Which Plastic Packaging Category Needs EPR Registration in India?

India is at a crossroads in its battle against plastic pollution. With a population of over 1.3 billion and a growing economy, the country faces significant challenges in managing its plastic waste.

Plastic packaging, in particular, has emerged as a major contributor to environmental degradation. Its disposal poses serious threats to ecosystems and human health.

In response to this pressing issue, India has adopted Extended Producer Responsibility as key policy tool to tackle plastic waste.

Understanding which categories of plastic packaging require EPR Certificate is essential for effective waste management and environmental conservation.

Let's discover about these categories and know why EPR Registration for P-waste is important in India.

What is EPR Registration for Plastic Waste Management?

Extended Producer Responsibility (EPR) for plastic waste management entails the accountability of any organization involved in introducing plastic packaging into the consumer market. This responsibility extends throughout the lifecycle of the plastic packaging, requiring the entity to manage it in an environmentally responsible manner until its end-of-life.

The Ministry of Environment, Forestry and Climate Change (MoEF&CC) delineates the procedures for EPR Authorization in the Plastic Waste Amendment Rules 2022, wherein the Central Pollution Control Board (CPCB) administers EPR authorizations to producers, importers, brand owners (PIBOs), and plastic waste processors. These authorizations are granted for various activities such as recycling, waste to energy, waste to oil, and industrial composting.

Complying with EPR Authorization mandates is imperative for organizations involved in the production and management of pre- and post-consumer plastic packaging waste, with registration required both at the central level with the CPCB and at the state level with the State Pollution Control Board (SPCB). The EPR Authorization process is a prerequisite for commencing manufacturing activities, as stipulated in the Plastic Waste Management (Amendment) Rules 2022.

According to these rules, PIBOs are mandated to submit Form I and an Action Plan meeting the standards outlined in the Environmental Protection Act, 1986, to secure EPR registration. The MoEF&CC serves as the regulating authority for plastic waste management in India, mandating EPR certification for any entity introducing plastic waste into the market under the PWM Rules 2016. The recent guidelines by the CPCB expand the scope of EPR obligation to cover all entities utilizing plastic packaging in their operations, irrespective of their turnover or scale, necessitating EPR certification tailored to the nature of their business activities.

Which Categories of Plastic Packaging Require EPR Registration in India?

Various categories of plastic packaging necessitate EPR Registration in India, as outlined below:

Category I: Rigid Plastic Packaging

This classification encompasses plastic packaging characterized by its unyielding nature. Examples include plastic bottles, containers, and boxes, which typically maintain their shape and do not bend easily.

Category II: Flexible Plastic Packaging

This category encompasses plastic packaging that is flexible and capable of being bent or folded. It includes both single-layer and multi-layer packaging, with the latter comprising multiple layers of plastic, often of different types. Common examples include plastic bags, wrappers, and certain types of pouches.

Category III: Multi-layered Plastic Packaging

Packaging falling into this category consists of at least one layer of plastic and at least one layer of non-plastic material. These complex packaging materials combine plastic with other materials for various purposes, presenting challenges in recycling and disposal.

Category IV: Plastic Sheets and Compostable Plastic Carry Bags

This category includes plastic sheets utilized for packaging purposes, as well as carry bags fabricated from compostable plastics. Compostable plastics are engineered to decompose into natural substances within a compost environment, offering an environmentally friendly alternative to conventional plastic materials.

What is the Necessity of EPR Registration for P-waste?

In India, EPR registration for plastic waste is mandatory, reflecting the urgent need to address plastic pollution and promote sustainable waste management practices. Here are some reasons highlighting the requirement of EPR Authorization for P-waste:

● Encourages producers to take responsibility for the entire lifecycle of their products, including post-consumer disposal.

● Promotes the adoption of eco-friendly packaging designs and materials to minimize environmental impact.

● Facilitates the development of recycling infrastructure and technologies to manage plastic waste effectively.

● Reduces the burden on local authorities and taxpayers by shifting the responsibility of waste management onto producers.

● Fosters a circular economy approach where resources are reused, recycled, or

repurposed, minimizing waste generation and conserving natural resources.

Who is Eligible to Apply for EPR Registration for Plastic Waste?

Entities eligible to apply for EPR registration for plastic waste management include:

● Producer (P)

● Importer (I)

● Brand Owner (BO)

● Plastic Waste Processor (PWP) engaged in recycling, waste to energy, waste to oil, and industrial composting.

What are the Responsibilities of PIBOs under EPR in India?

The responsibilities of Producers, Importers, and Brand Owners (PIBOs) under Extended Producer Responsibility in India are outlined as follows:

Registration on the EPR Portal: PIBOs are required to register on the designated EPR website to initiate their compliance with EPR regulations.

Submission of Action Plan: PIBOs must develop and submit an Action Plan detailing their strategies and commitments for managing plastic waste responsibly.

Compliance with Obligations for:

● Recycling

● Use of Recycled Content

● Reuse

● End-of-Life Disposal

● Optional Engagement in Collection and Recovery

Submission of Annual Returns: PIBOs are obligated to provide annual reports detailing their activities and achievements in managing plastic waste, including recycling rates, use of recycled content, and any other relevant metrics.

Provision of Proof of Certificates (Plastic Credits): PIBOs must furnish evidence in the form of certificates, such as Plastic Credits, to demonstrate their compliance with EPR regulations and their effective management of plastic waste.

What is the Procedure of Obtaining EPR Registration Certificate for P-waste?

The procedure for obtaining an EPR Certificate for P-waste in India involves the following steps:

Step 1: The entity seeking EPR registration must gather and prepare all necessary

documents required for the application process.

Step 2: The applicant submits the completed application form along with the requisite documents to the appropriate regulatory authority.

Step 3: The regulatory authority reviews the application to determine the eligibility of the applicant for the registration.

Step 4: Upon successful evaluation of the application, the regulatory authority issues an EPR Registration Certificate to the applicant, authorizing them to undertake responsibilities related to plastic waste management.

What Documents are Important to Get EPR Certificate for P-waste?

To obtain an EPR certificate for plastic waste management, the following documents are crucial:

● Copies of PAN and Aadhar Card of authorized persons, duly signed and stamped.

● The official email address of the company.

● Certificate indicating Micro, Small, and Medium Enterprise (MSME) status, if

applicable.

● Digital copy (JPEG format) of the signature of the authorized person.

● Contact number for OTP verification during the application process.

● Selection of states or union territories where the importer operates.

● Total capital invested in the project, stated in crores of rupees.

● Photographs showing the packaging material used in the business operations.

● Copies of purchase orders and invoices for the last two financial years.

● Information on the total number of container imports in a year, if applicable.

Conclusion

In conclusion, as we navigate the complex landscape of plastic packaging in India, it's evident that EPR registration is a crucial step towards sustainable waste management practices.

At Brand Liaison, we understand the significance of EPR registration and the challenges businesses face in obtaining certification. As a leading compliance consultancy, we are committed to assisting businesses in navigating the intricacies of the EPR process, facilitating seamless and efficient acquisition of EPR certificates.

Our expertise and tailored solutions empower businesses to meet regulatory requirements, promote environmental stewardship, and contribute to a cleaner, greener future for India.