India Issues Four Supplementary Documents for Plastic Packaging EPR 
India ‘s Central Pollution Control Board (CPCB) has promulgated four notices on the implementation of Extended Producer Responsibility (EPR) for plastic packaging, each on April 19, May 9, May 19, and June 7, 2023, respectively. The framework and online portal of plastic packaging EPR have brought wide concerns, since its implementation under Plastic Waste Management (Amendment) Rules, 2022. For effective implementation of EPR, the above supplementary documents by CPCB provide supplemental information and postponement of deadlines.
The contents of notices are summarized below.
Producers, Importers, Brand Owners (PIBO)
Producers:
- Confirm that adequate occupation safety/ health and fire safety measures have been provided in their plant. However, Offsite/Onsite Disaster Management Plan is not required at the time of registration.
- Provide details of manufacturing products other than plastic packaging in Section 13 (Any Other Information) of the application.
- MSME (Micro & Small category) Producers can apply for grant of provisional registration on the EPR Portal by submitting application for grant of Consent to Operate (CTO). Valid period will be 6 months, which can further be extended by another 6 months. Provision will be available till October 31, 2023.
- For plastic packaging sold to unregistered brand owners, its provisional EPR Target will be generated at the time of registration. Final EPR target will also be provided during the annual return filing. Such provisions will be valid for producers registered before June 30, 2023.
Importers:
- Provision for auto-registration if total plastic waste generation (pre + post) is less than 1 TPA.
All PIBOs:
- Provision for bulk uploading of transaction details, along with its Standard Operating Procedure (SOP), have been made on the EPR portal.
- Time slabs in the late fee mechanism have been relaxed for the current year (see table below). Late fee at 50% of the existing rates is payable till December 31, 2023.
| Current system | New system | Re-application fee（% of first time fee） | ||
|---|---|---|---|---|
| 1st | 2nd | 3rd | ||
| Less than 7 days | Less than 21 days | Free | 25% | 50% |
| 8-14 days | 22-30days | 25% | 50% | 75% |
| 15-21 days | 31-45days | 50% | 75% | 100% |
| 22-30 days | 46-60days | 75% | 100% | 100% |
| More than 30 days | More than 60 days | 100% | 100% | 100% |
Plastic Waste Processors (PWP)
- Generation of EPR certificates for sales made in 2022-23 is extended till June 30, 2023. The same will be accounted for in the Annual Report.
The supplementary documents are available to download at below:
- April 19, 2023
https://cpcb.nic.in/openpdffile.php?id=UmVwb3J0RmlsZXMvMTUyN18xNjgxOTY2NjU0X21lZGlhcGhvdG82MDQucGRm - May 9, 2023
https://eprplastic.cpcb.gov.in/plastic/downloads/Removal%20of%20difficulties%20%20for%20implementation%20of%20EPR%20Guidlines_9-5-2023.pdf - May 19, 2023
https://eprplastic.cpcb.gov.in/plastic/downloads/Removal%20of%20difficulties%20%20for%20implementation%20of%20EPR%20Guidlines_19-5-2023.pdf - June 7, 2023
https://cpcb.nic.in/openpdffile.php?id=UmVwb3J0RmlsZXMvMTU0M18xNjg2MjAzMTkxX21lZGlhcGhvdG8xOTM5Mi5wZGY=
