The Plastic Waste Management (PWM) Rules, 2016, has made the adoption of Extended Producer Responsibility Plans mandatory for Producers, Importers & Brand – Owners (PIBOs).
As ruled, PIBOs are required to establish a plastic waste management system according to local bodies’ rules and guidelines. Before implementation, PIBOs are required to register with the concerned SPCB and/or CPCB with their EPR Action Plan.
CPCB posted the format for the Action Plan in the PWM Rules (Annexure I) in June 2019. However, after an extensive round of interviews and discussions with concerned stakeholders, crucial amendments were suggested.
The Amended Standard Operating Procedure for Registration of Producers, Importers & Brand-Owners (PIBOs) Under Plastic Waste Management Rules 2016 has been published on 23rd March 2021.
It should be noted that PIBOs have the flexibility to do the EPR fulfillment through their own distribution channel, direct engagement with ULBs/State designated authority, or engagement with Waste Management Agency (WMA), which in turn should engage with ULBs.
The below-mentioned guide on the amendments is in accordance if the PIBO chooses to do the EPR fulfillment through engaging Waste Management Agency (WMA). Here is a quick guide on the amendments made to the registration process.
Changes in registration process under Plastic Waste Management Rules, as per 23rd March 2021 Amendment
| Amendments to SOP March 2021 | Prior to March 2021 |
| EPR Fulfilment | |
| PIBOs shall fulfill EPR in all the States/UTs in which they are introducing their products. | Earlier PIBOs need to fulfil EPR zone wise. |
| 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. | |
| Registration | |
| The PIBOs shall apply to CPCB for the registration online on the portal | Earlier the registration process was offline |
| The application fee shall be paid by PIBO at the time of submitting the application for Registration with CPCB | Earlier there was no application fee for registration |
| Registration issued by SPCBs/PCCs to PWPF to be engaged with for PW processing need to be submitted during the registration process | Earlier there was no such provision of submitting registration certificates of PWPFs |
| ULB/Designated State Authority | |
| WMAs, if engaged, shall be enrolled with the concerned ULB/ any authority designated by the State/UT. Details of such WMAs shall be intimated to the respective SPCB/PCC by the ULB/ designated state authority | Earlier there was no such provision of intimating the SPCB/PCC about the WMAs working in the state by ULB/designated state authority |
| EPR Progress Report | |
| The PIBO shall be submitting half-yearly progress reports, within 15 days of completion of the corresponding half year term – regarding the management of plastic waste for each State/ UT in their EPR Action Plan to the concerned SPCB/PCC (Format given in Annexure VIII of SOP) | Earlier PIBOs needed to submit only quarterly progress reports |
| Legal undertaking by WMA certifying that said type & quantity of plastic waste has been collected as per EPR Action plan of PIBOs who have engaged WMA | Earlier WMA could provide the undertaking stating that said type & quantity of plastic waste has been collected as per EPR Action plan of PIBOs who have engaged WMA |
| Copy of last Annual report (Form-IV) filed by PWPF with concerned ULB | Earlier there was no provision to submit the annual report (Form IV) filed by PWPF |
| Copy of valid registration issued by SPCB/PCC to PWPF | Earlier there was no provision to submit registration copy issued by SPCB/PCC to PWPF |
| PIBOs | |
| PIBOs need to submit verification of said quantities of waste managed. The Agency is to confirm that said quantity of waste has been managed by the Agency and there is no overlap/duplication with other PIBOs | Earlier conducting the audit of the WMA process in case of engagement by PIBOs was not compulsory |
| Agreement of PIBOs/WMA with PWPF | |
| The amendments provide a detailed list of required information for the agreement – Copy of registration issued to PWMF to be enclosed – The validity date of registration issued to PWMF – Type of plastic waste processed at PWMF Processing capacity of PWPF(TPA) – Type of plastic waste (LDPE/HDPE/PP/MLP/PET etc) to be provided by PIBOs/ WMA – Quantity of plastic waste (TPA) to be provided by PIBOs/ WMA – List of PIBOs/ WMA along with PW qty for which PWPF has signed agreement – Balance PWPF processing capacity (TPA) | Earlier there was no such specific mention of information required |
| Agreement of PIBO with WMA | |
| There is a format provided for the agreement of PIBO with WMA (Annexure V of the SOP) | Earlier there was no such format |
| EPR Action Plan | |
| There is a format provided for the EPR action plan of PIBOs registered in the state/UT | Earlier there was no such format |
| Application form of Producers/Brand owners | |
| Both registered address and postal address of producer/brand owner need to be mentioned | Earlier only postal addresses needed to be mentioned |
| Need to mention the names of the states/UTs in which the producer/brand owner is operating | Earlier there was no need to mention the name of the states/UTs in the application form |
| Producers/brand owners need to mention the pre-consumer and post-consumer plastic waste generated in the application form also | Earlier the pre-consumer and post-consumer waste generated need to be mentioned in the action plan not in the application form |
To know how the changes affect your brand, registration process, and registration cancellation process, get in touch with us or book a FREE 15-minute consultation with our team of experts.
Team Recykal’s EPRLoop is designed to give you the ease of fulfilling your requirements with easy, transparent, and accessible solutions and a network of brands, recyclers, aggregators and more, to make the transition smooth.
Click on the tab below to download the CPCB notice and the Standard Operating Procedure for Registration of Producers, Importers & Brand-Owners (PIBOs) Under Plastic Waste Management Rules 2016 (as amended).
Click here to download SOP Amendment for PIBOs
Click here to download the Notice of Registration issued by CPCB
