What is Extended Producer Responsibility (EPR)?
EPR means the responsibility of a producer for the environmentally sound management of the product until the end of its life.
Have EPR Guidelines been notified by the Government?
Yes. MoEF&CC vide Fourth Amendment to Plastic Waste Management Rules, 2016, notified EPR Guidelines on February 16, 2022.
Which entities shall register on the centralized portal developed by CPCB?
The following entities shall register on the centralized portal developed by CPCB:
I. Producer (P)
II. Importer (I)
III. Brand Owner (BO)
IV. Plastic Waste Processor engaged in:
(a) Recycling
(b) Waste to Energy
(c) Waste to Oil
(d) Industrial Composting
What assistance is provided for filling of application?
- AI Chat bot has been provided at the right side of the login and sign-up page of the portal
- Helpline No.: 011-43102469
- i-button with assistance provided in specific sections
- Standard Operating Procedure uploaded on the website
- Instruction sheet for filling of application uploaded on the website
Which PIBOs are required to register with SPCB/PCC?
PIBOs which are operational in one or two States/UTs are required to register with the concerned SPCB/PCC.
Which PIBOs are required to register with CPCB?
PIBOs which are operational in more than two States/UTs are required to register with CPCB.
Note: Brand Owners (BO), including online platforms/marketplaces and supermarkets/retail chains—other than those classified as micro and small enterprises as per the criteria of the Ministry of Micro, Small and Medium Enterprises, Government of India—are required to comply accordingly.
For details, Sections 3 & 4 of the EPR Guidelines may be referred to.
What are the documents required for KYC for registration of PIBOs?
i. PDF copy of Company’s PAN, CIN & GST (combined copies of GST invoices in all States/UTs where the PIBO is operating).
ii. PDF copy of Authorized Person’s PAN & Aadhaar.
Note: Proprietorship and partnership firms shall provide PAN and GST number for registration on the EPR portal. CIN number is applicable only for companies registered with the Ministry of Corporate Affairs.
Which are the plastic packaging categories covered under EPR?
The following plastic packaging categories are covered under EPR:
Category I: Rigid plastic packaging
Category II: Flexible plastic packaging of single-layer or multilayer (more than one layer with different types of plastic), plastic sheets or similar materials, carry bags, plastic sachets or pouches
Category III: Multilayered plastic packaging (at least one layer of plastic and at least one layer of material other than plastic)
Category IV: Plastic sheets or similar materials used for packaging and carry bags made of compostable plastics
(For details, refer to EPR Guidelines – Section 5)
What is Pre-consumer plastic packaging waste?
Pre-consumer plastic packaging waste refers to plastic packaging waste generated as reject or discard during the manufacturing stage of plastic packaging or during product packaging, before the packaging reaches the end-use consumer.
What is Post-consumer plastic packaging waste?
Post-consumer plastic packaging waste refers to plastic packaging waste generated by the end-use consumer after the intended use of packaging is completed and is no longer used for its intended purpose.
What is the EPR target for Producers & Importers?
The EPR target is the plastic waste introduced into the market by the PIBO. Details are provided in Section 7 of the EPR Guidelines.
Whether all PIBOs are required to submit Consent granted under Air & Water Act?
All producers are required to submit the consents issued to their production facilities. Brand owners having their own production facilities are also required to submit the consents.
How much application / annual processing / renewal fees are to be paid for registration of PIBOs / PWP?
The details of fees are as follows:
a. Application fees for Registration of PIBOs
| PW Generation Slab (TPA) | Proposed Processing Fees (Rs.) |
|---|---|
| < 1000 | 10,000 |
| 1000 – 10,000 | 20,000 |
| > 10,000 | 50,000 |
b. Application fees for Registration of PWP
| Production Capacity Slab (TPA) | Proposed Processing Fees (Rs.) |
|---|---|
| < 200 | 5,000 |
| 200 – 2000 | 20,000 |
| > 2000 | 50,000 |
c. Renewal Fees: Same as registration fees
d. Annual Processing Fees: 25% of application fees (for PIBOs as well as PWP)
Our entity collects plastic waste; do we need to register as PWP?
Only entities engaged in plastic waste processing (recycling, co-processing, waste to energy, waste to oil) are required to register as PWP.
What if PIBO has an in-house recycling unit for their packaging plastic?
PIBO must register both as PIBO and as Recycler with relevant documentation. Credits can be issued only to recyclers, and transactions of credits to PIBOs must be documented.
What are the documents required to register on the centralized portal if an entity falls in more than one sub-category?
- A different email ID is required to register for each category.
- Company KYC documents (PAN, GST & CIN) shall remain the same for each category.
What shall be the proportion of plastic waste in Municipal Solid Waste (MSW) for co-processing or incineration at Waste-to-Energy plants?
Equivalent quantity of plastic shall be considered for generation of EPR certificates. As per CPCB’s report “Assessment & Characteristics of Plastic Waste Generated in 60 Cities”, average plastic waste generation is around 6.92% of MSW. In the absence of actual characterization, this average percentage shall be considered.
What shall be the proceedings in case of rejection of application?
- If operating in one State/UT or more than two States/UTs: Fresh application must be submitted with the same login credentials and application fees as per SOP.
- If operating in two States/UTs: Fresh application must be submitted in case of rejection by one or both States/UTs, with fees as per SOP.
What are the liabilities of Producer/Importer if concerned Brand Owners are not registered on the centralized EPR portal?
The Producer/Importer may register on the portal, and EPR liabilities shall be adjusted while filing the Annual Report if the Brand Owners are not registered.
What shall be the EPR liabilities if an entity is both Brand Owner and Importer?
The entity must first register as a Brand Owner and disclose total plastic waste generation including imported plastic. Subsequently, the entity shall register as an Importer and provide import details. No EPR liability shall be fulfilled as an Importer.
What material is considered for EPR in case of MLP (Category III)?
Only the weight of the plastic layer shall be considered for EPR liability.
What is the EPR liability associated with third-party manufacturers?
If the third party does not own a brand name, the EPR liability rests with the concerned Brand Owners/Producers to whom the product is sold.
What is the definition of “Operations” for PIBOs?
Operations mean selling plastic packaging products or products with plastic packaging, including carry bags, multilayered packaging, or plastic sheets, into the Indian market.
What is the definition of “Raw material” for Brand Owners, Producers & Importers?
For Brand Owners and Importers: Plastic packaging, carry bags, multilayered packaging, or plastic sheets.
For Producers: Resin/granules used to manufacture carry bags, multilayered packaging, or plastic sheets.
Do PIBOs with valid CPCB/SPCB/PCC registration also need to apply on the Centralized EPR Portal?
Yes. All PIBOs must apply on the Centralized EPR Portal along with the applicable application fee.
Are export-oriented units exempted from fulfilling EPR obligations?
Yes. Export-oriented units are exempted from fulfilling EPR obligations.
Which category of PIBOs are exempted from fulfilling EPR obligations?
Micro and Small category Brand Owners are exempted from EPR obligations. All other entities must register on the Centralized EPR Portal in line with the notified EPR Guidelines.