A Practical Approach To EPR Plastic Waste Reporting For FMCG

Extended Producer Responsibility (EPR) is a paradigm shift in how we conduct business and commerce. Traditionally, the responsibility to collect waste and ensure its disposal stayed in the hands of consumers and local governments. However, in a remarkable move, the government delegated this power or obligation to the producers and importers. EPR is a strategic multi-dimensional approach that aligns with the principles of sustainability and circular economy.

To restrict the trade of waste, several economies introduce import restrictions. For instance, China in 2018 imposed a ban on import of several items including plastic waste. Several of the FMCG companies that produced plastic goods or had plastic packaging, suffered from this restriction. Thus, it became crucial for businesses to commence addressing their polluting strategies and implement eco-friendly design practices through EPR.

Let’s understand the various processes in EPR registration, regulations on Recycling plastic waste under EPR, and obligations, among others.

What are the Steps in the EPR Reporting Process?

Under the EPR, there is no one-size-fits-all approach. The rules specify different requisites for different companies operating either in one or more than one location. For instance, producers, importers, and brand owners (PIBOs) who operate in one or two states or Union Territory are mandated to register with the respective State Pollution Control Boards (SPCBs). However, PIBOs who are conducting their business in more than two states are required to register with the Central Pollution Control Board (CPCB) as well as SPCB.

The Role of EPR in Sustainable Plastic Waste Management incentivises producers to design products with a longer lifespan, fewer raw materials, and easy recyclable features. Further, the reporting guidelines increase transparency and stakeholder trust, demonstrate environmental responsibility, and enhance brand image. The EPR reporting process is as follows:

● Registration: For waste management of plastic produced and packaged by FMCG, the Central Pollution Control Board has developed a centralized online EPR portal where PIBOs can get themselves registered.

● Submission of Action Plan: Upon registration, PIBOs have to submit an elaborated action plan mentioning how they will manage their plastic waste and how they will fulfil their specified EPR targets. It includes information on the procedure of collection, transportation, recycling, and disposal of plastic waste.

● Annual Reporting: PIBOs must file annual returns to the CPCB, providing information on the quantity of plastic waste collected, recycled, and disposed of. These Strategic Approaches to EPR Waste Compliance for Plastic Waste provide comprehensive data on various activities of the company and bring greater transparency by enabling easy verification of the claims put forward.

EPR Reporting: What Documents Are Required for EPR?

The following documents are required to be submitted by the PIBOs and other obliged entities:
● PDF copy of GST, CIN and PAN card with a maximum file size of 5 MB.
● Details of Authorized Person, including their PAN and Aadhar.
● Copy of registration, in case the PIBOs are renewing their licence.
● Pictures of plastic packaging.
● If the unit is registered with DIC (Direct Industries Centre), submit a copy of the DIC registration.
● Consent issued by the Pollution Control Committee (PCC)/ SPCBs, if the unit has a production facility.
● Covering letter.
● Scanned copy of the signature of authorized persons.
● Geo-tagged photographs of raw material storage area, plant machinery, production area, and product dispatch area (applicable in case of plastic waste processors only).

Note: Separate applications need to be filed in case the brand owner is also working as a producer or importer, and vice versa.

What are the Obligations After EPR Registration?

The vast Scope of EPR for Plastic Packaging Waste, e-waste, waste tyres, and used oils brings accountability, traceability, transparency, and improvement in the fulfilment of EPR obligations. Once producers, importers, brand owners, and other designated entities register themselves on the EPR portal of the CPCB, they are mandated to comply with certain regulations. These are as follows:

● Waste Management: All the producers, importers, and brand owners (PIBOs), after getting registered on the centralized online EPR portal of the CPCB, are legally obligated to take measures for proper waste management. This involves the collection of plastic waste, recycling, and disposal to minimize the environmental impact and bring sustainability to the process. Learn more about How FMCG Businesses Can Meet EPR Plastic Waste Obligations?

● Submit an Action Plan: An action plan outlines detailed steps a producer will take to fulfil his/her EPR obligations. It includes information on collection points, partnerships with waste collectors and processors, disposal plans for plastic waste, and other information that demonstrates how producers plan to meet their goals.

● Reporting and Documentation: Entities who have registered on the portal are now required to maintain records of their operations, including the quantity of plastic waste generated and the amount of waste recycled. Moreover, they must submit reports mentioning whether they have met the recycling targets, and include procurement details and sales data. This documentation enables CPCB to monitor their compliance with the EPR Plastic Waste Rules and Penalties: What Every Business Should Know.

● Product Design Considerations: EPR norms motivate producers to design their products while keeping in mind their environmental impacts. This involves designing products that use minimal plastic, keeping the packaging small, using plastic that is easy to process and recycle, and using recycled plastic in manufacturing newer products.

● Financial Responsibility: EPR Plastic Waste Obligations for Manufacturers and Importers involve financial responsibilities. These entities are required to establish a waste collection network and infrastructure that requires substantial investment. Further, such entities also pay fees for waste management programs and to support recycling with the help of PWPs or others.

● Setting Targets: All the EPR registered entities are mandated to comply with the targets set by the regulatory authorities as per their average waste generation and other activities. FMCG Businesses Can Meet EPR Plastic Waste Obligations by fulfilling and diligently reporting their recycling rates, usage of recycled plastic, waste reduction insights, and other requested environmental metrics.

● Environmental Compensation: PIBOs and Plastic Waste Processors (PWPs) who fail to meet the EPR targets face fines, penalties, and other legal obligations. They might be asked to stop their production, get their registration cancelled, etc. The violations give the CPCB authority to impose Environmental Compensation on PIBOs. However, one must note that compensation does not null and void the targets. The obligations get carried forward to the next three years. Thus, even if someone pays the penalties, they are still required to fulfil their specified targets within the limited time frame to avail of the benefit of a compensation refund.

Therefore, The Importance of EPR in Reducing Plastic Waste Pollution is a crucial one, which places a major responsibility on the producers. It encourages them to design their products in such a way that it does not damage the environment. Further, it compels them to comply with EPR targets and bolster innovation in the process.

What is Extended Producer Responsibility Compliance?

The EPR establish a set of guidelines, including provisions on how to Meet EPR Targets and Manage Plastic Waste Effectively. This set of rules holds the producers and importers of plastic responsible for end-of-life management of their product’s waste. The EPR compliance includes the following two activities:

● Fulfilment of EPR Targets: PIBOs can fulfil their EPR targets in two ways. PIBOs can recycle plastic waste equivalent to the target specified for their category with the help of Plastic Waste Processors (PWPs), also known as recyclers. As evidence, these recyclers generate certificates and exchange them with PIBOs for a nominal fee. This way PIBOs do not get directly involved in recycling and still get their targets fulfilled. Another way to meet the EPR target norms is by buying credit points or certificates from any other entity.

● Updation of Procurement and Sales Data: All FMCG business that uses plastic packaging or production must include data on material purchased and sold in the given financial year in their annual filing report. They must provide information on the type of type and quantity of plastic used, and the percentage of recycled content in the product, among others. Based on these figures, targets for next year are calculated, which is a necessary parameter required while filing the annual returns. These statistical requisites in EPR is Shaping the Future of Plastic Waste Management by forcing PIBOs to diligently report their activities and enhance transparency in the process.

Conclusion

The EPR framework has played a pivotal role in sharing the physical, organizational, and financial responsibility for plastic waste management in the FMCG businesses. It has reduced the burden on municipalities and created effective schemes for end-of-life collection, sound treatment of collected products, and accelerated plastic waste reuse and recycling.

The guidelines for Recycling Plastic Waste Under EPR are an endeavour to reduce toxicity in the environment stemming from the products of FMCGs. The strategic approaches have enabled these companies to manage post-consumer waste, promote sustainable practices, reduce the environmental footprint of the product, and empower manufacturers to create a cleaner and ecologically sound future.

Whether you are an FMCG business or any entity involved with plastic production or supply, EPR compliance is a mandatory legal procedure. It is necessary to fulfil EPR recycling obligations while adhering to other rules prescribed under the framework. Thus, partner with us to obtain your EPR certificate seamlessly and remain compliant with applicable rules to avoid any violations. Achieve EPR targets with Legal Raasta to unlock an array of benefits and thrive in this extra competitive business world.