Understanding Stakeholder Responsibilities for EPR

Understanding Stakeholder Responsibilities for EPR
| 7 Min read

What Is EPR in India?

Before knowing anything about EPR in India, Are you aware that 79% of plastic waste is in landfills, water, and the environment? Humans consume that without their knowledge. According to researchers, what if things keep going this way? Plastic will outnumber fish in the oceans by 2050.

As a result, each country is responsible for enacting laws limiting plastic waste and encouraging a circular economy. In 2012, the Indian government implemented EPR to handle electronic waste, and in 2016, EPR was extended to plastic waste manufacturers by plastic waste management rules.

The EPR policy in India focuses on producers, importers, and brand owners who produce large amounts of plastic to be financially and physically responsible for treating or disposing of post-consumer products.

EPR in India promotes a circular economy in which waste generated by businesses contains numerous resources that can be recycled and reused rather than disposed of in landfills or polluting the environment; such waste is collected, segregated, and recycled for reuse. 

Also read, Everything you should know about the PWM rules

Understanding Each Stakeholder’s Responsibility of EPR in India

Central Pollution Control Board

The Central Pollution Control Board establishes waste management guidelines and standards and fosters stakeholder collaboration.

  • The CPCB establishes guidelines for various stakeholders involved in segregation, collection, disposal, co-processing, and multiple forms of plastic waste. It also explains how to follow the guidelines by giving each stakeholder an action plan.
  • The CPCB holds stakeholder consultations to address challenges faced by all stakeholders involved in waste management. It aids in the resolution of their problems.
  • CPCB coordinates with SPCB to guarantee that stakeholders performing EPR are monitored regularly.
  • CPCB verifies and researches all reports received from PIBOS executing EPR every quarter to provide national-level EPR reports.

State Control Board

The State Control Board is a state-level body responsible for monitoring state-level actions per the PWM regulations 2016.

  • SPCB ensures that stakeholders follow all CPCB guidelines, and regular inspections guarantee everything is done correctly.
  • All stakeholders, including processors, brand owners, and co-processors, require authorisation to operate, granted by the SPCB. The PIBOs must renew permission once it expires.
  • SPCB relays CPCB’s information, notifications, and guidelines to PIBOS.


Producers include industries, businesses, and other entities that create large amounts of different plastics. 

It is a corporation that manufactures or sells products. For example, Heritage Foods is a supplier and manufacturer of milk and dairy products.

  • The first step is registering with the State Pollution Control Board and providing accurate information about plastic consumption.
  • Businesses need to establish a mechanism for collecting and disposing of plastic waste.
  • It is critical to maintain regular communication with the CPCB/SPCBs to inform them of monthly EPR activity, quarterly reports, and participation in CPCB stakeholder discussions.
  • ULBs typically work with informal waste picker networks or organisations that connect waste pickers. Both can work independently or in tandem to achieve the goal of efficient collection.
  • It is the responsibility of the ULBs to set up the infrastructure for plastic waste segregation, collection, storage, and disposal. Individual organisations that seek to unite informal waste pickers can also organise infrastructure.
  • Creating local facilities to promote recycling/processing units opens the door to decentralised and low-cost waste recycling. It could be a government facility or a private but government-approved facility.

EPR Agency

Their primary responsibility is to bring out EPR activities on behalf of the client, the PIBOs, including the following.

  • Identify plastic waste sources such as ULBs, Bulk generators, etc. Examine the material quality, specifically whether it contains only segregated plastic waste rather than mixed solid waste. Signing official contracts for plastic waste collection with the source.
  • Identifying recyclers/processors with proper consent to continue operating from their respective State Pollution Control Boards. The agency must enter into agreements with these processors to dispose of Plastic scientifically on behalf of its clients.
  • The agency must keep on file the PIBOs purchase bills, weight receipts, lorry receipts, photos of the material, vehicle photos, E-way bills, material received acknowledgment from the processors, and disposal documents.
  • Compliance reports: The Agency must also submit all required documentation/proofs to the PIBO to prepare the Action plan and quarterly report. These proofs could be agreements the agency has with waste sources, processors, etc.

Recycler and Co-Processor

A person or company collects, sorts, and processes waste to create valuable materials that could be reused.

The following are their responsibilities:

  • Authorisation: Having a valid operating permit from the State Pollution Control boards and adhering to all handling standards and pollution control norms.
  • Registration entails registering with PCBs and Local governments as recyclers, which can be accomplished by issuing a Udyog Aadhar Memorandum.
  • Recyclers must communicate with PCBs regularly about their involvement in EPR activities, the details of the plastic packaged, and the clients on whose behalf the Plastic is processed.

Local Body

  • It is the responsibility of the local government to design and build up infrastructure for segregation, collection, storage, transportation, processing, and disposal of plastic waste, either independently or in collaboration with producers.
  • The local government is in charge of establishing and coordinating a waste management system and carrying out proper procedures.
  • Guaranteeing the segregation, collection, storage, transportation, processing, and disposal of plastic waste; 
  • Ensuring that no environmental damage occurs during this procedure; making sure the channelisation of recyclable plastic waste portion to recycling centres
  • Make sure the processing and disposal of a non-recyclable portion of plastic waste are in line with the guidelines issued by the Central Pollution Control Board and raise awareness among all stakeholders about responsibilities.
  • Involving civic organisations or groups working with waste pickers and preventing open burning of plastic waste should not occur.
  • The local authority responsible for establishing a system for plastic waste management began to seek producers’ cooperation; a system with producers’ cooperation can quickly be established within one year of the final publication of these regulations in the Government Gazette of India. 
  • The local body is responsible for drafting bylaws that include the requirements of these regulations.

Gram Panchayat

The gram panchayat, either on its own or with the assistance of an agency, should establish, implement, and coordinate waste management in the rural region under its authority, as well as undertake the related tasks, namely,

  • Assuring plastic waste segregation, collection, storage, transportation, and channelisation of recyclable plastic waste portion to recyclers with proper registration; ensuring that no environmental harm occurs throughout this process;
  • Raising awareness among all stakeholders about their duties and preventing open burning of plastic waste.

Waste Generator 

Challenges faced in EPR in India

Implementing EPR in India will significantly impact the environment, and humans will be held accountable for what they generate and consume. The biggest challenge is to bring the entire country on board with the EPR plan. As we all know, India is diverse, and putting it on track requires clear laws and regulations that all stakeholders must adhere to. The most serious difficulty is the absence of solutions in applying EPR.

Here is a handful of them:

  1. The most significant difficulty is that organisations did not meet EPR targets until 2020 due to a lack of understanding of the rules. Industries bear responsibility for effectively completing the EPR, and they have been negligent.
  2. It’s a tiring task if the documentation process takes a long time, and it’s even more difficult if we don’t grasp the sequence in the documentation, which is another EPR difficulty. It is critical to have documentation as verification of EPR implementation.
  3. In India, waste management infrastructure isn’t fully developed, and there aren’t many large-scale technologies applied, with EPR playing a minor role.
  4. Because the Producers Responsibility Organization manages the logistics and other aspects of the EPR process, it is challenging for enterprises to track the EPR process when they partner with other organisations (PRO).

What Are The Plastic Waste Categories PIBOs In EPR Have To Cater To? 

Plastic is commonly used in various applications, such as lunch boxes, water bottles, spoons, the purchase of soft beverages, and so on.

Do any of us know what kind of Plastic is environmentally friendly? Or what Plastic poses a risk to us? We can only know it if we thoroughly understand the many types of plastics. 

We have been oblivious to cautions from others about the dangers of excessive plastic use. As a consumer, limiting our use of Plastic is critical when we know it’s harmful to our health.

Here are four categories of plastic waste packaging:

Rigid Plastic Packaging

  • Rigid plastic waste packaging is a type of Plastic typically made of 2 HDPE and 5 P.P. rigid. 
  • These products have open tops that may be covered with lids and coverings and used as recyclable food containers. They have water bottles, soft drink bottles, yogurt containers, and prescription boxes.

Flexible Plastic Packaging

  • High-quality polymers such as PVC, polyamide, polypropylene, and polyethylene are used to make flexible packaging. These polymers are FDA-approved, contaminant-free, and entirely safe for use. They can withstand high heat and pressures. They also serve as a protective barrier for food and beverages, shielding them from microorganisms, U.V. radiation, moisture, and dust.
  • PVC can be used to make pouches, bags, and other malleable product containers in the same way as foil, plastic, and paper cans.

Multi-Layered Plastic Packaging

  • MLPs have a multi-layered composition and can be built of either thermoset or thermoplastic material. Multilayer plastic laminate is made by combining varying materials such as aluminium foil, polyethylene terephthalate (PET), polypropylene (BOPP), polyethylene (P.E.), and paper.
  • MLPs are used in pharmaceutical and cosmetics products, electrical and electronic goods, food storage and service items, and e-commerce packing materials.

Plastic Sheets

  • Plastic sheets are created through film casting, squeezing molten polymer through a thin slot.
  • Plastic sheets are perfect for a wide range of interior applications, including kitchen backsplashes, home renovation projects, home decor, glass cabinets, wall shelves, coffee tables, bed frames, picture frames, coffee tables, and bed frames.

Also read, How is environmental compensation levied under PWM rules?

How Does Recykal Simplify The EPR Process?

Recykal assists PIBOs in registering with SPCB and, if their business operates in multiple states, with CPCB via an online portal. When brands offer Recykal their action plan, including how much Plastic they need to recycle, Recykal begins its work by finding sellers of plastic waste and buyers for recycling plastic waste through the Recykal Marketplace App.

If a firm’s objective is listed on the brand owner’s dashboard, Recykal indicates how many targets they still have to meet and how many they have already met. Brand owners can audit and approve completed delivery. Following approval, brand owners can download quarterly reports that must be submitted to the CPCB.

Recykal simplifies the process for PIBOS from registration to fulfilment, documenting all the paperwork they need to present, proving they met the objective for the fiscal year for brand owners to submit to the CPCB easily. It helps track each phase of the EPR documentation process and ensures your documentation isn’t duplicated at the collection, agency, or recycling centre.

If you are interested, Get in touch with us at marketing@recykal.com or book a 30 mins demo with our team of experts. 

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