Overview of EPR Authorisation for Plastic Waste Management

Extended Producer Responsibility or EPR is the responsibility assigned to any entity that introduces plastic items into the consumer market. EPR mandates the entity to manage plastic items in anenvironmentally sound manner until the end of their life.The Ministry of Environment, Forest and Climate Change (MoEF&CC) announced Plastic Waste Amendment Rules 2022 and laid down instructions forEPR Authorisation given by the Central Pollution Control Board (CPCB) to the Producer, Importers and Brand Owners (PIBO) along with Plastic Waste Processor engaged in recycling and other activities (waste to energy, waste to oil, and industrial composting).

EPR Authorisation aims to promote the reuse, recycling and integration of recycled plastic into production and end-of-life disposal of plastic products.EPR compliance is mandatory for all the above entitiesgenerating pre and post-consumer plastic packaging waste. It isvital to get registration from CPCB/ SPCBs/PCCs depending on the extentof their operation. For example, the PIBO will have to receive registration from CPCB if it operates in more than two states or UTs. If the PIBO operates in only one or two states or UTs, the registration must be obtained from the respective SPCB/PCC. Notably, the EPR Authorisation needs to be obtained beforethe commencement of production. The PIBOs are required to apply for registration in Form I along with an Action Plan deemed fit under Environment Protection Act, 1986 and meet all prerequisites as per the latest guidelines mentioned under Plastic Waste Management (PWM) (Amendment) Rules, 2022.

Importance of EPR Authorisation for Plastic Waste Management Business

With the PWM Amendment Rules 2022, some new guidelines were laid for the PIBOs to promote a circular economy and discourage the use of single-use plastic. One of them was to obtain EPR Authorisation for effectively managing plastic waste. Additionally, some other significantchanges brought in the amended rules include

• Four new plastic packaging categories(Category 1,2, 3 and 4)have been introduced that must be covered under Extended Producer Responsibility. Also, recycling, reuse, use of recycled plastic content and end-of-life disposal have been identified as the crucial components of EPR. Specific targets have been introduced in each of the aboveelements for PIBOs.
• From now onwards, PIBOswill not be relieved of their EPR targets by simply paying compensation for the non-fulfilment ofthe target. If the targets are not met,they will be carried forward to subsequent years for up to 3 years.
• A list of PIBO-wiseactivities will be compiled by the SPCB in the state as per their EPR action plan and shared in the public domain. SPCB/PCC will validate information provided by State Nodal Agency and PIBO and submit it to the CPCB.
• A provision to sell surplus EPR certificates among the PIBOshas been introduced. If a PIBO or plastic waste processor falls short of the target, it can purchase certificates of equivalent quantity from PIBOs who have recycled more than their obligation.

Importance of Extended Production Responsibility Action Plan in EPR Authorisation Process

EPR Action Plan is the soul of your application for getting EPR Authorisation for Plastic Waste Management. EPR Action Planhas to be carefully made and submitted by PIBOs (those operating in more than two states) to obtain registration from CPCB. PIBOs must fulfil EPR in all the States/UTs they are introducing their products. EPR target for a particular State/UT should be equal to the type &amount of plastic introduced in the market (post-consumer waste) in that specific state. The format of the action plan and the quarterly report has to be as per Annexures 1 and 2 given in the SOP for PIBOs issued by the CPCB.

Documents needed for EPR Authorisation for Plastic Waste Management Business

The main documents required to obtain EPR Authorisation for Plastic Waste Management Business are

• Proof showing sale in more than two states (GST/ tax invoice and so on)
• ERP Plan providing necessary details
• Copy of permission from concerned Department/Ministry for selling the product
• Copies of agreement with collection centres
• Copies of agreement with dealers
• Copies of agreement withTreatment, Storage, and Disposal Facilities (TSDFs) (in case of CEEW5)
• Copies of agreement with dismantlers/recyclers
• Self-declarations on Restriction of Hazardous Substances Directive (ROHS)
• Copy if DGFT permission/licence (IEC (International Electrotechnical Commission) certificate)
• Copy of agreement with PRO

REGISTRATION PROCESS SECTION 

Mandatory Half-yearly Progress Report for PIBOs

PIBOs must submit half-yearly reports to SPCB/PCC by giving statements on plastic waste collection and its utilisation during the last six months. The validation of the report may be done through Form IV submitted by the recyclers/ and Form V submitted by Urban Local Body (ULBs)/ field inspector etc.

Renewal of EPR Authorisation 

The renewal will be based on the compliance status received by the CPCB from SPCB/PCC, subject to the submission of the half-yearly progress report.A renewedregistration is valid for three years and is issued within 15 days. Renewalrequests, however, must be made four months in advance of the expiry of the present certificate.

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