Is Plastic Waste EPR applicable to you?

Applicability is the most essential part of the PWM Rules. It is the beginning of compliance. The applicability can be seen from the following three points of view:

The Obligated entities

a. Producer: A company which manufactures plastic packaging

b. Brand Owner: A company that has a registered label/trademark with them. If a company does not have these, then it does not become a brand owner even if it consumes plastic packaging. Also, only Medium/Large brand owners are eligible for Registration.

c. Importer: A company which imports either plastic packaging directly or products that come with plastic packaging. Practically almost all the imports come along with plastic packaging.

Plastic packaging

The plastic waste Management Rules apply to plastic packaging like poly bags, shampoo bottles, wrappers etc. They do not apply to plastic products like chairs, crates etc. They also do not apply to tarpaulins which are used in agriculture. This plastic packaging is then further subdivided into four categories for better identification:

a. Rigid i.e. Category I: Plastic that has a rigid shape like shampoo bottles, PET bottles, curd/ice cream containers, IBC drums, paint/lubricant buckets etc.

b. Flexible i.e. Category II: Plastic that has soft/flexible properties like polythene, milk pouches, shrink wraps etc. An important thing to be noted here is that there are layers of plastic material only in this packaging. There can be one or more layers but all of them are of plastic only like LDPE, LLDPE, Nylon, EVOH, polyester, BOPP etc.

c. MLP i.e. Category III: This is also flexible in nature but different from Category II in one aspect i.e. presence of non-plastic material. In this packaging, one layer is of either paper or metal. For example, tetra pak, and wrappers of chips fall under this category.

d. Compostable i.e. Category IV: This is altogether a different category where the resin itself is compostable.

There is another way to look at plastic packaging. That is as per the involvement of the consumer and the cleanliness of the packaging. It is as follows:

1. Post Consumer: Meaning the one which is used by the consumer and thrown away.
2. Pre-Consumer: The definition mentioned in the rules is different from the common perception. Hence it is important to understand the definition in a better way. As per the definition, pre-consumer means the reject/discard during the manufacturing/packaging stage. It doesn’t include the packaging that comes along with raw materials and then gets thrown away as scrap even though it is also very clean.

Contributed By: Shailesh Shinde & Manasi Ranrui at Social Lab Environmental Solutions Private Limited

Social Lab Environmental Solutions is a waste management consultancy company providing end-to-end consultancy services to the ULBs on solid waste management and plastic waste management.

To know more about us and the sector updates, please visit our website (www.social-lab.in) and follow us on social media (https://linktr.ee/Social_Lab).