Waste management

EPR Action Plan for Plastic Waste: Explained

calendar18 Feb, 2022
timeReading Time: 3 Minutes
EPR Action Plan

The Plastic Waste Management Rules is applicable to PIBOs (producer, importer, or brand owner) who launch their plastic-packed products into a certain market. PWM rules also mandate these entities to set up systems to accumulate plastic waste generated by their product. This article will take a broad look at EPR Action Plan and other legalities mandatory for PIBOs.  

Plastic packagings are usually manufactured from the following materials:

  • High-Density Poly Ethylene
  • Polyethylene terephthalate
  • Low-Density Poly Ethylene
  • Polypropylene
  • Poly Vinyl Chloride
  • Polystyrene 
  • Multi-layer packaging 

Modes under PWM rules for the accumulation of plastic waste

As per PWM Rules, 2016[1], PIBOs are permitted to collect plastic waste via the following modes.

  • Through their distribution channel
  • Tie-up with ULBs, i.e., Urban Local Bodies
  • Work with PROs and WMC, i.e., waste management companies

Registration Compliance for PIBOs under PWM Rules

Every PIBO (Producer or Brand owner) shall apply for registration under PWM rules, 2016 via form 1. The said form should be filed with the following authorities depending on the scope of operation: 

  • The respective SPCB or PCB of the UT, if the entity is functional in one more or two states or UTs; or 
  • The CPCB i.e., Central Pollution Control Board, if the entity is functional in more than two Indian states or UTs. 

Steps for EPR fulfillment for Plastic Waste

Step 1: Define waste procurement targets

 Step 2: Identify fulfillment partners as mentioned above

 Step 3: Draft an Action Plan* as the format cited under PWM Rules, 2016

 Step 4: File application for PWM Registration with the competent authority and start meeting EPR target

Step 5: Quarterly filing

While filing an application for registration, the applicant must facilitate various documents relating to plant setup, business registration, and EPR action plan: 

EPR action plan depicts the firm’s capabilities of procuring/recycling/ processing plastic wastes from a materialistic viewpoint. Before we dive into the underlying format of the EPR Action plan, let us understand the term Extended Produce Responsibility.

What is the role of Extended Producer Responsibility? 

Extended Produce Responsibility refers to a policy approach under which PIBOs are given an important financial and/or physical responsibility for the disposal or processing of post-consumer products. 

EPR is the producer’s accountability to ensure environmentally sound management of their products till the end of their intended uses or service life. 

It may include deploying a take-back system by establishing collection centers & having agreed arrangements with the competent entities either individually or via a recognized Producer Responsibility Organization (PRO).

Action Plan to be drafted by PIBOs under PWM Rules

Following is the Format for Drafting Action Plan as per PWM Rules





Unit’s name and address



Type and Quantum of Plastic used



Estimated quantum of Plastic waste to be generated



Action plan relating to own waste/ equivalent quantum of waste



In case of equivalent quantum of waste, source of waste generation to be pinpointed



Action plan based on:

  • Own Distribution channel
  • Engagement of Agency
  • Engagement of ULBs



Own Distribution Channel



Distribution network’s detail 



Does the network posses Pan-India Coverage



Estimated quantum of waste to be accumulated




Mode of recycling/reusing waste



Registration detail of the recycler/coprocessor/agency involved with road making



Engagement with ULBs 



List of ULBs to be engaged with



Does the aforementioned list has pan India coverage



breakup waste to be accumulated with the aid of ULBs



Documentation supporting involvement with ULBs



Mode of reusing/recycling waste (Recycler/Co processing/Road making)



Involvement with Coprocessor/recycler/agency involved with road making



Registration details relating to Recycler / Agency/ Coprocessor involved with  Road making



Break-up of quantity to be sent to Recycler /Agencies/ Coprocessor engaged in Road making



Document reflecting involvement with Recycler/Agency/ Coprocessor engaged in Road making



Engagement of Agency



List of Agencies to be engaged



Does the aforementioned list has pan India coverage



Document reflecting engagement of the Agency by the ULBs/ Bulk Waste generators



Break up of Waste to be collected/segregated by the Agency



Mode of Reusing/Recycling Waste ( Recycler/ Road Making / Co processing)



Engagement with Recycler / Coprocessor/ Agency engaged in Road making



registration details of Recycler/ Coprocessor/ Agency involvement Road making



Break-up of quantity to be sent to Recycler/Agencies/ Coprocessor engaged in Road making



Any Other alternatives (provide details on PWM as per 6 a-c above)


Given the above information, we can conclude that EPR Action Plan is an absolute mandate for PIBOs operating pan India. It should be drafted as per the format mentioned above. Document preparation and form filing can be a hectic undertaking for the first-timer, considering the availability of legalities cited under the PWM Rules. Therefore, it is ideal to precede under the supervision of an expert firm like Corpbiz. This advanced platform is touted for rendering best-in-class licensing services to clients pan India.

Read our Article:How to get Plastic Waste Management Registration?

Request a Call Back

Are you human? : 1 + 8 =

Easy Payment Options Available No Spam. No Sharing. 100% Confidentiality