Revised documentation process for EPR compliance as per recent SOP published by CPCB under PWM Rules.
Insights on the new additions related to documentation for the EPR compliance.
CPCB has taken an important step towards Extended Producer Responsibility(EPR) under Plastic Waste Management(PWM) Rules, 2016. In March 2021, CPCB published a Standard operating procedure (SOP) for Registration of Producers, Importers and Brand Owners, which provides a clear guideline on EPR activities. A summary of this SOP is mentioned in our previous blog. The SOP can be accessed here.
In this blog, we are providing a short overview of the documentation part in accordance with the SOP. There are some additions to the EPR process documentation. These additions are applicable for those engaged in the EPR process, like Plastic Waste Processing Facilities(PWPF), Waste Management Agencies(WMA), Producers, Importers & Brand Owners(PIBOs), and Pollution control Boards, both state and central (SPCB/CPCB).
Let’s have a look at the documentation part
- Agreement: Following are the points added in the required agreements for EPR compliance according to the SOP
a. Agreement of PIBO/WMA with PWPF: The agreement between PIBO/WMA and PWPF will be as per Annexure 4 of SOP. The newly added points in the agreement will be:
- The EPR target of PIBOs
- Type and quantity of plastic waste for processing
- A list of engaged WMAs/PIBOs with that PWPF.
b. Agreement of PIBO with WMA: The agreement between PIBO and WMA will be as per Annexure 5 of the SOP. The newly added points in the agreement will be:
- The types and quantity of Plastic waste for collection and disposal.
2. Registration for EPR: This is the checklist of the documents for the registration of PIBO with CPCB/SPCB.
- Proof of product selling in more than two states, for example, GST/Tax invoice.
- DIC certificate, if the unit has a production facility
- Valid consents under Air & Water Act, if the unit has a production facility
- Documents related to Action Plan for fulfilling EPR liability(State Wise)
- Authorization document of WMA/PIBOs issued by ULB
- Registration issued by SPCBs/PCCs to PWPF for disposal process
- Agreement of PIBO/WMA with PWPF
- Agreement of PIBO with WMA(as applicable)
3. Half Yearly Progress Report: The half-yearly progress report, a newly added document, will be submitted by the PIBOs to SPCB/PCC every six months. The details required for this report will be according to the mode of execution of EPR activity as follows:
a. Own distribution channel of PIBO:
- The type & quantity of plastic waste for collection and disposal
- Supporting document of collection mechanism
- Disposal document: Including Quantity and type of plastic processed, Date of issue and period of waste processing
- Copy of PWPF registration with SPCB/PCC
- Copy of previous year annual report submitted to ULB by PWPF
b. Direct engagement with ULB:
- Document supporting PIBO engagement with ULB
- Legal Undertaking by PIBO to certify the processed type and quantity of plastic waste match with the EPR action plan
- The type & quantity of plastic waste for collection and disposal
- Disposal document: Including quantity and type of plastic processed, Date of issue and period of waste processing
- PWPF registration copy with SPCB/PCC
- Copy of previous year annual report submitted to ULB by PWPF
c. Engagement with WMA:
- Document supporting enrolment with ULB of WMA
- Legal Undertaking by PIBO: certify the processed type and quantity of plastic waste matched with the EPR action plan
- Document issued by WMA to PIBO indicating type and quantity of processed plastic waste
- Disposal certificate
- Self-declaration letter by WMA to PIBO of process
- PWPF registration copy with SPCB/PCC
- Copy of previous year annual report submitted to ULB by PWPF
We have tried to cover all major points regarding documents needed for PIBO, WMA and PWPF. This addition to the documentation part will make PIBO, WMA and PWPF take action on this as soon as possible and reform their documentation and agreements.
Contributed by- Zeba Asif, Manager, and Ashlesha Karande, Communication Executive 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.
Our Social Media
LinkedIn- https://tinyurl.com/4s3qsav4
Instagram- https://tinyurl.com/cai697bb
Facebook- https://tinyurl.com/uwsrxfcr
Twitter- https://tinyurl.com/kqse5yk1
Pinterest- https://tinyurl.com/nu3w9uv9
