Detailed Standard Operating Procedure for EPR under Plastic Waste Management Rules
Yet another guideline from CPCB to simplify the compliance requirement of EPR
As per Plastic Waste Management (PWM) Rules, 2016, the Producers, Importers, and Brand Owners (PIBOs) are responsible for the management of plastic packaging waste generated because of their products which are introduced in the market. All the PIBOs need to register themselves with the Central Pollution Control Board (CPCB) or State Pollution Control Board (SPCB)/Pollution Control Committee(PCC) as per the PWM Rules 2016.
In March 2021, CPCB published a Standard Operating Procedure(SOP) for Registration of PIBOs under PWM Rules, 2016. This SOP is a consolidated document that enlists the options for preparation of EPR Action Plan, reporting formats, timelines for registration etc. The SOP document also lists the roles and responsibilities of PIBOs, Waste management agencies(WMA), Plastic waste processing facilities(PWPF), Urban local bodies(ULB), SPCB and CPCB. Let’s look at a brief summary of the SOP document in the remaining part of this article.
- EPR Targets: PIBOs have to fulfill EPR compliance in all the states in which they introduce their products. The EPR target should be the same as the quantity and type of the post-consumer plastic waste introduced by them in each state.
- Alternatives for EPR activities by PIBOs: Through their own distribution channel, ULB or WMA.
- For ULB, one ULB from each zone of India should be engaged by PIBO
- For WMA, one WMA from each zone of India should be engaged by PIBO
3. Role of WMA (Waste Management Agency): If any PIBOs wants to engage with WMA to conduct EPR, they need to ensure WMA:
- Is authorized with the ULB/any authority designated by the state/UT.
- Multiple WMA can be engaged with any PIBO
- PIBO agreement with WMA will be as per Annexure 5 in the SOP (Quantity and type of plastic should be included in the agreement).
4. Registration:
- PIBOs operating in more than 2 states: Registration with the CPCB.
- PIBOs operating in one or two states: Registration with the concerned SPCB/PCC.
- Online portal: Registration at CPCB will be through an online portal.
- Supporting documents of WMA’s enrolment with ULB/any authority designated by the state/UT has to be submitted at the time of Registration of PIBOs.(The checklist of the documentation is also given in the SOP).
Timelines for Registration process:
- If there are any shortcomings in the application, CBCB will have to communicate within 7 working days. The applicant will get 30 days to respond that, if not communicated in 30 days, the application will be considered as withdrawn.
- Fresh registration will be valid for 1 year and renewal will be valid for 3 years.
- For renewal of registration, PIBOs should apply 4 months before the expiration of registration.
- Registration certificate will be issued online within 7 days of complete application submission. And for renewal, the PIBO’s registration will be renewed within 15 days of complete submission of the application.
5. Role of PWPF (Plastic Waste Processing Facility) (Recycler & Co-processor):
- The Plastic Waste Processing Facility should be registered with SPCB/PCC.
- The number of WMAs/PIBOs engagement with the PWPF will be limited as per their processing capacity.
- PIBOs/WMA agreement with PWPF will be limited as per their processing capacity.
- PIBOs/WMA agreement with PWPF will be according to Annexure 4 in the SOP (Quantity and type of plastic should be included in the agreement).
6. Role of State Government:
- Nominate State level nodal agency to coordinate among ULBs, RLBs, Cantonment Boards etc.
- Identify more than one such department, but only one will be the State Nodal Agency.
7. Role of Nodal Agency:
- Will help PIBOs get regular updates, Nodal agency will ensure that a six-monthly basis update is done on their website.
- Will submit consolidated details of EPR activities of PIBO & PWPF to SPCB/PCC.
- Will submit a consolidated half yearly progress report of PIBOs to SPCB/PCC.
8. Role of ULB/Designated state authority:
- Will be responsible for informing about the WMA to the respective SPCB/PCC.
- Will setup Plastic waste management system in their concerned area.
9. Role of SPCB/PCC:
- Will monitor EPR action plan implementation of PIBOs at state level.
- Will share compiled PIBO’s activities as per their EPR action plan on public domain.
- Will communicate regarding any shortcoming or deficiency in the information of PIBOs/WMAs EPR activities.
- Will validate the information provided by PIBO and State Nodal Agency.
- Will submit the EPR activities information to CPCB.
- Will validate the half yearly progress report and submit to CPCB.
10. Half Yearly Progress Report:
- PIBO will submit a half yearly progress report for each state to SPCB/PCC
- The report should be submitted within 15 days of completion of the corresponding half-year term.
This SOP is applicable for all new registrations, however all existing registrations need to align themselves as per the SOP within 3 months. The SOP will provide the PIBOs, WMAs and PWPFs with easy and understandable guidelines for completing the EPR process. PIBOs along with the WMAs and PWPFs should be ready with their documents according to this SOP, although this SOP will have few improvements but staying put with the timelines and guidelines provided by this SOP will be helpful and keep the process hassle free in the future.
Contributed By- Zeba Asif, Manager and Ashlesha Karande, Communication Executive at Social Lab
Social Lab Environmental Solutions is a waste management company, which helps brands take-back and scientifically dispose of post-consumer plastic waste of their products. Brands take our services to fulfill Extended Producer Responsibility (EPR) obligation under Plastic Waste Management Rules, 2018.
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