Who Needs to Register for EPR?

If you are a PIBO engaged in operations in India that involve plastic packaging, you must register for EPR, irrespective of your business size or revenue. This includes:

• Producers
• Importers
• Brand Owners
• Plastic Waste Processors involved in recycling, waste-to-energy conversion, waste-to-oil processing, and industrial composting.

Registration Requirements

• Single-State Operations: PIBOs operating in one or two states/UTs must register with the respective State Pollution Control Boards (SPCBs).
• Multi-State Operations: PIBOs operating in more than two states/UTs must register with the Central Pollution Control Board (CPCB).

Responsibilities of PIBOs

PIBOs have a range of obligations under the EPR framework, which include:

1. Registering on the EPR Portal: All PIBOs must register on the centralized EPR portal established by the CPCB.
2. Submitting an Action Plan: PIBOs must outline a detailed action plan for managing plastic waste, specifying how they will meet EPR targets.
3. Fulfillment of Obligations:
• Recycling of plastic waste
• Incorporating recycled content into products
• Reusing plastic materials
• Responsible end-of-life disposal of plastics
• Optional involvement in the collection and recovery of plastics
4. Annual Reporting: PIBOs must submit annual returns detailing their compliance with EPR requirements.
5. Plastic Credits: Providing proof of certificates (plastic credits) to demonstrate compliance with waste processing targets.

PIBOs can collaborate with Producer Responsibility Organizations (PROs) or other agencies to meet their obligations, but the overall responsibility for compliance remains with the PIBO.

Categories of Plastic Packaging Under EPR

EPR applies to various categories of plastic packaging, including:

1. Rigid Plastic Packaging
2. Single-layer or Multilayer Flexible Plastic Packaging: This includes products like plastic sheets, carry bags, and pouches.
3. Multi-layered Plastic Packaging: Comprising at least one layer of plastic and one layer of a different material.
4. Compostable Plastic Packaging: Including compostable plastic carry bags and sheets.

Documents Required for EPR Registration

To obtain EPR registration, PIBOs and PWPs must prepare the following documents:

• PAN, GST, and CIN: Company registration details.
• IEC: Importer Exporter Code for importers.
• Aadhar/PAN of the Authorized Person: Identification for the responsible individual.
• DIC Registration: If applicable, for units registered with the District Industries Centre.
• Process Flow Diagrams: Required for producers and PWPs.
• SPCB/PCC Consents: If the unit has a production facility.
• Signature Samples: Scanned copies of authorized persons' signatures.
• Covering Letter: A formal request for registration.
• Geo-tagged Photos: Images of storage areas, production facilities, and machinery (for PWPs).
• Additional Information: Any other relevant documents or information.

EPR Registration Process for PIBOs/PWPs

Step-by-Step Guide to EPR Registration

1. Documentation Preparation: Ensure you have all necessary documents in PDF, JPG, or PNG format ready for submission.
2. Self-Registration on the EPR Portal: Start the application process by registering on the centralized portal to obtain login credentials.
3. Application Submission: After obtaining login credentials, fill out the application form specific to your category (Producer, Brand Owner, or Importer). Upload all relevant documents.
4. Application Fee Payment: Pay the application fee online through the portal’s integrated payment gateway.
5. Application Processing:
• If operating in one or two states, the application will be forwarded to the respective SPCBs for processing.
• For multi-state operations, the CPCB will handle the processing.
6. Grant of EPR Registration: The registration application will be reviewed and processed within 15 days. If all information is accurate and complete, the CPCB/SPCB/PCC will issue the EPR registration certificate using a digital signature.

Validity, Renewal, and Cancellation of EPR Registration

• Validity: Newly issued registrations are valid for one year. Renewed registrations are valid for three years.
• Renewal Process: Submit the renewal application along with required documents four months before the registration expiry.
• Cancellation: EPR registrations can be canceled or suspended if it is found that false information or documents were submitted.

The EPR framework for plastic waste management represents a significant step towards sustainable environmental practices in India. PIBOs must be proactive in their compliance efforts, ensuring responsible management of plastic waste. By understanding their responsibilities and the registration process, PIBOs can contribute to a cleaner, more sustainable future.

Prohibited Single-Use Plastic Items in India

Effective July 1, 2022, the following single-use plastic items are banned under the Plastic Waste Management (Amendment) Rules, 2021:

• Earbuds with plastic sticks
• Plastic sticks for balloons
• Plastic flags
• Candy and ice cream sticks
• Thermocol (polystyrene) used for decoration
• Plastic plates, cups, glasses, forks, spoons, knives, straws, trays
• Wrapping films around sweet boxes and invitation cards
• Plastic cigarette packets
• Plastic/PVC banners less than 100 microns
• Stirrers