Draft Notification for EPR Implementation- Targets (Part-5)

Social Lab
4 min readOct 20, 2021

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The Ministry of Environment, Forests, and Climate Change has introduced a draft EPR notification on the 6th of October. This notification is a step further in regulating the management of plastic waste in India and bringing more clarity with respect to the implementation of Extended Producer Responsibility.

In terms of clarity, one important aspect was the targets that need to be fulfilled as part of EPR compliance. Even after 3 years of implementation, clarity on this aspect was not crystal clear. The current notification has addressed that concern very precisely and objectively.

Image used for representational purpose only

The notification details out the targets using 6 different parameters which are as follows:

1. Quantity Target

2. Type of Plastic

3. State-wise Coverage Target

4. Recycling Targets

5. Targets for use of recycled plastic products

6. Targets for reuse of plastic packaging

Let us examine these parameters one by one.

  1. Quantity Targets

a. Method/Formula for calculating the quantity:

The notification has given a formula for calculating these quantities. The formula has the following three variables

  • A: Average quantity of plastic packaging produced/used/imported in the last two financial years
  • B: Average quantity of pre-consumer plastic waste generated in the last two financial years
  • C: Average quantity of plastic packaging sold to brand owners who are registered under PWM Rules 2016
  • Depending on whether the entity is a Producer, Importer, or Brand Owner the formula gets applied accordingly

1. Producer: Quantity = A+B-C

2. Importer: Quantity = A+B-C

3. Brand Owner: Quantity = A+B

b. Quantity Targets: Once the quantities are calculated based on the above formula, the targets for the specific year are as follows:

i. FY2021–22: 35% of Quantity

ii. FY2022–23: 70% of Quantity

iii. FY2023–24: 100% of Quantity

1. Type of Plastic:

a. The type of plastic that needs to be collected is categorized into

  • Category I: Rigid plastic like PET bottles, shampoo bottles
  • Category II: flexible plastic-like milk pouches, grocery bags
  • Category III: Non-recyclable plastic-like laminates and pouches used for packaging chips, biscuits, etc

b. The PIBOs need to collect the plastic based on these types.

c. There is no necessity to collect your own plastic. The type should match as per the categories mentioned above.

2. State-wise collection:

a. The quantities and type of plastic need to be collected from each and every state where the respective PIBO is introducing the plastic.

b. However, the notification allows a deviation of 25% of the statewide collection provided once the overall annual targets are achieved.

3. Recycling Targets:

a. Whatever the plastic is collected based on the quantity and the type, it needs to be scientifically disposed of.

b. The notification mandates that the scientific disposal of this plastic has to include recycling as one option and has outlined specific targets for the same.

Recycling Targets

4. Targets for use of recycled plastic content

a. The purpose of this target is to replace the use of virgin plastic.

b. This target mandates the PIBOs to use a certain percentage of recycled plastic while producing plastic packaging items.

c. The targets are as per the below table

Exceptions: In case if any PIBO is not able to use recycled plastic for their packaging needs due to some statutory obligations, those PIBOs are required to buy credits for recycled plastic from other PIBOs.

5. Targets for reuse:

a. These targets are specific to the brand owners and specific to certain categories of plastic packaging only as mentioned in the below table.

This is a comprehensive gist of the targets mentioned in the draft notification.

This is a draft notification, and comments on this can be submitted to satyendra.kumar07@nic.in and amit.love@nic.in before 6th December 2021.

Contributed by- Shailesh Shinde, Director 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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Social Lab
Social Lab

Written by Social Lab

We are a waste management company, which helps brands take-back and scientifically dispose of post-consumer plastic waste of their products.

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