Overview of EPR Plastic Waste Annual Compliance

• Reduction in Plastic Waste: One last HWP benefits it can spark is through the Extended Producer Responsibility provision since it intends to inspire ANY manufacturers who producing plastics to integrate recyclability features in their products thus reducing accumulation of plastics in the landfills and oceans.
• Cost Efficiency: Promising outcomes of waste management and recycling under EPR can be more efficient financially in the long run when it comes to avoidance of fines and selling recycled products.
• Avoidance of Penalties: EPR compliance offers protection especially on heavy fines and penalties for failing to conform to the general environmental laws.
• Better Corporate Reputation: That conform to EPR are considered as being environmentally friendly this improves the corporate image and brand value among shoppers and investors.

The following plastic packaging categories are covered under EPR:

• 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)

The EPR regulation covers the following with respect to plastic packaging:

1. Reuse

2. Recycling

• Use of recycled plastic content

3. End of life disposal

The following entities shall register on the centralized portal developed by CPCB:

1. Producer (P)

2. Importer (I)

• Brand owner (BO)

3. Plastic Waste Processor engaged in (a) recycling, (b) waste to energy, (c) waste to oil Registration of PIBOs (operating in one or two states) and Plastic Waste processors as per Rule 13(2) and 13 (3) of PWM Rules shall be done by SPCB/PCC through the centralized EPR portal developed by CPCB.

Responsibility of producers, Importers and Brand Owners-

• Producers must develop waste collection systems, involving state urban development departments.
• Producers, importers, and brand owners are responsible for collecting used multi-layered plastic packaging. They must submit collection plans to State Pollution Control Boards.
• Non-recyclable or non-energy recoverable multi-layered plastic should be phased out.
• Producers must apply for registration with Pollution Control Boards.
• Producers cannot manufacture or use plastic packaging without registration.
• Producers must maintain records of plastic raw material suppliers.

Responsibility of waste generator-

• Waste generators must:

1. Minimize plastic waste generation and segregate at source

2. Not litter and ensure proper waste handover to authorized entities

• Institutional generators must segregate, store, and handover plastic waste according to Municipal Solid Waste Rules, 2000
• All waste generators must pay user fees or charges specified by local bodies for plastic waste management
• Organizers of events in open spaces involving food in plastic packaging must segregate and manage waste according to Municipal Solid Waste Rules, 2000

• EPR Registration Certificate - Proof of registration with the Central Pollution Control Board (CPCB) or State Pollution Control Board (SPCB), depending on the jurisdiction.
• Annual Return Filing
• An annual return must be submitted to the CPCB or SPCB detailing plastic waste generated, recycled, or disposed of in compliance with the EPR plan. This may include:

1. Quantity of plastic waste generated

2. Amount of plastic recycled

3. Amount sent for co-processing or waste-to-energy plants

4. Details of plastic waste collected through Producer Responsibility Organizations (PROs) or directly by the company

• Plastic Waste Management Plan: An extensive document outlining the company’s plans for collecting recycling and disposing of the plastic waste produced by its goods.
• Contract or Agreement with Authorized Producer Responsibility Organizations (PROs) or Recyclers: These documents demonstrate how the entity is carrying out its waste management responsibilities.
• The Plastic Waste Audit Report is an audit produced by internal teams or external auditors to confirm that waste management procedures and the EPR plan are being followed.
• Proof of Financial Contribution Proof of financial contributions such as money paid to recyclers waste management firms or PROs toward the collection segregation recycling or disposal of plastic waste.
• Brand Owners Declaration: An affirmation from the owner of the brand attesting to their compliance with EPR regulations and provision of accurate data about plastic waste.
• Certificates of Plastic Credits (if applicable): If the entity uses plastic credits to satisfy its compliance requirements it must provide certificates or other evidence of those credits.
• Environmental Impact Reports (if required): Some organizations might be asked to provide reports or assessments of the environmental effects of their operations particularly with regard to the use and waste of plastics.

• Registration on the Centralized EPR Portal

Step 1: Visit the Central Pollution Control Board (CPCB) or respective State Pollution Control Board (SPCB) EPR portal.

Step 2: Fill in the required details such as company name, category of producer (manufacturer, brand owner, importer), contact details, and production capacity.

Step 3: Submit documents

Step 4: Pay the prescribed registration fee (if applicable) and submit the form.

Step 5: Once approved, you will receive a registration number, which will be required for further compliance steps.

• Categorization of Plastic Waste

Step 1: Identify and categorize the types of plastic waste generated or introduced into the market, as per the Plastic Waste Management Rules 2016 and subsequent amendments.

Step 2: Classify the plastic based on the following categories:

Rigid plastics (e.g., plastic bottles, containers, pipes)

Flexible plastics (e.g., plastic bags, packaging films)

Multi-layered plastics (MLP) (e.g., laminated plastics, packaging for food, personal care products)

Step 3: Assess the amount (in tons or kilograms) of each type of plastic introduced in the market. This data is crucial for calculating your EPR liability.

• Fulfillment of EPR Liability

Step 1: Calculate the total plastic waste introduced by the company during the reporting period (e.g., the previous financial year).

Step 2: Determine the EPR target based on this amount. The government provides guidelines on the percentage of waste that needs to be recycled or managed for each type of plastic (rigid, flexible, multilayered).

Step 3: Fulfill the liability through:

Own waste management system: Set up a system for collection, transportation, and recycling of plastic waste.

Collaboration with PROs (Producer Responsibility Organizations): Partner with authorized agencies that help collect and recycle plastic waste.

Plastic Credit Mechanism: In some cases, companies can purchase plastic credits from certified waste processors to meet their EPR targets.

Step 4: Ensure proper documentation and maintain records of the collection, processing, and disposal of plastic waste.

• Filing Annual Returns

Step 1: Log in to the EPR portal using your credentials.

Step 2: Download the prescribed form for submitting the annual return (Form I for brand owners, Form II for producers/importers).

Step 3: Provide details such as:

Quantity of plastic introduced into the market in the previous financial year (segregated by rigid, flexible, and multilayered plastic)

Quantity of plastic waste collected, processed, and recycled or disposed of.

Proof of recycling or waste management activities undertaken (e.g., certificates from recyclers or waste processors)

Step 4: Submit the return online before the deadline (typically April 30th for the previous financial year).

Step 5: Ensure a copy of the return is sent to the SPCB/PCC, and maintain records for audit purposes.

• We can assist in Registration with portal

1. Seamless integration with CPCB and SPCB portals

2. Guided step-by-step registration process

• EPR Liability Management

1. Automatic calculation of EPR targets based on waste introduction

2. Options to manage liability through:

3. In-house waste management tracking

4. PRO collaboration management

• Annual Return Filing

1. Automated data compilation for Forms I and II

2. Deadline reminders and compliance calendars

• Compliance Monitoring

1. Real-time alerts for upcoming deadlines

2. Compliance status tracking across multiple regions

• Always Compliant: Stay up-to-date with changing regulations and never miss a deadline.