Page 189 - CW E-Magazine (5-12-2023)

Special Report Special Report

Extended Producers Responsibility (EPR ) – a primer 2. Category 2 – Plastics packaging of i.e., fl exible packaging woven sacks, credit liabilities or registering on the
single layer or multi-layer (more Flexible Intermediate Bulk Containers CPCB portal. It is a complex process
than one layer of different types of (FIBCs), and bags. that includes:
xtended Producers Responsibi- sacks and other materials for packing. KRUNAL GODA plastics); 1. Collection of internal data as per
lity (EPR) is a global compliance The PWMR 2016, introduced by Central APAC_LLP@outlook.com 3. Category 3 – Multi-layered plastics The policy has exemptions for CPCB norms;
Epolicy step taken by over 30 Pollution Control Board (CPCB), aims to (one layer of plastics with other micro- and small- brand owners; traders; 2. Input data analysis;
countries globally to ensure the world minimise the use of plastics and maxi- holder fulfi ls their social responsibility commodities); and and exports by producers, brand 3. Application processing;
collectively tackles the problem of mise the management of waste generated towards protecting the environment. It 4. Category 4 – Compostable plastics. owners and importers. 4. Registration approvals;
plastics waste in a systematic manner. when using plastics packaging. aims at managing both pre-consumer and 5. Credit liabilities generation;
post-consumer plastic packaging waste. Majority of the Indian chemical End-to-end process 6. Identifi cation of credit liability and
India was no exception in taking PWMR 2016 – what is it? industry uses Category 1 plastics, i.e., It is important for the chemical category grade;
the lead of EPR implementation and PWMR 2016 mandated the gene- To understand EPR the policy, it is rigid plastics, which includes drums industry to understand that EPR compli- 7. Identifying of right partners for
a compliance policy under the Plas- rators (producers, brand owners, and important to understand the basics con- and jerry cans; and Category 2 plastics, ance is just not about the fulfi lment of fulfi lment of compliances;
tics Waste Management Rules 2016 importers) of plastics packaging waste cept of the policy, which aims to ensure 8. Verifi cation of documents related to
(PWMR 2016) has been implemented to take steps to minimise generation that every stakeholder takes the respon- credit liability;
by the Government of India. The policy of plastics waste, not litter the plastic sibility equally by: 9. Purchase of credit liability; and
emphasises identifying the source waste, ensure segregated storage of  Controlling the use/overuse of plas- 10. Filing of annual returns.

of plastics packaging and make the waste at source, and handover segre- tics packaging; Targets for a producer
responsible stakeholders accountable. gated waste in accordance with rules.  Streamlining the waste generation Eligible Quantity in MT Packaging Material Pre-Consumer Plastic Quantity Supplied to BOs In addition to fees (see Table 1), the

Packaging Waste
Sold
(C)
(Q1)
Mass awareness drives, and consulta- The rules also mandated responsibili- disposal in the environment and its (A) (B) Credit Liability generated by CPCB
tions involving several brand owners ties of local bodies, gram panchayats, systematic treatment; and Targets for a Importer on the portal, is usually charged at

and plastics companies have led them waste generators, and retailers when it  Reducing, reusing and recycling the Packaging Material Pre-Consumer Plastic Rs. 1.25-2.00 per kg. The charges for
to understand the impact of the policy comes to managing plastics waste. packaging materials used by stake- Eligible Quantity in MT Imported and Sold Packaging Waste Quantity Supplied to BOs consultation, compliance, audit & risk
(C)
(Q2)
(B)
(A)
in the value chain. However, the holder. management are additional, and range
Indian manufacturing sector, in general, What is EPR as per Indian law? Targets for a Brand Owner from Rs. 25,000 to Rs. 200,000, based
and the chemical industry, in particular EPR outlines the responsibility of a The rules categorised the plastic Eligible Quantity in MT Packaging Material Pre-consumer Plastic Quantity of Reuse on the volume of plastics waste gene-
seems to be unclear on its relevance producer towards the environmentally waste management responsibility (Q3) Introduced in Market Packaging Waste (Only for CAT I) rated annually.
(A)
(B)
and application, until consignments of sound management of a product until amongst three stakeholders:
several companies became either stuck the end of its life. The Ministry of  Producers of plastics packaging and Table 1: Fees collected for EPR

at Customs seeking the EPR registra- Environment, Forest and Climate Change related products; Plastic waste generation Process fees
tion number, or received notices from (MoEFCC), vide its Fourth Amend-  Importers of plastics packaging
authorities for use of packaging drums. ment to PWMR 2016, notifi ed the EPR or commodities that have plastics < 1,000 tpa Rs. 10,000
guideline on February 16, 2022. packaging; and 1,000 to 10,000 tpa Rs. 20,000
The chemicals industry usually uses  Brand owners, including online
metal drums, plastic drums, woven EPR aims to ensure that every stake- platforms/market places and super- >10,000 tpa Rs. 50,000
markets/retail chains, other than Precautions
micro and small enterprises (as per EPR is a long process. A myth that
Producers
criteria of Ministry of Micro, Small Raw Material (Manufacturing Brand owners Importers Traders Contract Job has developed is that EPR ends with
supplier
and Medium Enterprises, Govern- (Granules) packaging
CPCB imposes materials buying credits and fi ling annual returns.
Plastic Waste (FSSAI) ment of India).
penalties to
Management CPCB empanels few big brands CPCB issues guidelines for However, industry needs to understand
(PWM) Rules PRO’s SOP for EPR Bottle-to-Bottle that policy is currently in implemen-
2016 introduce for Incomplete Compliance Recycling The majority of the Indian chemical tation phase and data inputs are in
EPR Compliance industry falls in the category of Impor- progress. It aims for compliance with
ters (any type of chemicals imported) CPCB norms, which many organisation
and Brand Owners (manufacturers of have failed to understand, leaving the
chemicals, APIs, Intermediates, etc.). door open for Government bodies to
identify the obvious fl aws
PWM (Amendment) Grades of plastics in EPR norms
Exports of
Import/purchase of
Brands begin CPCB withdraws Draft Rules 2022 – The policy categorises the grades of any commodity with Import/purchase of Import/purchase Manufacturing commodity in
Compliance of need for Notifi cation on Guidelines on EPR plastics packaging Packaging Bags, of Packaging Raw packaging material plastics packaging & Organisation should aim to work
Films, Rolls
Materials
EPR registration of EPR for Plastic plastics as: material Material with end-to-end EPR experts for fulfi l-
PRO’s Packaging 1. Category 1 – Rigid plastics packaging; ment of compliance under the policy.
188 Chemical Weekly December 5, 2023 Chemical Weekly December 5, 2023 189
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