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EPR Authorisation (Plastic Waste)

EPR, or Extended Producer Responsibility, is a policy approach that aims to make producers responsible for the end-of-life management of the products they produce. Under the EPR scheme, plastic industries are required to register with the CPCB and impleme

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Introduction

Plastic has many uses, and due to its physical and chemical properties leads to huge commercial use and success. The indiscriminate disposal of plastic has, however, become a major environmental threat. In particular, plastic carrying bags are the main contributors to littered waste and, every year, millions of plastic bags end up in the atmosphere vis-à-vis the soil, water bodies, rivers, etc it takes an average of one thousand years to decompose completely. Therefore, the Plastic Waste (Management and Handling) Regulations, 2011 were notified in 2011, which included plastic waste management, to tackle the problem of scientific plastic waste management. In violation of the earlier Plastic Waste (Management and Handling) Regulations, 2011 the government notified the Plastic Waste Management Regulations, 2016.

EPR, or Extended Producer Responsibility, is a policy approach that aims to make producers responsible for the end-of-life management of the products they produce.

The Plastic Extended Producer Responsibility (EPR) is a concept that requires manufacturers and producers of plastic products to take responsibility for the end-of-life management of their products. It is implemented by the Central Pollution Control Board (CPCB) under the Plastic Waste Management Rules, 2016 and applies to all companies that produce, import, or sell plastic products in India. The EPR scheme is aimed at reducing the environmental impact of plastic waste and promoting sustainable waste management practices. It requires companies to register with the CPCB and implement a plastic waste management plan, and pay a fee for the registration and for any services provided by the CPCB under the EPR scheme. Failure to comply with the rules can result in penalties and fines.


PLASTIC- means a material which contains as an necessary ingredient a high polymer such as high density polyethylene , vinyl , polyethylene , terephthalate , polypropylene , polystyrene, multi materials like acrylonitrile butadiene styrene , Polyphenylene oxide , polycarbonate , Polybutylene Terephyhalate.

Categories of Extended Producer Responsibilities:

Category 1- Rigid Plastic packaging

Category 2- Flexible plastic packaging of multilayer or single layer (multilayer means more than one layer with different types of plastic) plastic sheets or like and covers made of plastic sheet, carry bags, plastic sheet or pouch.

Category 3-Multilayered plastic packaging

Category 4- Plastic sheet or like used for packaging as well as carry bags made of compostable plastic

Objective of Extended Producer Responsibility

According to the Plastic Waste Management Rules, 2016, it is the obligation of waste producers/importers to appropriately dispose of or recycle post-consumer E-waste. Extended Producer Responsibility (E.P.R.) is an environmental and economic strategy to manage a product's lifecycle.

EPR refers to the producer's obligation for managing the disposal of products once they have been declared as no longer useful by customers. It's a producer's commitment to make it easier for end-of-life, post-consumer trash to be collected and recycled. The goal is to create a system that takes care of material collection, segregation, and transportation to a waste disposal facility. On the basis of quality and affordability, these materials can also be used in cement kilns, pyrolysis, road building, and recycling centres. Waste generators, such as brand owners/producers, must collect end-of-life waste generated by their operations. This obligation is met by waste recyclers that have been authorised by the Central Pollution Control board for in this regard. This provides financial incentives to brands to build marketplaces for reuse, buy-back, and recycling of materials. Companies can also entrust this task to a third-party.

The objective of extended producer responsibility (EPR) is to ensure that producers are responsible for the environmental impacts of their products throughout their entire life cycle, from the extraction of raw materials to the disposal or recycling of the products at the end of their useful life. This approach shifts the responsibility for managing the environmental impacts of products from governments and taxpayers to the producers who create and profit from these products. The goal of EPR is to incentivize producers to design and manufacture products in a way that minimizes waste and negative environmental impacts, and to promote the proper disposal or recycling of these products. This can help to reduce pollution, conserve natural resources, and protect public health.

Some of the initiatives vide EPR guidelines are:

  • Increase the minimum thickness of plastic carry bags from 40 to 50 microns and specify a minimum thickness of 50 microns for plastic sheets also to encourage the collection and recycling of plastic waste
  • Extend the applicability jurisdiction from municipal to rural areas, since plastic has also reached rural areas
  • Introduction of system collecting back of plastic waste by producers/brand owners, as per extended producer responsibility.
  • Promoting the use of plastic waste for road construction according to the guidelines of the Indian Road Congress or energy recovery, or waste to oil, etc. for the profit-making use of waste and also addressing the issue of waste disposal; entrusting further responsibility to waste generators, namely payment of user fees as prescribed by local authorities, collection and transfer of waste by the institutional generator, event organizer

Applicability

The Plastic Extended Producer Responsibility (EPR) is applicable on all companies that produce, import, or sell plastic products in India. This includes manufacturers, producers, and retailers of plastic products, as well as companies that use plastic packaging for their products.

The EPR scheme applies to a wide range of plastic products, including packaging materials, single-use items, and durable goods. It covers all stages of the product lifecycle, from the production and distribution to the end-of-life management of the products.

The EPR scheme is implemented by the Central Pollution Control Board (CPCB) under the Plastic Waste Management Rules, 2016. These rules specify the responsibilities of producers and manufacturers, as well as the steps they need to take to ensure the safe disposal of their plastic products.

Companies that are covered under the EPR scheme are required to register with the CPCB and implement a plastic waste management plan. They also need to pay a fee for the registration and for any services provided by the CPCB under the EPR scheme. Failure to comply with the rules can result in penalties and fines.

The Extended Producer Responsibility (EPR) is applicable on the following people:

  1. Manufacturers and producers of plastic products, including packaging materials, single-use items, and durable goods.

  2. Companies that use plastic packaging for their products, such as food and beverage companies, cosmetic manufacturers, and pharmaceutical companies.

  3. Retailers and distributors of plastic products.

  4. Importers of plastic products.

  5. Anyone involved in the production, distribution, or disposal of plastic products.

The EPR scheme is implemented by the Central Pollution Control Board (CPCB) under the Plastic Waste Management Rules, 2016. These rules specify the responsibilities of producers and manufacturers, as well as the steps they need to take to ensure the safe disposal of their plastic products.

Companies that are covered under the EPR scheme are required to register with the CPCB and implement a plastic waste management plan. They also need to pay a fee for the registration and for any services provided by the CPCB under the EPR scheme. Failure to comply with the rules can result in penalties and fines.

Responsibilities of Producers, Importers, Brand Owners, Local Bodies & Gram Panchayat

The producers must develop waste collection system modalities based on Extended Producers Responsibility and including State Urban Development Departments, either separately or jointly,

The production and usage of multi-layered plastics that are not recyclable, energy-recoverable, or have no alternative plastic use, if any, should be phased out within two years;

The producer must apply to the Pollution Control Board or the Pollution Control Committee, as deem appropriate, of the States or the Union Territories within three months of the date these rules were finally published in the Official Gazette for registration

Every producer shall maintain detailed records of the person who is engaged in supply of plastic used as raw material to manufacture carry bags and related stuff.

The responsibilities of producers, importers, brand owners, local bodies, and gram panchayats in relation to extended producer responsibility (EPR) would depend on their specific roles and the specific context in which EPR is being implemented. However, some general responsibilities might include:

  • Producers: Ensuring that their products are designed and manufactured in a way that minimizes waste and negative environmental impacts, and that they have a plan in place for the proper disposal or recycling of their products at the end of their useful life.

  • Importers: Ensuring that the products they import meet any relevant EPR regulations and standards, and that they have a plan in place for the proper disposal or recycling of these products at the end of their useful life.

  • Brand owners: Ensuring that their branding and marketing efforts accurately reflect the environmental impact of their products and do not mislead consumers, and working with producers and importers to develop and implement effective EPR plans.

  • Local bodies: Developing and implementing EPR regulations and standards, and working with producers, importers, and brand owners to enforce these regulations and ensure that EPR plans are being effectively implemented.

  • Gram panchayats: Implementing government policies and programs related to EPR at the local level, and working with local bodies and other stakeholders to ensure that EPR plans are being effectively implemented in their communities.

Responsibilities of Producers, Importers, Brand Owners

The producers must develop waste collection system modalities based on Extended Producers Responsibility and including State Urban Development Departments, either separately or jointly,

The production and usage of multi-layered plastics that are not recyclable, energy-recoverable, or have no alternative plastic use, if any, should be phased out within two years;

The producer must apply to the Pollution Control Board or the Pollution Control Committee, as deem appropriate, of the States or the Union Territories within three months of the date these rules were finally published in the Official Gazette for registration

Every producer shall maintain detailed records of the person who is engaged in supply of plastic used as raw material to manufacture carry bags and related stuff.


Any person shall produce carrying bags or recycle plastic bags or multi-layered packaging unless the person has, as the case may be, obtained a certificate from the State Pollution Control Board or the Pollution Control Committee of the Union Territory concerned before production begins

For the purpose of registration or for renewal of registration, make an application to the State Pollution Control Board or the Pollution Control Committee of the Union territory concerned

Every producer shall apply in Form I, every manufacturer shall apply in Form III & every person recycling or processing shall apply in Form-II.


Pre-requisite for EPR Registration:

The State Pollution Control Board or the Pollution Control Committee shall not renew the registration of producer unless the producer possesses an action plan endorsed by the Secretary in charge of Urban Development of the concerned State or Union Territory for the setting of the plastic waste management system

Procedure of EPR

STEP 1: Fill the requisite form that forms I, II or III as per the type and formation of business

STEP 2: Annex/Upload all the necessary documents, such as the establishment registration certificate, PAN card, and proof of address. In addition to these documents, plastic industries need to submit a certificate of registration from the Plastic Waste Management Institute (PWMI) and a copy of the plastic waste management rules issued by the CPCB.

STEP 3: All the documents should be signed by an authorized person of the organisation.

STEP 4: Submit the form to the Central Pollution Control Board (CPCB) for processing/approving the application. 

STEP 5: Once the application is approved, the company will receive an EPR registration number, which will be used for all future transactions with the CPCB.

STEP 6: IF the form is proper and fine the department will grant the certificate. Once the application is approved, the company will receive an EPR registration number, which will be used for all future transactions with the CPCB.

The company will also need to pay a fee for the registration and for any services provided by the CPCB under the EPR scheme. The company can track the status of their EPR registration and view the reports submitted to the CPCB through the online portal.

 

Documents for EPR Registration

The documents required for Plastic Extended Producer Responsibility (EPR) registration in India are as follows:

1. Aadhar card of the authorized person

2. PAN copy of the Company or authorized person

3. GST certificate of organization

4. Proof of Address of the Company - Rent/lease/ proof of ownership

5. Factory license/trade license

6. Electricity bill

7. Layout/plan of the unit

8. Establishment Certificate - CIN(certificate of incorporation) in case of company/LLP

9. Memorandum Of Association (MOA)

10. Articles of Association (AOA)

11. Board resolution for appointing an authorized person

12. Certificate of registration from the Plastic Waste Management

13. Any other relevant documents as required by the CPCB

These documents need to be uploaded online while filling out the EPR registration form on the CPCB's website. The application will be processed once all the required documents are submitted and verified by the CPCB.

 

Benefits of EPR registration

EPR registration for Plastic Waste Management offers numerous benefits for both the environment and businesses. Let's explore some of these advantages:

1. Environmental Impact Reduction

By holding producers accountable for the proper disposal and recycling of plastic waste, EPR helps reduce the environmental impact caused by plastic pollution. It promotes the efficient collection and recycling of plastic waste, diverting it from landfills and water bodies.

2. Circular Economy Promotion

EPR encourages the adoption of a circular economy model by creating markets for the reuse, buyback, and recycling of materials. This approach reduces the dependence on virgin resources and promotes the sustainable use of existing resources.

3. Compliance with Regulations

EPR registration ensures compliance with Plastic Waste Management Rules, demonstrating your commitment to environmental responsibility. It helps businesses avoid penalties and legal consequences for non-compliance.

4. Brand Reputation and Consumer Confidence

Implementing EPR practices enhances your brand's reputation as an environmentally responsible entity. Consumers increasingly value sustainable practices, and by complying with EPR regulations, you can gain their trust and loyalty.

5. Economic Opportunities

EPR registration opens up economic opportunities in the recycling sector. With the increasing demand for plastic waste processors, this industry provides employment and business prospects for individuals and organizations involved in waste management.



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