Overview regarding Plastic Waste Processor - PWP Registration under CPCB

According to the new notification of the Central Pollution Control Board (CPCB) under the Ministry of Environment, Forest and Climate Change (MoEF&CC) mandated Plastic Waste Processor - PWP registration under CPCB.The registration can be done on the Centralised Extended Producer Responsibility (EPR) portal and comply with the EPR. According to the amended guidelines, under Section 4, Extended Producer Responsibility is given to the Producers/Importers/Brand Owners (PIBOs) and plastic processors involved in waste to energy, waste to oil, recycling and industrial composting.

Requirements for registration

• The Plastic Waste Processors (PWPs) are not mandated to carry out business without registration via the centralised online portal of the CPCB.
• PWPs are mandated not to deal with stakeholders who are not registered via the centralised Plastic Extended Producer Responsibility portal.
• The total amount of plastic waste required to be handled by the PWP must be made available to the CPCB via their centralised online portal.
• Authorised Plastic Waste Processors are to be granted certificates for plastic waste processing.
• The PWPs are mandated to file annual returns on plastic packing waste handled to satisfy the liabilities under Plastic Waste Management (PWM) Rules and the guidelines provided by the CPCB.

• If the information provided by the PWP is false, he/she shall be debarred by the State Pollution Control Board (SPCB), as per procedure laid down by CPCB, from operating under the EPR framework for one year.

• The PWPs must comply with provisions of PWM rules and conditions prescribed under Consent to Operate (as applicable). Failing which required action as deemed fit shall be initiated against the violator. The environment compensation, as applicable, shall be imposed by CPCB/SPCB/PCC (Pollution Control Committee) on the violators.

EPR Authorisation needed for Plastic Waste Processor

EPR Authorisation for Plastic Waste Processors is governed under Plastic Waste Management Rules, 2016. Processors must file an authorisation application to the centralised portal of the CPCB with the authorised documents. Once the authorisation application is submitted, the concerned PCC or SPCB check the application to validate and scrutinise the documents, following which the processor is provided with the authorisation. 

The registration application needs to be processed within 15 days, within which the pollution control authorities will either grant or reject the authorisation. If the application is not processed within the mandated time, the registration will be generated automatically for the Plastic Waste Processor.

Documents required for acquiring EPR Authorisation

• PAN or Aadhaar card of the authorised personnel
• Flow diagram of the manufacturing procedure
• Consent certificates issued by the concerned Pollution Control Committee/the State Pollution Control Board under the Air and Water Acts
• Authorisation under Hazardous Waste Management Rules granted by concerned PCC/the SPCB
• Geo-tagged photos of raw material production area, storage area, and product dispatch area
• Copy of documents mentioning occupational safety and health aspects
• Geo-tagged photos of plant equipment
• Copy of electricity bill
• Copy of examination report of classification of waste generated
• Details of pollution control measures
• Copy of disaster management plant (onsite/offsite)
• Document concerning any other info which the unit needs to provide
• The authorisation/certification from the respective/applicable state authority for the operating plastic processing unit. The documents required areas follows:
  1. TIN details;
  2. PAN details;
  3. Incorporation certificate;

Registration Cancellation

If the documents mandated to be submitted by the Plastic Waste Processor are discovered to be fabricated at any time, the registration will be considered null and void. Apart from this, if the PWP is found to be violating any provisions of the registration or the guidelines mandated, the notice for the same will be issued by the SPCB/PCC.

To ensure fair chances, the Plastic Waste Processor will be allowed to present their side within fifteen days from the date of notice before making the final call on the cancellation or suspension of the PCC/SPCB. The decision for cancellation will be communicated within ten working days after the hearing. Chairman of Pollution Control Committee/State Pollution Control Board will finally ask the authority to make a call on cancellation or suspension.

Consent Certificates to be obtained by Plastic Waste Processors

CTE (Consent to Establish)is acquired by Plastic Waste Processors before the processing unit is established under the Air and Water (Prevention and Control of Pollution) Act. However, CTO (Consent to Operate)is acquired after the processing unit is established and is ready to start the manufacturing process under the same Acts.

The certification process for both consent certificates is identical. The authorisation form is submitted via the concerned Union Territory PCC/the SPCB with the required documents, followed by a review of an application. Once the documents are analysed, in the case of the CTO, a government official of state authorities conducts a site inspection and makes the report accordingly. The consent certificate is granted to the Plastic Waste Processor upon analysing the report.

Documents required for consent certificate

• The Aadhaar card
• Water usage breakdown
• SSI certificate
• Processing unit department certificate
• The layout plan/site plan
• Product/by-product list with daily MTD/monthly quantity
• Details on channelization
• Permission from the state's groundwater authority
• Total open land
• Total constructed area
• The project report
• Effluent/Sewage Treatment Plant flow diagram
• Boiler type, fuel used, and quantity
• Authorisation letter
• Raw material list with daily MTD/monthly quantity
• Specifics on air pollution controls
• Factory/Trade License
• PAN card
• Municipality or processing unit license
• Registration proof of the unit
• Site plan
• Water bill

To get authorisation for environmental compliances, the Plastic Waste Processor has to acquire general business licenses and authorisation from the concerned governmental authorities. A few of these licenses are: -

Company license

Documents required for establishing the company

• PAN card
• Address proof such as
  1. Passport
  2. Election card or Voter Identity card
  3. Ration card
  4. Driving license
  5. Electricity bill
  6. Telephone bill
  7. Aadhaar card
• Residential proof such as
  1. Bank statement
  2. Electricity bill
  3. Telephone bill
  4. Mobile bill
• GST registration certificate
• MOA (Memorandum of Association)
• AOA (Article of Association)

Factory license acquired by Plastic Waste Processors

To establish their manufacturing units, Plastic Waste Processors must list their business under Factories Act. As per theact, processors are mandated to get a factory license, which the Chief Inspector of the Labour Commissioner Organisation approves after examining the Plastic Processing site.

Documents needed by Plastic Waste Processor

For the factory license, Plastic Waste Processorsrequirethe following documents: -

• Form 1
• MOA
• Aadhaar card
• Layout plan/site plan
• List of directors
• AOA
• Partnership deed
• Account details
• Commencement date
• Payment receipt
• Land deeds
• Consent form from SPCB/PCC
• Details of hazardous and non-hazardous waste
• Tax receipt

Udyog Aadhaar MSME Registration

To establish a processing unit, the Plastic Waste Processor is mandated to acquire Ministry of Micro, Small and Medium Enterprises (MSME) registration. PWP must register through the MSME's centralised online portal with the authorised documents. 

Documents needed for MSME registration

• Applicant'sofficial name
• NIC code
• Account details
• Name and type of enterprise
• Aadhaar card
• PAN card
• The social category of the applicant
• The business operations of the enterprise
• Date of incorporation of a business
• Details related to employment

Hazardous Waste Authorisation

The registration relating to the establishment or transboundary or cross-country movement of hazardous waste that includes the establishing Plastic Processor Unit is regulated under The Hazardous Wastes (Management, Handling and Transboundary Movement) Rules, 2008. For authorisation,the PWPmustapply under Form 1 to the concerned SPCB's website to acquire the authorisation.

Documents required for submission

The documents which are compulsory while applying for hazardous waste authorisation are: -

• CTO
• Certificate of incorporation (CIN)/LLP
• CTE
• MOA (Memorandum Of Association)
• AOA (Article of Association)
• Board resolution for appointing an authorised person
• Aadhaar card
• PAN copy
• Layout plans
• GST certificate of business
• Rent/proof of ownership

Factory license/Trade license

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