All you need to know about your EPR Action Plan

In a bid to effectively manage plastic waste generated, the Central Pollution Control Board (CPCB) further amended the Plastic Waste Management Rules, 2016 (PWM), and released a detailed list of changes to the rules – Overview of the amendments to PWM,2016.

Along with amendments two important documents were released in late March 2021, One requiring all Producers, Importers, and Brand-Owners (PIBOs) to register themselves as a “Brand” or “Producer”, second, was an important Statement of Operating Procedures (SOP) for registration of PIBOs under the PWM Rules 2016.

The SOP outlines the procedures to be adhered to by PIBOs towards Extended Producer Responsibility (EPR), with one section highlighting the EPR Action Plan required to be submitted.

To assist in easier understanding of the guidelines, here is All you need to know about the EPR Action Plan.

EPR Fulfilment

The process of EPR fulfillment is in two stages, and this brief is focused on Stage 1 of the fulfillment procedure.

             Stage 1: Registration

              Stage 2: Implementation

To begin the process,

• PIBO’s are required to register themselves with the CPCB on their online portal

• Registration Application Format for a Producer Click here to download

• Registration Application Format for a Brand Click here to download

• if the PIBOs operate in either one or two states, registration must be with the respective State Pollution Control Board (SPCB) or Pollution Control Committees (PCC)

• If operating in more than 2 states, register with CPCB

• EPR targets may vary for each state/UT where the PIBO is operational

Keeping in pace with the growing need for digitisation, CPCB is gearing up to digitise the process. Digitisation of EPR fulfillment in India will significantly aid PIBOs, SPCBs, PROs, and all stakeholders in the system in tracing, tracking, and managing plastic waste.

“PIBOs shall fulfil EPR in all the States/UTs in which they are introducing their products. EPR Target for a particular State/UT shall be equal to the type & quantum of plastic introduced by them in the market (post consumer waste) in the specific State /UT“ – CPCB

EPR Action Plan for Compliance in India

The registration requires PIBOs to submit an EPR Action Plan.

The Action Plan is required to focus on plastic waste minimization, source segregation, recycling, involving waste pickers, recyclers, and waste processors in the collection of plastic waste either from households or any other source of its generation or intermediate material recovery facility and adoption of polluter’s pay principle to manage waste.

Additional to the above list, the Plan of Implementation of their EPR requirements by PIBOs is extremely crucial. The PWM Rules, 2016 Annexure 1 released in June 2019, outlines the 3 ways of suggested Implementation methods:

1. PWM through Own Distribution Channels
2. PWM through Urban Local Bodies (ULBs)
3. PWM through Waste Management Agencies (WMAs) which in turn channel waste through a ULB

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The pointers required for three methods include: the following (it should be noted based on the implementation procedure, the details under each pointer vary)

1. Waste Collection
2. Waste Quantity
3. Waste Recycling
4. Action Plan Coverage

The format of the required EPR Action Plan has been provided in the SOP document, which can be downloaded by clicking on the link below:

 Format for framing EPR Action Plan

As a PRO, Our team understands the need for comprehensive implementation coverage that ensures effective implementation of your brand’s EPR. Our team of experts is here to assist you in this process. The above-listed information is a brief to give you as a brand/producer on what to expect. For further information book a free 30-minute consultation with our EPR experts.

Recykal is a digital waste commerce platform that is designed to assist your brand in manage the plastic waste generated across a/many states in India. With all services under one umbrella, we can ensure transparent, traceable, and comprehensive implementation of EPR.