What is EPR Compliance

Introduction

Extended Producer Responsibility is a policy approach to affix the responsibility of the complete life cycle of a product on the producers of such product. EPR implies that once a product manufactured is rendered useless, then the manufacturer of such product shall be responsible for taking it back or recycling the product.

Extended producer responsibility legislations are put in place to motivate the adoption of remanufacturing initiatives resulting in increased focus on the end-of-use treatment of consumer products. Such Legislations are aimed at increasing the amount and degree of product recovery and also minimizing the impact of waste materials on our environment.

EPR legislations motivate the manufacturers to design environment friendly products which have low impact on the environment or are easily recyclable.

EPR may be undertaken in the form of re-use or buy-back or recycling program. The manufacturer of the product may also opt for delegating such responsibilities to the third parties specialised in such service. Such third parties are also known as producer responsibility organization (PRO) who facilitate the EPR for manufacturers.

 

Plastic Extended Producer Responsibility Policy in India

The Ministry of Environment, Forest and Climate Change notified the Plastic Waste Management Rules, 2016 on 18th March, 2016. EPR Policy has mandated the generators of waste have been to take steps in order to minimize the generation of plastic waste, decrease litter of the plastic waste, ensure segregated storage of waste and systematic handover of the segregated waste to the local bodies or agencies authorised by the local bodies. The EPR rules have also mandated the responsibilities of local bodies, gram panchayats, waste generators, retailers and street vendors to manage plastic waste.

 

Benefits of Extended Producer Responsibility

EPR legislations have been put in place to act as motivators for the manufacturers to decrease the impact of product on the environment. EPR ensures a direct financial impact on the manufacturers with increase in environmental impact of their products on the environment. EPR is a positive force towards incremental recycling and reuse of the products and decrease in the use of hazardous components in manufacture of products. It also has led to increased implementation of environment friendly design and strategies ultimately resulting in decrease of landfills and hazardous wastes 

 

Responsibility of Producer

Producers are made responsible for the end-of-life management of their products by undertaking activities like take-back, recycling and reuse of the products manufactured by them.

Manufacturers have to be compliant with the regulatory compliance associated with the production process but are also responsible for end of life cycle of the product. Not all producers are equipped with waste management capabilities, hence they end up hiring specialised third party agencies / organisations to take care of recycle and reuse on their behalf. Some of the responsibilities of the producers can be summarised as below:

1. The producers of plastic waste shall register themselves as “producer” in accordance with the provisions of Plastic Waste Management Rules, 2016 (PWM Rules).

2. If the producer operates in more than two states then the application shall be submitted to the CPCB

3. Design an action plan for EPR responsibility and submit it to the CPCB. The plan shall consist the type and quantities of plastic waste. The details shall also include pre-consumer and post-consumer generated waste segregated in a zone-wise manner, the method of collection and processing of plastic waste segregated zone-wise and the details of the strategic / implementation partners along with the detailed and supporting documentation.

4. Once the EPR Plan is approved by the CPCB, the Producers are responsible for the Collection, logistics, recycling, processing/ co-processing / re-processing or disposal of plastic waste in the manner and quantity mentioned in the approved EPR plan. They may conduct such activities either through their own channels, or in association or partnership(s) with municipalities/local bodies or any other method that can ensure traceability of the waste.

5. Maintenance of records for each activity for quarterly filings and other periodic filings.