Overview of EPR for Plastic Waste Importers

• Encourages Sustainable Practices: Importers are encouraged to use natural packaging that is sustainable and lowers plastic use through EPR to build a more sustainable supply chain.
• Reduces Environmental Impact: By managing plastic waste recycling and collection processes EPR minimizes pollution and ecological harm attributed to plastics.
• Promotes Innovation: EPR promotes businesses to put resources into creative packaging solutions and to create recyclable or biodegradable alternatives to conventional plastics.
• Improves Waste Management Systems: By joining forces with waste management systems through EPR importers measurably boost collection and recycling efforts for plastic waste.
• Legal Compliance and Risk Mitigation: Importers follow EPR rules to evade fines and keep their business running smoothly.
• Boosts Consumer Trust: When importers adhere to EPR regulations they prove their commitment to environmental care and enhance consumer faith and brand affinity.
• Global Market Competitiveness: By following international sustainability standards India’s importers boost their competitiveness in the global marketplace.

Meaning of Important terms-

• End of Life disposal- End of Life disposal refers to the utilization of the plastic waste for generation of energy in which it can be co processed such as in cement kiln or waste to oil or for construction of road as per IRC norms.
• Extended Producer’s Responsibility (EPR)- Extended Producer’s Responsibility (EPR) can be defined as the obligation of a producer to take care of the survival and disposal of the product up to the time of its disposal
• Importer- Importer means any person importing any plastic packaging product or products with plastic carry bags or multi-layered packaging or plastics sheets or alike
• Reuse- Reuse refers to the use of an object or resource material more than once, for the same purpose or another purpose but without altering the structure of the object.

• Category I- Rigid plastic packaging
• Category II- Flexible plastic packaging of single layer or multilayer (more than one layer with different types of plastic), plastic sheets or like and covers made of plastic sheet, carry bags (including carry bags made of compostable plastics), plastic sachet or pouches and
• Category III- Multilayered plastic packaging (at least one layer of plastic and at least one layer of material other than plastic)

Under the Central Pollution Control Boards (CPCB) online centralized portal importers—who are classified as PIBOs (Producers Importers and Brand-Owners)—must register.

Registration with CPCB is required if operating in more than two states. For operations in one or two states, registration with the concerned State Pollution Control Board (SPCB) or Pollution Control Committee (PCC) is necessary.

Importers cannot carry out any business without registration or deal with any unregistered entity.

Action Plan and EPR Target

Importers must provide an Action Plan containing information on their Extended Producer Responsibility (EPR) Target, category-wise and state/UT-wise, through the online portal.

The Action Plan should cover the tenure of their registration as per the Plastic Waste Management (PWM) Rules, 2016.

The EPR target is determined based on the Eligible Quantity (Q2), calculated as:

Q2 = (A + B) – C

Where:

A = Average weight of all plastic packaging material imported and sold in the last two financial years

B = Average quantity of pre-consumer plastic packaging waste in the last two financial years

C = Annual quantity supplied to brand owners in the previous financial year

EPR Targets as a percentage of Q2:

2021-22: 35%

2022-23: 70%

2023-24 onwards: 100%

Collection and Processing-

• To comply with their EPR responsibilities importers need to gather and monitor plastic packaging waste processing.
• They could create collection outlets for themselves or join forces with relevant authorities and waste businesses.

Recycling and End-of-Life Disposal-

1. Recycling Obligations
2. Minimum levels of recycling (excluding end-of-life disposal) of plastic packaging waste:

• Category I: 50% (2023-24), increasing to 80% by 2026-27
• Category II and III: 30% (2023-24), increasing to 60% by 2026-27
• End-of-Life Disposal

3. Only non-recyclable plastics can be sent for end-of-life disposal.
4. Approved disposal methods include road construction, waste to energy, and waste to oil, as per guidelines.

Use of Recycled Plastic Content-

Mandatory use of recycled plastic in packaging:

• Category I: 30% (2023-24), increasing to 60% by 2026-27
• Category II: 20% (2023-24), increasing to 30% by 2026-27
• Category III: 5% (2023-24), increasing to 10% by 2026-27

Reuse Obligations-

For certain categories of rigid plastic packaging, there are obligations to reuse a minimum percentage of packaging.

Annual Returns and Compliance

• Importers must file annual returns on the plastic packaging waste collected and processed by April 30th of the next financial year.
• They need to provide details of recycling certificates from registered recyclers and information on end-of-life disposal.
• CPCB or SPCB/PCC may verify compliance through inspections and periodic audits.

Penalties and Environmental Compensation

• Non-compliance can result in environmental compensation, revocation of registration, or actions under the Environment Protection Act.
• Surplus EPR certificates can be used for offsetting previous year shortfalls, carrying forward, or selling to other entities.

Special Considerations-

• Any recycled plastic used in imported material doesn't count towards fulfilling the obligation.
• Importers must fulfil recycled content obligations by purchasing certificates from other entities who have exceeded their targets.

• Streamlined Registration Process: We simplify the registration process with the Central Pollution Control Board (CPCB) or State Pollution Control Boards (SPCBs).
• All-over Assistance: Apart from registration we help in submission of EPR plan, meet waste management targets, and reporting on compliance.
• Expert Support: Our team of EPR specialists is always available to guide you through complex regulatory requirements and best practices.
• Most Affordable Rates: Whizseed assures most affordable rates for your very compliance.
• One Stop Solution: One you connected with us you don’t need to go anywhere else. We have solutions for all of your compliance requirement.