Draft Notification for EPR Implementation- FAQ
- What does the recent EPR notification address?
The recent EPR notification was issued by the MoEFCC on October 6, 2021, in accordance with the PWM Rules, 2016. This announcement is a draft for future amendments to the PWM Rules or guidelines to clarify and precise the EPR process.
2. When will the regulations or guidelines mentioned in the draft be applicable?
These regulations shall come into force with immediate effect. The ongoing processes related to the obligations will be inclined with this.
3. Will brand owners, such as online platforms or marketplaces, be required to comply with EPR?
Yes, but only for those online marketplaces or platforms that employ plastic for packaging or as a selling product. If they have their labeling on the packaging, they will almost certainly be required to comply with EPR.
4. Both pre-consumer and post-consumer plastic waste are mentioned as being part of EPR. What is the difference between the two?
Plastic waste formed during the process from raw material to product reaching the consumer is referred to as pre-consumer plastic waste. This indicates that pre-consumer plastic is generated along the product’s entire supply chain. The waste generated after a consumer has finished using a product is known as post-consumer plastic waste.
5. If one entity is a producer in two states and a BO in three distinct states, does that entity need to register with the CPCB as a producer and brand owner for both?
No. As a producer, you must register your PWM in each state’s SPCB separately. However, because it is in more than two states, it must be registered with the CPCB as a brand owner. As a result, the entity must complete three registrations. The operational state number of Categories (Producer, Brand Owner, Importer) will be used to determine whether the registration will be in SPCB or CPCB.
6. Is the use of plastic recycling content an obligation for the carry bags also?
No, it is now solely referred to in relation to plastic packaging.
7. Is it obligated for the BO to reuse the rigid plastic packaging of their own brand?
There is nothing mentioned regarding that as of now. Hence, it’s not necessary to reuse the plastic packaging of their own brand only, but reusing their own packaging would be a viable option as the packaging of other brands will have different compositions and might hamper the product’s safety and storage.
8. If one entity comes under more than one category(Brand owners, Importer, Producer) then will the action plan be submitted separately?
Yes, if the action plans are created on the basis of the registration. The EPR target will be determined on the basis of obligations given for each category if the entity comes under more than one category.
Contributed by- Zeba Asif, Manager 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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