Extended Producer Responsibility - Demystified


In the last decade, the global attention has shifted to unabated growth in the use of plastic material as packaging resulting into large amount of post-consumer packaging  waste making way to landfills  or marine environment and raising concerns for  environmental effect.  . The crisis of managing the waste in an efficient and systematic way has become a challenge not only in India but all over the world forcing governments to take initiatives  to address  the problem. 

One of such initiative is Extended Producer Responsibility (EPR), which describes the life-cycle of products and packaging made, sold and distributed by suppliers, importers, brand-owners and manufacturers. EPR encourages a ‘cradle-to-cradle’ approach to managing materials, meaning products and packaging discarded by the consumer are recovered, recycled, reused or brought to end of life through waste to energy.  Recycled materials are used to make new products- redirecting waste destined for landfill and reducing our impact on the environment.

Indian Government introduced the concept of EPR in 2016 under Plastic Waste Management Rule, 2016 and defined it as ‘the responsibility of a producer for environmentally sound management of the product until the end of its life.’ Later on 16th February, 2022, Ministry of Environment, Forest and Climate Change issued a notification on Guidelines on Extended Producer Responsibility for Plastic Packaging. 

Plastic waste Management Rule, 2016, rule 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 the rules. Also the rule mandate the responsibility of local bodies, gram panchayats, waste generators, retailers and street vendors to manage plastic waste. 

The PWM, cast EPR on Producers, Brand Owners and Importers. It also provides a framework for the implementation of Extend Producers Responsibility.

As per the EPR Guidelines, Rule 4, total 4 entities have been covered under Extended Producers Responsibility- Producers (P) of plastic packaging, Importer (I) of all imported plastic packaging and/ or plastic packaging of imported products, Brand Owners (BO) including online platforms/ marketplaces and supermarkets/ retail chains other than those and Plastic Waste Processor (PWP). However, Brand owners which are micro and small scale as per the criteria of Ministry of Micro, Small and Medium Enterprises, Government of India has been exempted under the said Rule.

The PWM rule, 2016 and its subsequent amendments also defines the various terminology used throughout the rule for some better understanding. The definition of PIBOs as described under the rule are mentioned below:

Brand Owners: means a person or company who sells any commodity under a registered brand label or trade mark.

Importer: means a person who imports plastic packaging products with plastic packaging or carry bags or multilayered packaging or plastic sheets or like

Producer: means person engaged in manufacturer or import of carry bag or multilayered packaging or plastic sheets or like, and includes industries or individuals using plastic sheets or like or covers made of plastic sheets or multilayered packaging for packaging or wrapping the commodity. 

Under the PWM, 2016 Center Pollution Control Board (CPCB) has released the revised module on EPR registration on CPCB centralized portal. The revised Module has been introduced in phase wise manner and comprises total of 7 Module. 
Module-1: Registration of PIBOs, updated 
Module-2: Registration of PWPs, updated 
Module-3: Issue and Exchange of EPR Certificate, updated 
Module-4: Filing of Annual Return, In-progress
Module-5: Environmental Compensation, In-progress
Module-6: Third Party Audit, In-progress
Module-7 Training, In-progress

As per the guidelines PIBOs, are initially required to register themselves on the portal mentioning company’s details. This will create an account on centralized portal which can be logged in for further and future reference. During the submission of the application, enterprise need to submit various documents and details divided in 4 different section: Part A, B, C, D. 
In part A, unit need to mention the general details of the company and the type of entity with some supporting documents. 
In part B, information relating to Consent obtained from SPBCs (State Pollution Control Board) need to be mentioned without which application will not be further submitted. 
Part C, comprises the details and information relating to Waste generated within the units, procurement details and sales details of previous two financial year. 

The mentioned details in Part A, B and C will create the action plan for implementation of Extended Producer Responsibility for PWM which will be auto filled in the last section of the form i.e. Part D. Please Note here that once the detail in section C has been submitted, no further changes can be done on portal.  During the process of EPR registration, there are certain documents which are required to be submitted with the registration form. 

Post registration, the portal will generate the ERP targets for each financial year based on the details uploaded on the portal of every sales and procurement of materials done in the present year. Earlier, units were required to upload the action plan and the EPR liabilities applicable as per the rules, but with the Updation in the Modules, EPR responsibility will be generated automatically in  accordance with  Invoices uploaded on the portal for every sales and procurement of material done by the unit.

For further information call on +91 9930304565

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