What is EPR in Plastic waste Management?

The Extended Producers Responsibility/EPR regime is defined in Plastic Waste Management Rules, 2016. The rules mandate the generators of plastic waste to take steps to minimize generation of plastic waste, not to litter the plastic waste, ensure segregated storage of waste at source and hand over segregated waste in accordance with rules.

Under this it is the responsibility of Producers, Importers and Brand-owners to ensure processing of their plastic packaging waste through recycling, re-use or end of life disposal (such as co- processing/ Waste-to-energy/Plasticto-oil/roadmaking/industrial-composting).

As per these guidelines, Producers, Importers and Brand Owners (PIBOs) shall have to register with Central Pollution Control Board (CPCB). Extended Producer Responsibility shall be applicable to both pre-consumer and post-consumer plastic packaging waste.

Which entities shall register on the centralized portal developed by CPCB?

The following entities shall register on the centralized portal developed by CPCB:

1. Producer (P) of plastic packaging;

2. Importer (I) of all imported plastic packaging and / or plastic packaging of imported products;

3. Brand owner (BO) including online platforms/marketplaces and supermarkets/retail chains other than those, which are micro and small enterprises as per the criteria of Ministry of Micro, Small and Medium Enterprises, Government of India.;

4. Plastic Waste Processor engaged in (a) recycling, (b) waste to energy, (c) waste to oil, and (d) industrial composting.

Categories of plastic packaging under EPR

Category I

Rigid plastic packaging

 

Category II

Flexible plastic packaging of single layer or multilayer (more than one layer with different types of plastic), plastic sheets or like and covers made of plastic sheet, carry bags, plastic sachet or pouches

Category III

Multilayered plastic packaging (at least one layer of plastic and at least one layer of material other than plastic)

Category IV

Plastic sheet or like used for packaging as well as carry bags made of compostable plastics

Responsibilities of PIBOS

PIBO stands for producer, importer and brandowners. All the PIBO operating in India that uses plastic packaging as part of your operation, irrespective of your turnover or scale of operations you fall under the obligation of EPR and are responsible for Register at EPR Portal and fulfill obligations as under:

1. Recycling

2. Use of Recycled content

3. Reuse

4. End of life disposal

5. Optional engagement in collection and recovery of the plastics

6. Submit annual returns- Annual Reports are to be filed by June 30 of the following year for the intervening Registration period.

7. Provide proof of certificates (Plastic credits)

Process to Register, Comply and Obtain EPR Certificate

Step 1:

Process starts with registration at CPCB/SPCB by submission of relevant documents required which mainly consist of an KYC, action plan, agreement, certificates, licenses, etc.

Step 2:

The authorised waste management agency will  collect back agreed volume of post-consumer plastic waste in a period of 1 year from desired location and recycle or dispose it safely as per CPCB/SPCB guidelines.

Step 3:

Waste collection agency will present relevant documents for proof of waste collection activity.

Step 4:

On behalf of PIBOM’s agency will submit quarterly report to CPCB.

Step 5:

After completion of activity final report will be submitted by agency to PIBOM’s on yearly basis.

Validity of Licences

Fresh Registration shall be valid for a period of 1 year and the renewed Registration shall be valid for a period of 3 years

Timeline for registration

2 weeks

Application fees for Registration of PIBOs

Sl. No. Plastic Waste Generation Slab (Tons Per Annam) Proposed Processing Fees
1 Less than 1000 INR 10000
2 Between 1000-10000 INR 20000
3 More than 10000 INR 50000

Fees for renewal of Registration shall be same as same as Registration fee.

25% of Application fees is to be paid as Annual Processing Fees at time of filling annual returns.

Author Bio

Qualification: CS
Company: Praman Advisors private limited
Location: New Delhi, Delhi, India
Member Since: 19 Feb 2018 | Total Posts: 64
I am a Practicing Company Secretary and a Lawyer and have an experience of over 12 years. I have been practicing in the field of Corporate Laws, Secretarial Audits, Legal Drafting, Compliances, NBFC, FEMA & RBI and SEBI, Stock and Commodity Market Exchange Regulation, Advisory of Listed and unli View Full Profile

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4 Comments

  1. Abhishek says:

    What is an EPR Registration?

    Extended Producer Responsibility (EPR) is a government-led initiative. That requires businesses to take responsibility for managing the waste generated by their products and packaging materials. The process begins with EPR registration, which is a formal stage where businesses obtain authorization to handle the waste produced by their products. This responsibility covers waste generated at both pre-consumer and post-consumer stages, ensuring proper waste management throughout the product life cycle.

    The Central Pollution Control Board (CPCB) is a statutory body under the Ministry of Environment, Forest, and Climate Change in India. It plays a crucial role in formulating and implementing policies and programs for environmental protection.

    *Types of online EPR certificates under CPCB

    Plastic Waste
    Battery Waste
    Plastic Waste
    E-Waste

    *Documents required for EPR registration

    Aadhar Details
    Covering letter
    GST Certificate
    PAN Card details
    PAN of Authorized person
    CIN of company/LLP/OPC
    IEC Certificate in case importer
    Partnership deed in case of partnership firm
    DIC Registration (if unit registered with DIC)
    Scanned copy of signatures of authorized persons
    Process flow diagram (In case of Brand owners only)
    Consent issued by SPCP/PCC (If unit has production facility)
    Document regarding any other information which the unit wishes to provide

  2. Narendra says:

    Dear Ma’am
    Due to oversight, we have declared total consumption of 2021-22 i.e.including export, at the time of registration.
    Kindly suggest how to revise it.

  3. Uzair Ahmad says:

    Dear Madam
    We are registered as PIBO on the CPCB portal and how to update the procurement invoice on the portal as directly dont purchase any plastic waste its only the the packaging parts. How to segregate this and how to upload the procurement details on the portal.

  4. ANUJ KUMAR GOEL says:

    Dear Madam,
    Please advice about EPR. Our company started the production on Sep-2021 when EPR compliance came into effect on us. If we will fail to get the certificate then what will effect on the import.

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