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Overview of EPR Target Fulfilment and Compliance

Extended Producer Responsibility, or EPR, was first introduced in 1988 in Sweden. Since then, the concept of EPR has evolved in a multidimensional manner, encompassing the unique waste management requirements of different countries. In India, the EPR regime has significantly transformed the waste management framework in the field of plastic packaging waste, e-waste, tyre waste and hazardous waste such as battery waste. India's EPR framework focuses on end-of-life waste management, EPR Target Fulfilment and compliance requirements in the abovementioned sector. It encourages manufacturers and recyclers to adopt sustainable manufacturing, recycling, disposal, and co-processing practices while promoting a circular economy between the production and recycling sectors.

EPR Targets are recycling targets that are assigned to identified producers (manufacturers, importers, brand owners). These targets are usually defined as a percentage of the Eligible Quantity that the entity has to recycle, and the targets are increased gradually. EPR targets are assigned after the successful registration for EPR and subsequently after the successful annual return submission on the EPR portal.

Need for EPR Policy in India

India has actively tried to improve its waste management policies from a way back. We are a party to the Basel Convention and a signatory to international conventions like the Stockholm Convention (2006) and the Rotterdam Convention that addresses the idea of shared responsibilities among the participating countries. However, a need to develop a defined process for reusability and recyclability in the waste management sector led to the evolution of EPR. The Polluter's Pays principle on which the EPR Policy emerged shifted the burden of waste management from municipalities to the producers (manufacturers) and importers of the product.

The provisions regarding EPR Target Fulfilment were notified under the different waste management rules separately for business entities in all the identified sectors, along with the provision of EPR certificate trading among registered entities. EPR Target Fulfilment obligations require a producer to take responsibility for the product's entire lifecycle they put on the market, including their disposal.

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EPR Target Fulfilment in Case of Plastic Packaging Waste

Producers, Importers and Brand Owners (PIBOs) that introduce products in plastic packaging are made responsible for the management of packaging waste generated.

PIBOs, as well as the plastic waste processors (engaged in recycling plastic waste or involved in waste to energy, waste to oil, and industrial composting), are the entities identified under the PWM Rules 2016 that need EPR registration. PIBOs, after obtaining EPR authorisation on the CPCB's centralised EPR portal, have the option of managing their EPR Targets through their waste collection/distribution channels or Urban Local Bodies (ULBs) or with the assistance of any Waste Management Agencies (WMAs). Apart from EPR Target Fulfilment, other obligations of PIBOs include

  • Registering on the centralised EPR portal developed by CPCB
  • Submitting their Action Plan for waste management
  • Recycling of plastic packaging waste
  • Use of Recycled content in production
  • End-of-life disposal
  • Collection and recovery of the plastics
  • Submitting annual returns
  • Provide auditable proof for purchased EPR certificates

EPR targets for PIBOs

For FY 2023-24, the EPR Target is set to 100 % of the eligible quantity (Q), which is calculated by the following equation:

For Producer

For Importer

For Brand Owner

Q= (A+ B) - C

Q= (A+ B) - C

Q= (D+ B)

Note:

  • A is the average weight of plastic packaging material sold in the last two FYs.
  • B is the average quantity of pre-consumer plastic waste generated in the last two FYs.
  • C is the quantity of plastic sold to Brand Owners in the last financial year.
  • D is the average weight of plastic waste purchased/introduced in the last two FYs.

If your business introduces any product in plastic packaging in the plastic categories, namely rigid, multi-layered, flexible or compostable plastic, the EPR Target fulfilment will have to be done under the specific category only. However, if the PIBO cannot fulfil their targets, they can purchase EPR certificates from registered recyclers, co-processors and Plastic Waste Processors with the assistance of Corpbiz, which has a pan-India network of registered recyclers, co-processors and PWPs.

EPR Target Fulfilment in Case of E-Waste

The updated E-Waste Management Rules define the rules and recycling modalities related to EPR Target fulfilment for Manufacturers, producers and importers of EEE. Schedule 1 of the E-Waste Management Rules, 2022 outlines the electrical and electronic equipment (EEE) category, including their components, consumables, parts and spares that invite EPR. The manufacturers of the electronic devices, along with dealers or refurbishers who intend to sell refurbished EEE in the market, were introduced as additional stakeholders that need EPR registration and fulfil their recycling targets. Schedule III of the rules defines the E-Waste Recycling Target (by weight) that is applicable from 2023-24 onwards on producers, manufacturers and importers of EEE.

EPR Targets for Producers and Importers of EEE

Under the E-Waste (Management) Rules, 2022, the producers will have to achieve the recycling target generated annually by the CPCB's EPR portal for E-waste. Also, as a part of EPR Target Fulfilment, producers must submit an annual report on the portal concerning their target fulfilment.

Year

EPR Targets

2023 -2024

60% of the EEE quantity placed in the market in year Y-X, ('X' denotes the average life of the product).

2024 -2025

60% of the EEE quantity placed in the market in year Y-X.

2025 -2026

70% of the EEE quantity placed in the market in year Y-X.

2026-2027

70% of the EEE quantity placed in the market in year Y-X,'

2027-2028

80% of the EEE quantity placed in the market in year Y-X

2028-2029 onwards

80% of the EEE quantity placed in the market in year Y-X.

However, the EPR targets producers who have started sales operations recently, and the number of years of sales operations in their case is less than the average life of their products mentioned in the guidelines issued by CPCB from time to time, will have different targets. Once the number of years of sales operation equals the average life of the product mentioned in the guidelines issued by CPCB, their EPR obligation will be similar to the rest of the producers, as mentioned in the above table. The table below shows the targets of producers who have started sales operations recently.

Year

E-Waste Recycling Target (by weight )

2023-2024

15% of the sales figure of the financial year 2021-22

2024-2025

20% of the sales figure of the financial year 2022-23

2025-2026 onwards

20% of the sales figure of the financial year two years back

EPR Target Fulfilment in Case of Waste Tyre

The Hazardous and Other Wastes Amendment Rules, 2022, lays down the responsibilities of producers, recyclers, and re-treaders for environmentally sound management and disposal of waste tyres by introducing EPR obligations for waste tyre management. A centralised EPR portal developed by the CPCB for this purpose acts as the single point data repository for identified stakeholders in tyre manufacturing, import and recycling/retreading. The utilisation and management of waste tyres will be in accordance with the Schedule IX of the HOWM (Amendment) Rules, 2022.

EPR targets for Producers, waste Tyre Importers and Retreaders

EPR obligations imposed under the Amendment Rules 2022 have been bifurcated based on the entity registering on the CPCB portal.

For producers (For manufacturers or importers of new tyres)

The EPR obligations have been set as per the table below

Sr. No.

Year

Waste Tyre Recycling Target in Weight (Kilogram or Tons)

(i)

EPR obligation of the year 2022-2023 (the year in which this Schedule comes into force)

35% of the quantity of new manufactured or tyres imported in the year 2020-2021

(ii)

EPR obligation for the year 2023-2024

70% of the quantity of new manufactured or tyres imported in the year 2021-2022

(iii)

EPR obligation of the year 2024-2025

100% of the quantity of new manufactured or tyres imported in the year 2022-2023.

(iv)

After the year 2024-2025 (year Y), the EPR obligation will be 100% of the quantity of tyres manufactured or imported in the year (Y-2).

(v)

For units established after the 1st April, 2022, the EPR obligation shall start after two years (Y) and will be 100% of the tyres manufactured or imported in the year (Y-2).

EPR Target Fulfilment for Waste Tyre Importers

The EPR obligation for waste tyre importers in the current year will be 100% of the weight of tyres imported in the previous year. Also, the import of waste tyres for the purpose of producing pyrolysis oil or char has been prohibited.

EPR Target Fulfilment for Retreading of Waste Tyre

Retreading of waste tyres has been allowed. However, the retreader will have to get registered on the portal to issue retreading certificates.

EPR Target Fulfilment in Case of Battery Waste

MoEF&CC published the Battery Waste (Management ) Rules 2022 in suppression of the Batteries Rules of 2001 for managing hazardous Battery waste. The Rules have defined EPR modalities related to battery waste management through collective efforts of Producers, Battery importers, and recyclers, refurbishers involved in the handling of 'end-of-life Batteries. The Rules focus on setting up a centralised portal for stakeholders' registration and introducing recycling targets. Producers may also engage themselves or authorise any other entity to collect, recycle or refurbish waste batteries. Entities involved in the refurbishment and recycling of Waste Battery when registered will be allowed to provide EPR certificates for waste battery processing.

EPR targets for Producers of Batteries

When we say recycling targets concerning batteries, we mean the maximum recovery target under the Battery Waste Management Rules, 2022. As these are subject to the percentage of non-recoverable hazardous material content in the battery, the EPR targets would mean the recovery target in percentage form. The following table shows the EPR Targets for different types of batteries identified under the Battery Waste Management Rules, 2022.

Type of Battery

Recovery target for the year in percentage

Portable

70

80

90

Automotive

55

60

60

Industrial

55

60

60

Electric Vehicle

70

80

90

Necessary Papers Required in Case of EPR Registration

Although the required necessary papers may vary depending on the category in which EPR authorisation is desired, here is a list of some common necessary papers that are needed at the time of online EPR registration.

  • A covering requisition letter
  • Copy of attested Lease Deed, Sale as proof of possession
  • Copy of attested MOA in case of Public/Private sectors or registered partnership deed in case of partnership company
  • Layout plan
  • Detailed manufacturing process for each product along with detailed process flow chart
  • Details of Water Balance
  • Details of Material balance for each product and process
  • Land use classification certificate
  • Consent NOC under Water and Air Acts
  • Any other necessary paper required by the Board

Frequently Asked Questions

The government tried its best to shift the focus to alternatives to plastic with the ban on SUP from July 1, 2022. However, the legislation does not seem to have a uniform and desired effect on the behaviour of sellers and consumers concerning SUP usage. In the case of Single-use plastic, like polythene bags and disposable plastic items, can still be found in many regions of the country.

A Deposit Return Scheme or DRS is a scheme which incentivises the return of waste or end-of-life products generated by consumers when they drop/deposit the waste at particular drop points.

Before the introduction of EPR as a regulatory policy, the cost of recycling was being borne by all taxpayers of the country. With EPR, the financial burden is distributed between the producer and consumer that use the product by paying for the waste management upfront. Therefore, EPR obligations should not be seen as an additional cost of the business as PIBO charges this added cost from the consumer.

The introduction of EPR did increase the effectiveness and coverage of formal channels of waste management services, thereby working to reduce the increasing stockpile of waste, curbing environmental degradation, improving the working conditions of waste recyclers and reducing the consumption of fresh resources by promoting circularity.

There are 4 categories of Plastic packaging i.e. Category I for Rigid plastic Packaging, Category II for Flexible plastic packaging, Category III for Multi-layered plastic packaging and Category IV for compostable plastic.

The focus of the EPR policy in India was laying down defined responsibilities and targets for every stakeholder. Provision to penalise PIBOs for missing their targets in the form of environmental compensation and carrying forward their unmet targets may work in increasing EPR compliance.

The E-Waste (Management and Handling) Rules, 2011, first introduced the concept of EPR. Later, the MoEF&CC notified the EPR guidelines in the Fourth Amendment to Plastic Waste Management Rules 2016, while the 2018 amendment of E-Waste (Management) Rules 2016 defined targets for the collection of end-of-life products and simplified the process of applying for EPR authorisation.

The entities that were introducing potentially hazardous e-waste and other non-biodegradable waste, such as plastic, were not regulated by any dedicated waste management laws. This led to the manipulation of the waste management and import regulation, slowly turning India into a global dump yard for e-waste.

Before the introduction of HWM rules, India faced some major challenges in waste management. Managing hazardous waste was proving to be ineffective as it did not address the problem at its source. Later on, when India became a party to the Basel Convention, it came out with defined measures for storage, recycling disposal and transboundary movement of hazardous waste. Since then, the HWM Rules have been key in controlling hazardous waste pollution.

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