EPR For Plastic Packaging

Registration and Thereafter

What is EPR for Plastic Waste

Plastic Packaging Waste is known to cause an adverse impact on the environment when littered and left unmanaged. The Central Pollution Control Board(CPCB), in its annual report of 2020-2021 regarding implementation of Plastic Waste Management Rules, 2016, quoted that plastic waste generated in India is 4,126,997 TPA.

Extended Producers Responsibility (EPR) for Plastic Waste is a defining step to channelise unregistered plastic waste and ensure recycling, reuse and use of recycled plastic content. As per Plastic Waste Management Rules, 2016, Producers, Importers and Brand Owners (PIBOs) are required to register on the centralised EPR portal under CPCB and fulfil EPR targets. Till date, over 18000+ entities have registered on the portal and are compliant with norms.

Significantly, a total plastic packaging of 2.26 million tonnes in FY 2022-23 has been covered through Plastic Waste Processors.

Comprehensive Guidelines on EPR for Plastic Waste

Extended Producer Responsibility is now not just rules on paper but a Compliance norms implemented full-fledgedly.

For PIBOs:
If you are a Producer, Importer or Brand Owner(PIBO) that produces plastic packaging or uses it for your products, here’s a step-by-step guide:
 

  1. Registration:
    1. Sign-up on EPR portal
    2. Submit Documents of Company
    3. Declare Plastic Packaging Data for 2 Financial Years
    4. Get EPR targets and EPR Certificate will be generated
  2. EPR Target Fulfilment
    Every registered PIBOs are required to fulfil the EPR targets before 30th June of every Financial Year
    1. Buy EPR credits from a registered PWP (only those registered on CPCB portal)
    2. Once the credits reflect on your wallet, fulfill your EPR target
    3. Pay annual filing fee
  3. Other Post Registration Operations:
    1. Uploading annual Sales and Purchase Data
    2. Uploading e-GST invoices
    3. Generate EPR target for next year

Plastic Waste Processors(PWP) under EPR
Plastic Waste Processors(or Recyclers) play a crucial role in realising the circular economy model of EPR. Under EPR Guidelines, PWP/PWRs will be incentivised to ensure that the plastic packaging waste generated are recycled or put to end-of-life.

PWPs covered under EPR for Plastic Waste:
  1. Plastic Waste Recycling
  2. Co-Processing in Cement Kilns
  3. Waste to Energy
  4. Waste to Oil
  5. Industrial Composting
Step -by- Step Guide:
  1. Registration
  2. Post Registration Operation for PWPs : Portal Management
  3. EPR Credit Transfer
How We Support PIBOs and PWPs:
The Trash Co. extends support on EPR compliance for Plastic Packaging to Producers, Importers, Brand Owners (PIBOs) and PWPs in a range of ways. We have a dedicated expert team for both PIBOs and PWPs to guide on EPR Compliance norms.
 
  1. End-to-End EPR Support
    1. Understanding Your Requirements
    2. Collation and Verifying Checklist of Documents for EPR Portal
    3. Registration and Obtaining EPR Certificate
    4. Post Registration Operations
    5. Annual Filings
    6. Any kind of follow up with CPCB notice or issues on portal
  2. Support and guidelines to reduce PIBO’s EPR Liabilities
Case Study
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FAQs

EPR target is the plastic waste which is introduced in the market by the PIBO

The Micro & Small category of Brandowners are exempted from fulfilling EPR obligation. Also, the Export Oriented Units are exempted from EPR fulfillment obligations
The Growing Concerns of E-Waste Management

The rapid advancements in Electrical and Electronic Equipments has posed mounting concerns on the environment and health. Mismanagement and mishandling of e-waste by the informal sector is a major point of concern today. India stands as the third largest e-waste generator with 3.230 Million Metric tonnes of waste generated.

What is EPR Registration for E-Waste?

EPR for E-waste regime is a corrective measure to channelize e-waste recycling from the informal sector to the formal sector and ensure the recycling process is carried out in an environmentally Sustainable manner.

It has been introduced under E-Waste (Management) Rules, 2016. Subsequently, E-Waste (Management) Rules, 2022 has been notified in November, 2022 and enforced since 1st April, 2023.

This framework mandates that every Manufacturer, Producer, Refurbisher, Dismantler and Recycler involved in manufacture, sale, transfer, purchase, refurbishing, dismantling, recycling and processing of e-waste or electrical and electronic equipment listed in Schedule I, shall register on the EPR portal maintained by CPCB.

What is Electronic-waste(E-waste)?

Electronic-Waste, also known as E-waste refers to the electrical and electronic equipment(EEE), including solar photo-voltaic modules or panels or cells, whole or in part discarded as waste, as well as rejects from manufacturing, refurbishment and repair processes

Salient Features of E-Waste (Management) Rules, 2022:

  1. Mandatory for all the Manufacturer, Producer, Refurbisher, Dismantler and Recycler to register on EPR Portal

  2. Unregistered entities to not carry out any business

  3. No entity to deal with any unregistered entity

  4. Targets: Annual E-Waste Recycling targets to be given to producers of EEE based on the generation from the previously sold EEE or based on sales of EEE as the case may be.

  5. Measure to avoid false claim: The quantity recycled to be computed on the basis of end products

  6. Environmental Compensation: Entities not registered on the portal as directed and non-compliance could attract penalty known as Environmental Compensation

What Next if You Are Mandated to Follow EPR E-waste Mandates?

If you find yourself mandated to adhere to EPR (Extended Producer Responsibility) E-Waste mandates, it becomes crucial for you to understand the framework and follow the necessary guidelines. We are here to guide you through the process seamlessly.

Policy Guidance from Our Compliance Expert Team: Our team of compliance experts provides comprehensive policy guidance on EPR, ensuring that you understand the requirements and obligations under the regulations.

End-to-End Support on Registration to Fulfilment of Your EPR Targets: From registration on the dedicated EPR portal to meeting your e-waste recycling targets, we offer end-to-end support to streamline your compliance journey.

Navigation through Any Complexities in Aligning Your Company with Environmental Compliances: Navigating through environmental compliances can be challenging. However, with our assistance, you can navigate through any complexities and align your company with environmental regulations effectively.

Ready to Get Started? Contact us today to learn how our services can help you navigate EPR e-waste mandates efficiently and ensure compliance while contributing to a sustainable future.

FAQs

Any person or entity repairing or assembling used electrical and electronic equipment as listed in Schedule-I for extending its working life, and selling them in the market

Two years from the end of the financial year in which EPR Certificate for E-Waste was generated

The importers of used electrical and electronic equipment have 100% EPR obligation for the imported material after end of life, if not re-exported.

Registration on the E-Waste EPR Portal is not Required in the following cases:
a) If import of EEE is not listed in Schedule-I of E-Waste (Management) Rules, 2022
b) If import of EEE is for the purpose of selling to Registered Producers
c) Self-Use(Not for Sale)
d) Captive consumption for manufacturing and selling to Producers

Solar photo-voltaic modules or panels or cells are excluded from e-waste recycling targets.
What is EPR for Battery?

Batteries today have grown in importance like never before. The Portable, Automotive, Industrial and Electronic Vehicle Batteries continue to serve as a viable source of energy reigning across different sectors. With developments around Electric Vehicles (EV) as an opportunity to decarbonise transportation, it presents huge market scope for batteries. However, it also calls for management of battery waste responsibly.

As a transformative step to ensure sustainable management of battery waste, the Ministry of Environment Forest and Climate Change notified Battery Waste Management (BWM) Rules on 22nd August, 2022 as per which every producer and person or an entity involved in manufacturing of battery shall have to register with CPCB.

Under EPR(Extended Producer Responsibility) (EPR) Obligation for the Battery, it is a mandate for Producers to ensure the attainment of recycling or refurbishing of batteries introduced in the market. It is IMPORTANT EPR is fulfilled through certified waste battery recyclers to meet assigned EPR targets.

Batteries of all types, viz. Electric Vehicle batteries, portable batteries, automotive batteries and industrial batteries are covered.

Are you Covered?

If you are a Producer, Importer, Dealer, or Recyclers/Refurbishers of Waste Battery, then you are covered under the BWM Rules, 2022.

  • Producer has the obligation of Extended Producer Responsibility (EPR) for the Battery that they introduce in the market to ensure the attainment of the recycling or refurbishing obligations.

  • Producers are required to fulfil their EPR obligation by ensuring that waste battery is recycled through certified waste battery recyclers to meet assigned EPR targets.

  • They shall obtain EPR certificates from recyclers according to the quantity of waste batteries recycled by recyclers and use such certificates to meet their EPR targets.

On Non-Compliance,

  1. Environmental compensation will be imposed in line with the Polluter Pays Principle.

  2. Entities have been directed to not deal with unregistered companies

Who are Producers under EPR Battery?

Producer' include those entities who engage in:

  1. manufacture and sale of Battery including refurbished Battery, including in equipment, under its own brand; or

  2. sale of Battery including refurbished Battery, including in equipment, under its own brand produced by other manufacturers or suppliers;

  3. import of Battery as well as equipment containing Battery.

What do you need to do?

It is important for entities covered under EPR Battery to stay in line with BWM Rules, 2022 to avoid any hurdles in their business process. At the same time, staying up-to-date with CPCB guidelines will help businesses prepare for any changes that could impact your business at the earliest opportunity. We take the ownership to keep our Clients informed through our regular newsletter on the website.

Application Process for Producers:

  1. Account creation on CPCB portal

  2. Registration process with necessary documentations

  3. Generation of EPR Battery Credits based on sales data by the portal

  4. Certification on successful submission.

  5. Annual Filing Process

If you are Recyclers/Refurbishers

The entire ecosystem of EPR goes incomplete without Recyclers/Refurbishers. The objective to manage battery waste in an environmentally sound manner can be achieved through recyclers and refurbishers. It has been directed to ensure waste batteries are recycled through certified waste battery recyclers/refurbishers.

Steps for Recyclers/Refurbishers:

  1. Account creation on CPCB portal

  2. Registration with concerned SPCB through the portal

  3. Documentation Works including furnishing quarterly returns

  4. Issuance of EPR Certificates to Producers.

WE ARE HERE TO SUPPORT YOU

If you are a Producer or Recycler/Refurbisher, we can support you through,

  1. Policy guidance on EPR from our Compliance Expert Team

  2. End-to-End Support on Registration to fulfilment of your EPR targets.

  3. Navigation through any complexities in aligning your Company with Environmental Compliances

What is EPR for Tyre?

Extended Producer Responsibility (EPR) for tyres is a policy approach that holds producers responsible for the entire lifecycle of their products, especially for take-back, recycling, and final disposal. This means that manufacturers, importers, and retailers of tyres are obligated to manage the waste generated from their products.

Overall, EPR for tyres aims to create a more sustainable system for managing tyre waste, reducing environmental impact, and promoting circular economy practices.
 

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