Extended producer responsibility (EPR)
EXTENDED PRODUCER RESPONSIBILITY(EPR)
What is EPR?
Extended Producer Responsibility (EPR) is a policy strategy that mandates manufacturers to take full responsibility for the entire life cycle of their products, including disposal. This approach aims to minimize the environmental impact of products by requiring producers to manage their post-consumer waste responsibly.
Implementing EPR has economic and social benefits. It encourages manufacturers to design products that are simpler to recycle, reduces the waste management burden on local governments, and generates employment opportunities in the recycling industry. Moreover, by transferring the economic burden of waste disposal from the government to producers, EPR provides incentives for manufacturers to create more sustainable and eco-friendly products.
POLICIES
i. The environmental policy requires Producers to take responsibility for the management of their products and their waste, throughout the entire lifecycle of the product, with the aim of reducing environmental impact.
ii. Rule 13 (1) (Management) of the 2016 Central Pollution Control Board mandates the granting, renewal, or refusal of Extended Producer Responsibility (EPR) Authorization to Producers.
iii. The Central Pollution Control Board has taken direct responsibility for the implementation of EPR, providing specific instructions to Producers and other stakeholders for EPR Authorization, including channelization, collection, storage, transportation, environmentally sound dismantling, recycling, and refurbishment.
Plastic Waste Management Rules 2016
The Plastic Waste Management (PWM) Rules establish a consistent EPR framework that defines the roles and obligations of Producers, Importers, and Brand Owners. However, given India’s unique circumstances, single EPR models may not be feasible, and alternative models should be considered. The PWM Rules outline the Material Flow for Plastic, which focuses on the six primary streams that collect plastic waste in any urban local body (ULB).
Type of models
Fee-based
This model involves ULBs, plastic assemblers/recyclers, rag pickers, and IEC activities. In this framework, the primary responsibility is assigned for the collection, segregation, and disposal of plastic waste. The plastic assemblers/recyclers, rag pickers, and IEC activities are supported to ensure efficient waste management.
PRO-based model and plastic credit model
The objective of this model is to establish a professional organization to lead the implementation and provide the necessary funding on behalf of producers/importers/BO to support plastic recycling and facilitate ease of doing business for all stakeholders. An industry self-managed PRO is responsible for fulfilling the producer’s national and state legal obligations. Producers have the option to establish channels for collecting plastic credits, with or without linking with PROs.
Plastic credit model
Under the plastic credit model, producers are not obligated to recycle their own packaging, but they must ensure that an equivalent amount of packaging waste is recovered or recycled to fulfill their responsibility. Producers are required to gather proof of recycling or recovery from accredited processors or exporters. Producers and processors/exporters may exchange plastic credits for a financial transaction at a mutually agreed upon price and other terms.
Guiding principles for uniform EPR Framework
A national registry will be established for the registration of all stakeholders, with the ownership of the portals and digital exchange resting with the government to ensure data confidentiality and protection. The program aims to include waste pickers, with EPR obligations for MLP being higher than traditional recyclable plastic. ULBs/Municipal Corporations will bear the primary responsibility for door-to-door collection of segregated waste, and Manufacturers and PIBOs will obtain a digital certificate from the professional.
Key Highlights:
i. The EPR target for PIBOs must align with the type and quantity of plastic generated in the respective state/s. The number of WMAs/PIBOs involved in PWPF shall be restricted by the processing capacity of PWMF, as per registration guidelines.
ii. PWPF must obtain registration with SPCB/PCC under PWM Rule 13(3).
iii. Online registration application is available on the CPCB portal, and PIBOs must pay the application fee.
iv. A state/UT level Nodal Agency/Department must be designated to oversee the management of Urban Local Bodies in the state/UT.
v. PIBOs and the Nodal agency must submit Half-Yearly Progress Reports to SPCB/PCC.
vi. CPCB will conduct third-party audits to verify the documents submitted by the PIBOs.
Standard Operating Procedure for Registering PIBOs under Amended Plastic Waste Management Rules 2016
The CPCB has recently released a Standard Operating Procedure (SOP) for the registration of Producers, Importers, and Brand-Owners (PIBOs) under the Plastic Waste Management Rules 2016 (as amended), with necessary updates. This SOP offers several options for meeting EPR obligations by PIBOs and outlines the process for obtaining registration to facilitate the seamless submission of applications and progress reports by PIBOs, ensuring effective implementation of the EPR plan.
Overview of the SOP for Registration of PIBOs
Under PWM Rules 2016 (as amended)
Registration Process for Producers, Importers & Brand Owners (PIBOs) under Plastic Waste Management (PWM) Rules 2016: Standard Operating Procedure (SOP)
The Plastic Waste Management (PWM) rules have assigned the responsibility of managing plastic waste packaging to the Producers, Importers, and Brand Owners (PIBOs) who introduce the products in the market. They are required to establish a system for managing the plastic waste generated by their products through engagement with local bodies. PIBOs have three alternatives as per Annexure I for implementing the Extended Producer Responsibility (EPR) plan:
I. PWM through their own distribution channel.
II. PWM through direct engagement with Urban Local Bodies (ULBs).
III. PWM through engagement with a Waste Management Agency (WMA), which in turn should engage with ULBs.
Responsibility of SPCB/PCC
The state/UT level should monitor the implementation of the EPR action plan of PIBOs to ensure its effective execution. They should compile the activities of PIBOs operating within the state/UT as per their EPR action plan and share it transparently. Additionally, they should assess the information on EPR activities of PIBOs/WMA provided by the state nodal agency and compare it with their EPR plan. Any deficiencies should be communicated to the PIBO. The information provided by the state nodal agency and PIBO should be validated, and the same should be submitted to CPCB.
Role of the (PIBOs)
As per the provisions of the PWM Rules the PIBOs need to compute modalities for waste collection system supported Extended Producers Responsibility (EPR). EPR means the responsibility of a producer (includes Brand-owners/Importers) for the environmentally sound management of the merchandise until the top of its life
Plastic Waste management through Own Distribution channels/ Urban Local Bodies(ULBs)/- Through Agency
i. Waste Collection: The waste should be collected either through the PIBO’s own channels or networks, or through a partnership with ULBs/Agencies.
ii. Waste Quantity: The quantity of waste collected should match the projected amount of plastic waste generated.
iii. Waste Recycling: The collector should have a direct connection with the waste recycler to ensure that all waste collected is sent for recycling. PIBOs can also send plastic waste for co-processing in cement mills, roadmaking, or any other waste processing facility, but they must submit documentary proof to CPCB.
iv. Coverage: The area where the products are sold should be covered to ensure the collection of plastic waste, preferably with Pan-India coverage. The distribution channel should cover states/UTs, and at least one ULB from Tier I, II, and III should be engaged to ensure that cities of all categories are covered.
Role of (PCB) Pollution Control Board /CPCB,SPCB
Each state in India has its own Pollution Control Board (PCB) or Pollution Control Committee (PCC), which aims to increase awareness about sustainable development and improve the environment’s quality with the help of stakeholders. The SPCB works under the CPCB’s supervision, and the latter has delegated all its functions and powers to the former. The SPCB is responsible for enforcing environmental laws and regulations within its jurisdiction and is formed under the Water (Prevention and Control of Pollution) Act, 1974.
Objectives of state pollution control board
I. Its objective is to prevent depletion of natural resources.
II. It promotes sustainable development for the economic growth of the nation while ensuring environmental protection and social equity.
III. It focuses on effective waste management to protect the environment.
IV. It aims to increase public awareness regarding environmental issues.
Impact of EPR
The EPR process involves providing recommendations to the reviewed country with the aim of addressing the challenges faced by the country and promoting the convergence of environmental policies in the ECE region as a whole. This has resulted in several improvements such as enhanced policy and legal frameworks, better integration of environmental concerns into sectoral policies, stronger institutions for environmental management, improved financial resources for environmental protection, greening of the economy, better environmental monitoring and knowledge systems, strengthened public participation, and increased international cooperation. Governments and private companies are encouraged to invest in reducing transportation costs for collected recyclables, designing for recycling, developing industrial standards for recycled products, and promoting green initiatives.