Introduction

India’s Plastic Waste Management Rules, 2016 were notified by the Ministry of Environment, Forest and Climate Change under the Environment (Protection) Act, 1986. The rules underwent eight total amendments since its first version, notably the 2021 amendment which saw the first nationwide ban on single use plastics. What followed in 2022 was arguably the most vital step towards a circular economy: the introduction of India’s first ever Extended Producer Responsibility (EPR) legislation. Manufacturers, producers, importers and brand owners of plastic packaging now bear various obligations in this plastic packaging circularity framework.

EnviX has compiled a simple overview of the rules for reference.

 

Plastic Packaging Categories

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 like and covers made of plastic sheet, carry bags, plastic sachet 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 sheet or like used for packaging as well as carry bags and commodities made of compostable plastics
Category V Plastic sheet or like used for packaging as well as carry bags and commodities made of biodegradable plastics

 

PIBO

The main obligated entities “PIBOs” (P:Producer, I:Importer, BO:Brand Owner) are defined as such:

Producer (P) A person engaged in manufacturing of plastic packaging; and, includes a person engaged in manufacture of intermediate material to be used for manufacturing plastic packaging, and also the person engaged in contract manufacturing of products using plastic packaging or through other similar arrangements for a brand owners
Importer (I) A person who imports for commercial use, any plastic packaging or any commodity with plastic packaging or carry bags or plastic sheets or like material, or plastic raw material including in the form of resin or pellets, or intermediate material to be used for manufacturing plastic packaging such as films or preforms
Brand Owner (BO) A person or company who sells any commodity under a registered brand label or trademark

 

Obligations of PIBOs

A major part of this EPR scheme is to have the PIBOs bear responsibility for the plastic packaging used in their products, especially the three following:

  • Recycling
  • Use of Recycled plastic content
  • Reuse 

These targets can be fulfilled with the purchase of EPR certificates from plastic recyclers, via the centralized portal by the Central Pollution Control Board (CPCB).

Other obligations by PIBOs include:

  • Register on the centralized portal.
  • File annual returns including details on plastic packaging used, EPR certificates purchased etc.
  • Provide appropriate label on recycled plastic packaging.