacturer, producer, refurbisher, dismantler and recycler of electronic products, with the scope of products also being expanded.


OPPORTUNITIES: l New Rules from 1st April 2023 l Single largest growth oriented business segment– E-Waste Recycling l Coverage has increased from 30 products to almost 100 and virtually everything that runs on Electric or Electronic circuits has been covered. l Potential global partnerships for setup in India l Work with customers on providing end to end services in both areas l Association with big brands paving way to add other major brands who are not yet customers

THREATS: l Liability of past – without support have to bring in huge amounts of funds into the company l Sustaining enormous EBIDTA as promised to investors l Large corporate houses getting into the e waste space l Change of guard and thus exposure of past l Covid-19


As on 31stMarch 2023, the Company has focussed more on E-Waste Recycling EPR Business and has since reduced the refurbished business wherein it requires increased capital in acquiring assets from companies. It has its major business coming in from EPR [Extended Producer Responsibility] commitments for large consumer electric and electronic companies in India. It has in total recycled about 9200 Metric Tonnes of Waste Electronic and Electrical Equipments. Its looking at concentrating on its EPR business and also adding other consumer electrical &electronic large manufacturing companies into its ever growing list of clients. The internal reporting and performance of the Group is assessed by the Managing Director as E-Waste Recycling& Refurbishment segment.


India generated 3.1 million tonnes of E- Waste in 2021 and only around 10% of this E–Waste is collected by formal sector. Your Company has seen more opportunities and also has been signing up with more partnerships and agreements with large IT and Corporate India Companies. In India, refurbish and reuse is gathering pace and is reflected in about 12 million units of refurbished PC sales annually. The refurbished category is growing at 4X on a YoY basis. Credit pressures this time around could possibly be higher than the previous year, given the prolonged stress till date and the likelihood of limited fiscal or policy support in the absence of force majeure conditions like last time.


While Opportunities are huge, compliance is a major concern, Laws are becoming more stringent and Companies expectations are in tune with these compliances. Quality resources are hard to find for a business which is dealing with Recycling & Refurbishment. Your Companys risk management strategy encompasses in-depth identification, assessment and prioritization of risk followed by speedy mobilization of Quality resources to minimize, monitor and control the losses of unfortunate events.


Your Company has an adequate system of internal controls which commensurate with its size to ensure that all assets are safeguarded and protected against loss from unauthorized use or disposition. All the transactions are authorized, recorded and reported correctly.

The Companys internal control systems are further supplemented by an extensive programme of internal audit by a firm of Chartered Accountants and periodic review by the Management. The Internal Control system is designed to ensure that all financial and other records are reliable for preparing Financial Statements and for maintaining accountability of assets.



Employees continue to be the key for the continued success of any Organization. Industrial relations have been generally harmonious at the factory and offices. Sound human resource development policies of the Company ensure that each employee grows as an individual and contributes to the performance and growth of the Company. Regular in-house training programs to employees at all levels helpst o achieve this objective. While getting skilled manpower at some levels in the operations continues to be a challenge, employee turnover remained low during the year. The Company has satisfactory human resource department in place to address Human Resource challenges faced by the employees of the Company.

E-Waste Recycling Business:

Globally only 17.4% of Electronic Waste is documented to be collected and recycled properly thus realising 10 Billion $ worth of raw materials which can be used in remanufacturing of new products. India generated 3.1 million tonnes of E- Waste in 2021 and only around 10% of this E – Waste is collected by formal sector. In India, refurbish and reuse is gathering pace and is reflected in about 12 million units of refurbished PC sales annually. The refurbished category is growing at 4X on a YoY basis.

Government of India for the first time in the budget speech has acknowledged Circular Economy and its benefits. The increase in affluence during the last century, especially in the industrialized countries, have generated a linear economy and a consumer society. This growth came at the expense of resources, the environment and human health. Recently, moves towards a circular economy have shown the potential of decoupling growth from resource use, maintaining affluence and taking the environment, resources and health of people into account. A circular economy aims to maintain to value of products, components and materials throughout their entire lifecycles. The longer a product can retain its functionality, for example through repair or reuse, the higher value and environmental savings are obtained in the system. After a product reaches the end of its functional life, the reuse of components or parts (remanufacture) is preferred over recycling of it.

Your company has already embraced the idea of Circular Economy. It has been successful in employing repair, remanufacture, remarket and recycle processes thus enabling the extension of end of life products. By extending the end of life of a single PC, we can delay a carbon footprint of 422.5 KGs by couple of years. Your company has refurbished over 40,000 PCs during last financial year.

Your company has completed the third facility at Narsapura and obtained 40,000 MT capacity authorisation from Karnataka State Pollution Control

Board which is double the capacity of previous year.

Your company has partnered with large OEMs and worlds largest data storage company to collect the used/end of life assets from bulk consumers.

Your company has added four large OEMs as customers in the EPR business segment.


The division is focussed on devising and executing people strategies –building the right talent with cost effective measures like references, job posts on professional sites etc. We take every effort to motivate the team across the organization and to retain our star employees. We ensure that all our policies and practices are in alignment to our business objectives.

EPR has field executives, collection centres at different parts of country and MIS team in factory and branch offices in Bangalore as well as at Noida. We have a robust procurement team focused on procurement of IT and EPR products at PAN India level. The workforce in Refurbishment & Recycling divisions at factory consists of qualified operators and supervisors. We have skilled sales professionals engaged in sales and leasing of IT assets to end customers like individual buyers, institutions, corporates etc.

Enterprise Solutions Division

Your Companys focus has been reduced and is completing all AMC and other services taken up during the period. We have received work orders for

Automated Driving Testing System and the work is in progress.