How to Meet EPR Targets and Manage Plastic Waste Effectively

Extended Producer Responsibility is implemented under the Plastic Waste Management Rules, 2016. The act specifies the obligation of Producers, Importers, and Business Owners (PIBOs) to process their plastic waste through recycling, reuse, and disposal via co-processing, waste-to-energy, road making, plastic-to-oil, or industrial composting.

Every person involved in plastic manufacturing or packaging is mandated to obtain an EPR certificate. For this, they must register through the online centralized portal of the CPCB (Central Pollution Control Board). The portal is for those PIBOs that operate in more than two states or UTs. However, PIBOs operating in only one or two states have to obtain their EPR certificate through the concerned SPCBs (State Pollution Control Boards). Upon registration, the PIBOs are asked to fulfil certain terms and conditions, including EPR targets.

Let’s understand the Plastic waste management EPR norms by exploring plastic waste processing, categories of plastic under EPR, EPR targets and how to meet these targets while effectively managing plastic waste.

Plastic Waste Processing

Plastic packaging involves multiple stakeholders in the process. Producers are those firms and companies that manufacture plastic and are engaged in the intricate spheres of the plastic packaging supply chain. Importers either directly import plastic to use it for packaging or packaging itself. These two work in tandem and introduce the plastic product into the market. Brand owners are responsible for selling these plastic-packaged products to consumers.

Once the product reaches its end life, these stakeholders are requested to recover the plastic and ensure it is processed thoroughly. Plastic waste processing comprises collection through a material recovery facility, sorting of plastic, washing to get rid of any contaminants, and shredding it through a recycling plant shredder. Further, the plastic is melted into small melting materials called pellets. These pellets are then used as raw materials in producing new products.

Responsibilities of PIBOs under EPR certification:

Plastic waste management EPR norms mandate PIBO, which has its operation in India and plastic packaging is an integral element in business process, to comply with EPR obligations. Under the recent framework, PIBOs are responsible to:

Register: All PIBOs must register on the EPR portal of the Central Pollution Control Board (CPCB).

Collection: PIBOs must actively engage in the collection and retrieval of post-consumer plastic packaging waste. Post-consumer waste is the plastic that consumers discard or throw away after usage.

Recycle: It is the responsibility of PIBOs to implement and oversee an effective recycling mechanism. They must ensure that a certain percentage of their plastic is being recycled either on their own or through collective efforts.

Payment: The application fees for authorization range between Rs. 10,000 to Rs. 50,000. However, CPCB can levy fines and penalties if they fail to meet the EPR targets.

Submission of a plan: An elaborated action plan is requested in the EPR authorization process. It highlights how producers intend to manage their plastic packaging waste and how they will achieve their specified EPR targets.

Processing: Ensure that plastic is processed through a well-defined channel and not dumped to avoid adhering to the regulations.

Collaborate: Although producers are not mandated to engage with other entities, they can partner with PROs (Producer Responsibility Organizations) or other agencies to meet their specified EPR targets. The responsibility of reporting, however, lies entirely in the hands of PIBOs.

Annual Returns: PIBOs are subject to guidelines that seek annual submission of reports attaching the proof of recycling and usage of plastic that is recycled.

Purchase Plastic Credits: Individuals and firms who fail to meet their EPR target can purchase plastic credits from others. The plastic waste management EPR credit mechanism is a way PIBOs can buy credits to avoid any legal or financial repercussions arising due to non-compliance.

EPR Targets:

According to the act notified by the Ministry of Environment, Forest, and Climate Change, there are mandatory targets for reuse, minimum level of recycling, and minimum level of usage of this recycled material in plastic packaging.

The target for Plastic waste management EPR is decided on the virgin plastic packaging average weight in the last two financial years. This is added to the average quantity of pre-consumer plastic in the preceding two financial years. Further, the entire sum is subtracted from the quantity of plastic supplied to Brand owners except for micro and small enterprises. The target determined considering various categories is as follows:

In the initial years, the targets are kept lower to facilitate higher participation of stakeholders in the mechanism. With the passage of time, the targets are increased to encourage greater recycling and reuse to promote a circular economy.

How to effectively achieve EPR Targets?

To effectively achieve the targets under Plastic waste management EPR, producers and manufacturers can implement a myriad of strategies. These are as follows:

Waste Collection Strategies: PIBOs can collect waste themselves or delegate the responsibility to a registered PWP (Plastic Waste Processor). In return for the plastic waste processed by the PWP, they issue certificates to the PIBOs mentioning the amount of plastic recycled by them. However, this certificate is valid only when the PWP is registered and verified with the concerned authorities.

Investment in Recycling Infrastructure: With a substantial financial investment in recycling infrastructure, PIBOs can improve their recycling rate to a great extent. Moreover, it will provide accurate information on waste generation and encourage companies to design products that are relatively easier to recycle.

Sustainable Material: Using renewable materials that are easily recyclable will help companies easily comply with EPR targets. It will encourage PIBOs to use products that have minimal impact on the environment, create less waste, and demonstrate companies’ commitment to enforcing sustainable practices. It will also lower production costs in the long run.

Collaborate and Partner: To enable the sharing of responsibility in the collection and disposal of waste, collaboration plays a pivotal role. By partnering with other stakeholders like waste management firms, retailers, recyclers, etc., PIBOs can create efficient collection networks and monitor waste collection.

Quality Control: Quality control under EPR regulations includes choosing the right material, designing products with higher longevity, and incorporating features that allow it to be easily dismantled during recycling. Further, regular inspection will help identify defects that act as an obstacle in recycling process.

Increase Recyclability Rate: Avoiding mixed material, clearly labelling the packaging, educating consumers about its proper disposal technique, and establishing a robust collection network will increase the recyclability rate of the plastics.

Consumer Education and Awareness: To increase awareness about Plastic waste management EPR provisions, the inclusion of consumers is extremely important. Consumers can help producers sort and return products to collection points, participate in take-back schemes, and further educate others about the significance of EPR.

Track and Report Recycling Data: Monitoring and reporting the amount of waste generated, collected and further re-used in the production of other products is an obligation for PIBOs to achieve EPR targets. Thus, implementing robust data collection methods and using software will speed up and smoothen the reporting responsibility.

How to Manage Plastic Waste Effectively?

Plastic waste management EPR provisions obligate PIBOs to meet certain targets. Failing to do so may result in severe fines, penalties, and restrictions on continuing production. Hence, it is crucial to adhere to these norms and meet the specified targets. However, this requires a holistic approach towards plastic waste management where one must minimize the multi-layering of plastic, recycle it diligently, and dispose of it thoroughly.

Implementing take-back programs will help PIBOs collect their products post their usage. This way, they will be able to manage the entire lifestyle of their product and include the recycled material back into the economy. Further, efforts can be made to set up collection points at a certain drop-off location, or any retail store within closer proximity of consumers to enable seamless collection of plastic waste.

In addition, collaborating with industry peers will help share expertise and best practices. To cater for the remote regions, PIBOs must partner with local rag pickers and recycling units to enable plastic waste management to the last mile. Use the recycled content to produce new products and limit the damage done to the environment.

Final Thoughts

According to this polluter-pay strategy, PIBOs must fulfil their targets within the specified deadline. However, failing to fulfil these targets will result in CPCB imposing Environmental Compensation. Even if PIBOs pay this compensation, the targets still need to be fulfilled as they are carried forward for the upcoming three years. Upon accomplishment of the target, a certain portion of this compensation will be refunded. But if PIBOs still fail to comply, the entire compensation amount is forfeited after three years.

Why you must opt for Legal Raasta Pvt Ltd as your EPR expert? With us, you can leverage our industry knowledge gained over decades and get a stop solution for all your needs. We offer Pan India services and help businesses navigate through complex regulations of EPR while ensuring they meet their specified targets. Our dedicated support staff break down all the complex norms into easy-to-understand concepts so that the entire process remains a few minutes of process. Partner with us to obtain your EPR certificate and avail the benefits of post-certification services with professional guidance and assistance.

Understanding these Strategic Approaches to EPR Compliance for Plastic Waste is important to comply with the stipulated norms while ensuring the profitability of the company does not suffer from a setback.