Overview of Extended Producer Responsibility
Extended Producer Responsibility involves employing financial incentives to motivate manufacturers to craft eco-friendly products, holding them responsible for overseeing product management in the final stages of consumption. It distinguishes itself from product stewardship in that it alleviates the government from overseeing specific products, instead making manufacturers shoulder the recycling costs within the product's price.The CPCB, which is the nodal pollution control authority, is supervising the implementation of EPR in the entire country, along with the assistance of SPCBs/PCC. CPCB is managing dedicated centralised EPR portals for the registration of businesses that fall under the ambit of EPR. The E-Waste Management Rules, 2022; Plastic Waste Management Rules, 2016; the Hazardous Waste Management Rules, 2016 and the Battery Waste Management Rules, 2022, lays down the modalities of EPR in plastic packaging, e-waste, used tyres and end-of-life batteries, respectively. The identified entities must fulfil their respective EPR obligations to keep operating in the country. The portal works as a single-point data repository for registration, submission of data related to their operation/ trading of EPR certificates and submission of annual returns. The respective waste management rules also include providing heavy environmental compensation, surprise inspection by agencies, and cancellation of their CTO/ closure of the facility. From April 2024, EPR will also be implemented in oil and lubricant manufacturers, importers and collection centres.
EPR Guidelines under PWM Amendment Rules 2022
According to the EPR Guidelines for plastic packaging issued by the CPCB, as outlined in the Plastic Waste Management (Amendment) Rules of 2022, dated February 16, 2022, there are specific directives in place. These guidelines establish compulsory targets concerning Extended Producer Responsibility (EPR), recycling plastic packaging waste, the reutilization of inflexible plastic packaging, and incorporating recycled plastic material. These guidelines aim to advance towards sustainable plastic packaging and diminish the ecological impact associated with plastic packaging.
EPR obligations are designed on the principle that those who own the brand possess significant control over product design, allowing them to create products with reduced adverse environmental impacts. This concept includes reusing, facilitating product buyback, or engaging in recycling initiatives. Manufacturers can also delegate this duty to a third party, with costs potentially borne by them for managing used products. This transfer of waste management responsibility shifts the onus from the government to private industries, streamlining the process for producers or sellers to internalise waste management practices and ensure responsible merchandise handling.
Furthermore, the Government of India extends supplementary central support to the States/Union Territories through the Swachh Bharat Mission. This support is aimed at bolstering solid waste management, which encompasses plastic waste management as per the program's outlined guidelines. This initiative addresses both urban and rural regions of the nation.
Process of Obtaining EPR Authorisation
To obtain EPR Certification, Producers, Importers, Manufacturers, and Brand owners need to apply to the Central Pollution Control Board (CPCB). Once the application is submitted, the CPCB has 25 days to review and evaluate the provided documents carefully. This includes cross-checking and investigating the details provided.
After thoroughly examining the submitted documents and ensuring their alignment with the EPP plan, the Pollution Control Board grants the EPR registration and the respective EPR targets to different businesses covered under E-Waste, Plastic Waste, Battery Waste, and Tyre Waste rules.
Documents required for EPR Authorisation
The essential documents needed at the time of EPR Authorization include:
- Valid proof of the producer's or importer's address
- A copy of the GST certification displaying the business location's address
- A copy of the business certification issued by entities such as ROCs, Directorate of Industries, Local Bodies, or DGFT
- Copy of the relevant Certificate or Document
- Detailed information about the products, including batch numbers and model numbers
- A comprehensive record of electronic goods introduced to the market over the past ten years presented chronologically with quantities, numbers, weights, etc.
- Valid BIS registration
- Copy of ISI mark or BIS registration number, if applicable
- Information concerning compliance with the Reduction of Hazardous Substances (RoHS)
- Estimation of Waste Electrical and Electronic Equipment or WEEE generation
- Extensive EPR plan outlining collection methods, e-waste handling procedures, website details, etc.
- Budget allocation for accumulation and waste disposal schemes
- Self-declaration affirming RoHS compliance
- The official authorisation provided by the relevant department/ministry to sell the respective product.
- Copies of agreements with dealers, collection centres, and recyclers
- Copy of agreement with TSDF
- Copy of agreement with PRO
Benefits ofExtended Producer Responsibility for PIBOs
The advantages of Extended Producer Responsibility are as follows:
- Manufacturers can receive financial incentives to create more ecologically sustainable and considerate products, particularly when they confront the economic or practical challenges associated with recycling their goods.
- Adopting strategies that employ fewer resources and extend product lifespans can directly minimise the eventual expenses producers bear.
- As the EPR concept gains wider acceptance, it exerts increased pressure on nations engaged in waste export. This, in turn, discourages the continuation of waste export practices and compels these countries to invest in their recycling infrastructure.
How can Enterclimate assist you?
Owing to our extensive experience of over ten years in the field of Environmental aspect-related clearances, our team of professionals will provide comprehensive assistance in registration process and point out the compliance required as EPR obligation.
Expert Legal Guidance
Enterclimate provides complete legal support services for Extended Producer Responsibility, including legal advice, through a customisable package that can be customised as per the priorities and needs of our clients.
Best-in-Class Client Support
Our dedicated network of licencing and compliance experts ensures that our clients are kept up to date with the latest guidelines and updates from relevant government departments regarding Extended Producer Responsibilityand other relevant monitoring guidelines.