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Overview of EPR Fulfilment in Plastic Waste Management

Plastic was invented in 1907, and because it was less expensive and more convenient than other materials, it quickly found use in a variety of applications in our daily lives. Today, plastic is present in almost everything, from our money to electronic appliances, and it is used across multiple sectors, including packaging, building, construction, transportation, industrial machinery, and health, among others.

The Plastic Waste Management Rules mandate the generators of plastic waste take steps to minimize the generation of plastic waste, not to litter the plastic waste, ensure segregated storage of waste at source, and hand over segregated waste to local bodies or agencies authorized by the local bodies. The rules also mandate the responsibilities of local bodies, gram panchayats, waste generators, retailers, and street vendors to manage plastic waste.

Producers, importers, and brand owners bear extended producer responsibility (EPR) for the collection and recycling of plastic packaging waste. EPR will apply to both pre- and post-consumer plastic packaging waste.

Obligated Entities under EPR Fulfilment in Plastic Waste Management

  • Producers (P) and Importers (I) of all imported plastic packaging and/or plastic packaging of imported products.
  • Brand Owners (BO) include marketplaces/online platforms and supermarkets/retail chains other than those that are micro and small enterprises, according to the Ministry of Micro, Small and Medium Enterprises, Government of India.
  • Plastic Waste Processors (PWPs), except cement kilns and road construction.

Annual Return in EPR Fulfilment in Plastic Waste Management

The Plastic waste processors shall submit annual returns after the end of every financial year by 30 April of the next financial year on the quantity of plastic waste processed category-wise and state-wise as per prescribed pro forma on the centralized portal developed by CPCB. The total quantity of plastic waste processed by plastic waste processors and attributed to PIBOs on an annual basis will be made available on the centralized portal developed by CPCB as well as on the website of Plastic waste processors.

In case, at any stage, it is found that the information provided by the plastic waste processor is false, the plastic waste processor shall be debarred by SPCB, as per procedure laid down by CPCB, from operating under the EPR framework for a period of five years.

Plastic Packaging Waste Collection System by PIBOs

PIBOs, while fulfilling their EPR obligations, may encourage the development, collection, and segregation infrastructure of plastic packaging waste, as needed, based on the category of plastics. It may include the following based on the implementation modality of EPR adopted by PIBO:

  • Set up waste plastic collection points as well as Material Recovery Facilities (MRFs).
  • Ensure that plastic packaging waste is collected from collection points on a regular basis proportionate to the area covered and the volume.
  • Offer plastic collection from entities such as Urban Local Bodies, gram panchayats, any other public authorities, or third parties involved in waste management, and provide for collection from all entities that have taken advantage of that offer; make the necessary practical arrangements for collection and transportation.
  • Ensure that the plastic packaging waste collected from the collection points is subsequently subject to recycling in a registered facility by a recycler or its permitted end use in the designated manner.

PIBOs ensures that the network of collection points is not limited to areas where collection and subsequent management is profitable, taking into account the size of the population, expected volume of plastic/packaging waste, accessibility, and proximity to end-users. Waste collection companies will deliver waste to designated end uses or for recycling and treatment. Participation of voluntary collection points, who will be handing over plastic packaging waste to PIBOs or third-party agencies acting on their behalf for treatment and recycling or end-use identification.

EPR Fulfilment in Plastic Waste Management

When filing annual returns on the online portal, the PIBOs must provide the details of the recycling certificate only from recyclers that are registered, as well as the quantity sent for end-of-life disposal, by 30 April of the following fiscal year. The online portal will cross-check the information provided by PIBOs and registered plastic waste processors. In the event of a discrepancy, the lower figure would be applied toward PIBO's EPR obligation. The certificates shall be subject to verification by CPCB/SPCB/PCC, as the case may be.

Documents Required under EPR fulfilment in Plastic Waste Management

  • Legal Name (As per GST)
  • Trade Name (As per GST)
  • Type of Business (Private/Public/ Proprietorship/ Co-operative etc)
  • Type of Company (Micro/ Small / Medium/large) and Supporting Document
  • Registered Address of the entity
  • Company PAN Card Number (validated on the Portal)
  • Company CIN Number (Necessary for registered companies under the Company Act and validated on the Portal)
  • Name & Designation of Authorized Person
  • Mobile Number of Authorized Person
  • PAN Details of Authorized person
  • Aadhaar details of Authorized person (optional)

Challenges under EPR Fulfilment in Plastic Waste Management

The adverse impacts of plastic have created an alarming situation everywhere, with a call for countries to make commitments against plastic pollution. Some of the challenges under EPR fulfilment in Plastic Waste Management are:

Limited Separation and Recycling Activities

There are limited separation and recycling activities at the source (particularly at the household level). Recovery is mostly applied to high-value plastics but is still largely informal-led (e.g., waste pickers who go house to house to collect recyclable wastes), leaving a sizable volume of high-value recyclable packaging ending up in disposal sites or leaking to the environment.

A Limited Number of Recycling Facilities

Despite the large volume of high-value recyclable plastics, they often end up not being recycled due to the limited number of recycling facilities, which are mostly concentrated in the central parts of the country. Coupled with the low recovery rates, some large recyclers and aggregators end up importing plastics to process.

High Volume of Low-Value Plastics and Non-Recyclables

There is a high volume of low-value plastics and non-recyclables (e.g., flexible films, sachets, composites), which are hard to collect as one needs to spend a long time to reach the minimum weight and buy at a low price. Recycling sachets also requires new equipment for processing. These scenarios lead to these sachets ending up in disposal sites or leaking into the environment.

Benefits under EPR Fulfilment in Plastic Waste Management

Extended Producer Responsibility (EPR) fulfillment in plastic waste management offers several significant benefits, contributing to a more sustainable and environmentally responsible approach to handling plastic waste. Some of the benefits of EPR fulfilment in Plastic Waste Management are:

Promotion of Recycling

EPR encourages the development of efficient recycling processes. Producers, motivated by their responsibilities, invest in recycling technologies and infrastructure. This results in more plastics being recycled, reducing the demand for new plastic production and conserving resources.

Job Creation

The establishment and maintenance of recycling facilities and collection systems under EPR programs create employment opportunities. Recycling initiatives generate jobs in waste collection, sorting, processing, and related sectors, thereby supporting the local economy.

Reduction in Plastic Pollution

EPR programs ensure proper collection, recycling, and disposal of plastic products. By holding producers responsible, there is a significant reduction in plastic pollution in natural habitats, such as oceans, rivers, and forests, leading to a cleaner environment.

Steps to be Followed under EPR Fulfilment in Plastic Waste Management

Since EPR fulfilment in Plastic Waste Management requires a lot of steps and paper works, it would not be easy for an individual to do it. These involve:

  • Registration on a centralized portal developed by CPCB
  • Determination of EPR targets by PIBOs
  • Obligation for Recycling
  • End-of-life product disposal
  • Obligation for Use of recycled plastic content
  • Obligation for Reuse (only in case of brand owner)
  • Fulfilment of Extended Producer Responsibility (EPR) Obligations
  • Filing of yearly returns by processors of plastic waste and producers, importers, and brand owners
  • Submission of the Annual Report by SPCB/PCC on EPR portal regarding fulfilment of EPR by PIBOs and PWPs to CPCB

Navigation through Plastic Waste Rules:

  • 1998 - Recycled Plastics Usage Rules, 1998
  • 1999 - The Plastics Manufacture, Sale and Usage Rules, 1999
  • 2003 - Recycled Plastics Manufacture and Usage (Amendments) Rules, 2003
  • 2009 - Draft Plastics (Manufacture, Usage and Waste Management) Rules, 2009
  • 2011 - Plastic Waste (Management and Handling) Rules, 2011
  • 2016 - Plastic Waste Management Rules, 2016
  • 2018 - Plastic Waste Management (amendment) rules, 2018
  • AUGUST 2021 - Plastic Waste Management (Amendment) Rules, 2021
  • SEPTEMBER 2021 - Plastic Waste Management (Second Amendment) Rules, 2021
  • FEBRUARY 2022 - Plastic Waste Management (Amendment) Rules, 2022

Role of Producer, Importer, Brand Owners under EPR fulfilment in Plastic Waste Management

  • It will be necessary for the PIBOs to register via the Central Pollution Control Board's online centralized portal. The certificate of registration shall be issued using the portal.
  • PIBOs shall provide an Action Plan containing information on the EPR Target, category-wise, where applicable, through the online centralized portal developed by CPCB, along with the application for registration or renewal of registration under PWM Rules, 2016.
  • Brand Owner shall provide details of plastic packaging purchased from Producers and/or Importers separately. The quantities attributed to each Producer and Importer covered obligated upon the Brand Owner shall be deducted from the obligation of Producers and Importers.
  • The Producers and Importers will maintain a record of the quantity of plastic packaging material made available to the Brand.
  • The Producers, Importers, and Brand-Owners shall file annual returns on the plastic packaging waste collected and processed towards fulfilling obligations under Extended Producer Responsibility with the Central Pollution Control Board or concerned State Pollution Control Board or Pollution Control Committee as per pro forma prescribed by the Central Pollution Control Board by the 30th of June of the next financial year.

Categories of Plastic under EPR Fulfilment in Plastic Waste Management

Different types of plastics possess different characteristics. According to Plastic Waste Management Rules, 2016, there are seven categories of plastics on the basis of their recyclability:

SL NO.

Category

1

Polyethylene Terephalate (PET)

2

High-Density Polyethylene (HDPE)

3

Poly Vinyl Chloride (PVC)

4

Low-density polyethylene (LDPE)

5

Polypropylene (PP)

6

Polystyrene resins (PS)

7

Multi-materials like Acrylonitrile butadiene styrene, poly-phenylene oxide, polycarbonate, Polybutylene terephthalate

How Can Corpbiz Assist You?

Corpbiz takes pride in being your partner for hassle-free EPR (Extended Producer Responsibility) and Registration services. Our dedicated team specializes in demystifying the registration process, assisting your business every step of the way.

We at Corpbiz also assist you by providing the following:

Expert Consultation and Management of the Online EPR Portal and Annual Filing

Consultation with the experts for EPR Fulfilment in Plastic Waste Management. You need to provide information about your yearly sales, purchases, and recycling to us for the Central Pollution Control Board's online EPR Portal. Corpbiz oversees the management of your EPR Portal and makes sure that annual returns are filed on time as needed.

Documentation

Our team warrants hassle-free paper works. We ensure to collect the Documents and share the relevant drafts to ensure timely filing and delivery.

One-Stop Solution

Let us become your One-stop Solution platform to manage all your EPR fulfillment; from decoding the eligibilities to paper works and to filing timely reports and plans, we will take care of everything for you.

Real-time Updates

Throughout the process, our team will be there to provide you with assistance. You can also easily keep track of everything through our platform and interface and stay abreast of everything.

Frequently Asked Questions

EPR is a policy approach in which manufacturers are held responsible for the disposal or recycling of the products they produce, especially plastics, once they reach the end of their life cycle.

EPR is important as it encourages producers to design products that are easier to recycle, reduce plastic usage, and manage their products' entire life cycle, thereby minimizing environmental impact.

Producers establish recycling programs, contribute to collection infrastructure, and ensure proper disposal of their products. They may collaborate with recycling facilities or local governments to fulfil their EPR obligations.

EPR promotes recycling, reduces plastic pollution, conserves resources, and encourages innovation in eco-friendly product design, leading to a more sustainable environment.

Challenges include setting up efficient collection systems, ensuring compliance from producers, educating consumers, and creating a robust recycling infrastructure.

Consumers can participate in recycling programs, choose products with minimal packaging, and properly dispose of plastic waste to support the EPR initiatives of producers.

Governments establish and enforce EPR policies, monitor compliance, and provide necessary support, such as creating guidelines and regulations for producers.

Yes, producers failing to meet EPR obligations may face fines, legal actions, or restrictions on their products, motivating them to comply with the regulations.

Businesses should stay informed about relevant regulations, collaborate with recycling organizations, and invest in sustainable product design and recycling infrastructure.

Innovations include advanced recycling technologies, biodegradable plastics, and initiatives promoting circular economy principles, which aim to minimize waste and maximize resources.

EPR regulations often cover a wide range of plastic products, including packaging materials, electronic devices, appliances, and other consumer goods made of plastic.

Recycling facilities collaborate with producers to handle the collection and recycling of plastic waste. They process collected materials, ensuring they are recycled or disposed of responsibly according to EPR guidelines.

Communities can raise awareness, participate in recycling programs, and advocate for effective EPR policies, encouraging both producers and consumers to play their part in responsible plastic waste management.

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