Registering for Plastic Waste Management through EPR: Plastic products play a vital role in our daily lives and are manufactured on a large scale worldwide. In India alone, the annual generation of plastic waste amounts to approximately 5.6 million tonnes (TPA), posing a significant disposal challenge. While recycling presents a viable option for reusing plastic products, the need to find alternatives to plastic is paramount.

In order to address the management of plastic packaging waste, the Plastic Waste Management Rules of 2016 have introduced the Extended Producer Responsibility (EPR) regime. Under this framework, producers, importers, and brand owners are tasked with ensuring that their plastic packaging waste undergoes proper processing, whether through recycling, reuse, or appropriate end-of-life disposal methods.

If you fall into the category of a producer, importer, or brand owner (PIBO) and operate in India using plastic packaging, compliance with EPR obligations is mandatory, regardless of your business turnover or operational scale.

Exploring Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) entails the responsibility of producers for the environmentally sound management of their products throughout their lifecycle.

The Ministry of Environment, Forests, and Climate Change, Government of India, introduced an amendment to the Plastic Waste Management (PWM) Rules on February 16, 2022. This mandates that producers, importers, brand owners (PIBOs), and Plastic Waste Processors adhere to Extended Producer Responsibility as outlined in Schedule II of the PWM Rules.

As per the EPR guidelines for plastic packaging, Producers, Importers, Brand-Owners, and Plastic Waste Processors must register via the centralized online EPR portal established by the Central Pollution Control Board (CPCB). PIBOs must secure EPR Registration for Plastic Waste Management from CPCB. PIBOs operating in one or two states/UTs must register with the respective State Pollution Control Boards (SPCB/PCC), while those operating in more than two states/UTs must register with CPCB.

PIBOs must ensure that plastic waste is processed by Plastic Waste Processors (PWPs) according to an action plan to fulfill assigned EPR targets. Failure to comply with PWM rules may result in environmental compensation and disciplinary measures.

Guidelines for EC Assessment for violation of PWM Rules 2016, CPCB

The subsequent entities are required to obtain an EPR registration certificate through the centralized EPR portal established by the Central Pollution Control Board (CPCB):

1. Manufacturers

2. Importers

3. Brand proprietors

4. Plastic Waste Processors involved in: a. Recycling b. Waste-to-energy c. Waste-to-oil d. Industrial composting

The duties of PIBOs include:

1. Registering on the EPR Portal

2. Submitting their Action plan

3. Meeting obligations for:

   • Recycling
   • Utilization of Recycled content
   • Reuse
   • End-of-life disposal
   • Optionally engaging in the collection and recovery of plastics
   • Submitting annual returns
   • Providing proof of certificates (Plastic credits)

PIBOs may collaborate with PROs (Producer Responsibility Organizations) or other entities separately to achieve their targets, but they are solely responsible for reporting and fulfilling those obligations.

Government Notification for Plastic Waste Management Registration

Prohibited Single-Use Plastic Items in India

As per the Plastic Waste Management (Amendment) Rules of 2021, the manufacturing, importing, stocking, selling, distributing, or usage of specified single-use plastic products will be deemed illegal starting July 1, 2022.

The catalog of Single-Use Plastic (SUP) items that will be banned from July 1, 2022, includes:

• Earbuds with plastic sticks

• Plastic sticks for balloons

• Plastic flags

• Candy sticks

• Ice cream sticks

• Polystyrene (Thermocol) for Decoration

• Plates

• Cups

• Glasses

• Forks

• Spoons

• Knives

• Straws

• Trays

• Wrapping/packing films around sweet boxes

• Invitation cards

• Cigarette packets

• Plastic/PVC banners less than 100 microns

• Stirrers

CATEGORIES of Plastic Packaging Included in Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) pertains to the following types of plastic packaging:

Category I: Firm plastic packaging

Category II: Single or multiple-layer adaptable plastic packaging (comprising various plastic types), plastic sheets, covers crafted from plastic sheets, tote bags, plastic packets or pouches

Category III: Packaging made of multiple layers of plastic (with at least one layer of plastic and one layer of non-plastic material)

Category IV: Plastic sheets or similar materials utilized for packaging, including biodegradable plastic tote bags

Documents Needed for EPR Registration of PIBOs/PWPs

Required Documentation for EPR Registration of PIBOs/PWPs:

• PAN, GST, CIN

• IEC (for importers) of the Company

• Aadhar/PAN of Authorized Person

• DIC Registration (if applicable)

• Process Flow Diagrams (for producers & PWPs only)

• Consents issued by SPCB/PCC (if applicable)

• Scanned copy of signatures of authorized persons

• Covering Letter

• Geo-tagged pictures of raw material storage area, production area, product dispatch area, and plant machinery (for PWPs only)

• Any other relevant documents provided by the unit.

Guideline for Plastic Waste Management Registration

EPR Registration Process for PIBOs/PWPs:

To secure EPR for Plastic Waste Management, PIBOs need to complete an online application process by providing the required information, documents, and application fees.

To secure EPR for Plastic Waste Management, PIBOs need to complete an online application process by providing the required information, documents, and application fees.

Here's the step-by-step process for EPR Registration:

1. Document Preparation: Ensure you have all relevant documents in pdf, jpg, or png formats ready before starting the application.

2. Registration for Credentials: Begin by registering yourself on the centralized portal to acquire login credentials, followed by filling out the application form.

3. Application Submission: Upon self-registration, use the obtained login credentials to access the application form. Different sections are designated for Producers, Brand Owners, and Importers. Complete each section with the required information and upload necessary documents for EPR Registration.

4. Payment of Application Fee: Alongside the application, submit the required application fees using the integrated online payment gateway on the portal.

5. Application Processing: For PIBOs operating in one or two states, their online applications will be forwarded to the respective SPCBs/PCCs via the portal for further processing. Remaining applications will be processed by CPCB.

6. EPR Registration Approval: Authorized officials will process the registration application within 15 days. Applications containing false information or documents will be rejected. Upon verification of completeness, CPCB/SPCB/PCC will issue EPR registration certificates to PIBOs, utilizing a digital signature integrated into the portal.

Sample of a Grant Certificate for PWM

How much cost/fee for EPR Registration of PIBOs/ PWPs?

Fees for EPR Registration in Plastic Waste Management to be Paid by PIBOs/PWPs are as Follows:

Application charges for EPR registration of PIBOs

B) Application Fees for EPR Registration of PWPs

C) EPR Renewal Fees: The renewal fees will be identical to the initial registration fee for EPR.

D) Annual Processing Fees: The annual processing fees will amount to 25% of the Application Fees for EPR.

Validity, Renewal, and Cancellation of EPR Registration

A fresh registration remains valid for a period of one year, while a renewed registration extends the validity to three years. PIBOs must submit their renewal applications, complete with necessary documentation, at least four months prior to the expiration of their registration. The EPR Plastic Waste registration provided to PIBOs may face cancellation or suspension if any submitted documents are discovered to be false.

WHY USE ABSOLUTE VERITAS (AV) FOR EPR FOR PLASTIC WASTE MANAGEMENT?

Absolute Veritas is a prominent organisation from the private sector of India primarily dealing with the Inspection, Testing, Audits, Certification of products& consulting services to various industries in India and worldwide, ensuring compliance with regulatory standards and industry requirements. Offering a comprehensive range of services including product certification, testing, training, auditing, and compliance services, Absolute Veritas helps manufacturers and importers achieve higher production efficiency and quality standards.

Absolute Veritas (AV) will handle end to end pre-registration request, sample preparation, documentation, testing and application process for EPR For PWM Certification

For any questions regarding the most recent update on EPR registration for Plastic Waste Management, please reach out to us via email at cs@absoluteveritas.com

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