Overview of EPR Target Fulfilment and Compliance

Extended Producer Responsibility (EPR) was first introduced in Sweden in 1988 and has since evolved globally to address various waste management challenges. In India, the EPR framework has significantly transformed waste management, particularly in plastic packaging waste, e-waste, tyre waste, and hazardous waste like battery waste.

EPR focuses on end-of-life waste management, target fulfilment, and compliance requirements. It encourages sustainable manufacturing, recycling, disposal, and co-processing while promoting a circular economy between production and recycling sectors. EPR targets are assigned to producers (manufacturers, importers, brand owners) as a percentage of the eligible quantity to be recycled, increasing gradually. Targets are allocated after successful EPR registration and annual return submission on the EPR portal.

Importance of EPR Policy in India

India has been improving its waste management policies and is a party to the Basel Convention, Stockholm Convention (2006), and Rotterdam Convention. The need for a structured process for reusability and recyclability led to the development of EPR, shifting waste management responsibility from municipalities to producers and importers.

Provisions regarding EPR target fulfilment are outlined under different waste management rules for business entities, with an EPR certificate trading mechanism among registered entities. Producers must take responsibility for the entire lifecycle of the products they introduce into the market, including their disposal.

EPR Target Fulfilment in Case of Plastic Packaging Waste

Producers, Importers and Brand Owners (PIBOs) that introduce products in plastic packaging are made responsible for the management of packaging waste generated.

PIBOs, as well as the plastic waste processors (engaged in recycling plastic waste or involved in waste to energy, waste to oil, and industrial composting), are the entities identified under the PWM Rules 2016 that need EPR registration.

PIBOs, after obtaining EPR authorisation on the CPCB's centralised EPR portal, have the option of managing their EPR Targets through their waste collection/distribution channels or Urban Local Bodies (ULBs) or with the assistance of any Waste Management Agencies (WMAs). Apart from EPR Target Fulfilment, other obligations of PIBOs include

1. Registering on the centralised EPR portal developed by CPCB
2. Submitting their Action Plan for waste management
3. Recycling of plastic packaging waste
4. Use of Recycled content in production
5. End-of-life disposal
6. Collection and recovery of the plastics
7. Submitting annual returns
8. Provide auditable proof for purchased EPR certificates

EPR Targets for PIBOs (FY 2023-24)

Notes:

A = Average weight of plastic packaging material sold in the last two FYs.
B = Average quantity of pre-consumer plastic waste generated in the last two FYs.
C = Quantity of plastic sold to Brand Owners in the last financial year.
D = Average weight of plastic waste purchased/introduced in the last two FYs.

If PIBOs cannot fulfil their targets, they can purchase EPR certificates from registered recyclers, co-processors, and Plastic Waste Processors with the assistance of Fastdeal, which has a pan-India network of registered recyclers, co-processors, and PWPs.

EPR Target Fulfilment in Case of E-Waste

EPR Targets for Producers and Importers of EEE

EPR Targets for New Producers (Recently Started Sales Operations)

EPR Target Fulfilment in Case of Waste Tyre

EPR Targets for Producers (Manufacturers/Importers of New Tyres)

Additional Notes:

Units established after April 1, 2022, will have their EPR obligation start after two years (Y) at 100% of tyres manufactured/imported in Year (Y-2).

EPR Target for Waste Tyre Importers = 100% of the weight of tyres imported in the previous year.

Waste tyre import for pyrolysis oil/char production is prohibited.

EPR Target Fulfilment in Case of Battery Waste

EPR Targets for Producers of Batteries

Entities involved in refurbishment and recycling of waste batteries must be registered to issue EPR certificates. Fastdeal provides assistance in fulfilling EPR obligations under Battery Waste Management Rules, 2022.

Documents Required for EPR Registration

The required documents for EPR (Extended Producer Responsibility) registration may vary depending on the category in which EPR authorisation is desired. However, here is a list of commonly required documents for online EPR registration:

1. Covering Requisition Letter – A formal request letter addressed to the concerned authority.
2. Proof of Possession – Copy of attested Lease Deed or Sale Deed.
3. Company Incorporation Documents –
   .Copy of attested Memorandum of Association (MOA) in case of Public/Private sector companies.
   .Registered partnership deed in case of partnership firms.
4. Layout Plan – A detailed site plan of the facility.
5. Manufacturing Process Details – A comprehensive description of the manufacturing process for each product along with a process flowchart.
6. Water Balance Details – Information on water consumption and wastewater generation.
7. Material Balance Details – Breakdown of material usage for each product and process.
8. Land Use Classification Certificate – Certifying the land’s approved usage.
9. Consent NOC under Water and Air Acts – Approval from the respective pollution control boards.
10. Any Other Documents Required by the Board – Additional documents as per regulatory requirements.

EPR Registration Process

The EPR registration process involves the following steps:

1. Determine EPR Category – Identify the specific category for which EPR authorization is required.
2. Document Preparation – Gather and prepare all necessary documents as per the category.
3. Online Application Submission – Submit the application through the official online portal.
4. Application Review – The concerned authority reviews the application and documents.
5. Clarifications (if required) – If any additional information is required, applicants will be notified.
6. Approval & Certification – Upon successful review, the EPR authorization certificate is issued.