File No. HSM-12/64/2023-HSM (Computer No.

205868)
895578/2023/HSM

F. No, 12/64/2023-HSM
Government of India
Ministry of Environment, Forest and Climate Change
(Hazardous Substances Management Division)

2™ Floor, Jal Wing

Indira Paryavaran Bhawan
Jor Bagh Road, Aliganj
New Dethi-1 10003
Date: 28" Mareh 2023

OFFICE MEMORANDUM

Subject: Guidelines on Extended Producer Responsibility for plastic packaging-reg

The Ministry has received representations with respect to implementation of Guidelines on

Extended Producer Responsibility for plastic packaging. Separately, a reference has also been
received from Department of Chemicals and Petrochemicals, Government of India, on similar
ISSUCS.

2. These issues have been deliberated in the Ministry along with Central Pollution
Control Board, The issue-wise way forward for removal of difficulties is given in table
| below,

Sr.No, | Issues Raised | __Way Forward =)

I, Producers need to Provisional reqistration certificate may be
submit the CTO from issued to producers bused upon the
SPCB without which submission of application for consent to
unit is not able to operate (CTO).
proceed further = with ‘The tenure for the provisional certificate
EPR Application. may be 6 months.
The provisional registration may be
extended for another period of 6 months.
| Direction may be issued to CPCB for|
) directing SPCBs to delink the grant of CTO
to producers and plastic waste processors
from the penalty for their operation without|
obtaining CTO before the date of
application of grant of CTO.

2, In Part C of EPR portal, The provision for editing the data before
in Section 8, there are submission of application has been
four subsection provided,
(A,B.C.D) requires This has also been updated in manual by
procurement and sales Central Pollution Control Board.
_data of fast nyo financial
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years and,
The section does not
provide opportunity to
edit one’s the data has
been entered in the
system,
Producers need to The mandatory details such as production
submit various other capacity, geo tagged location, pictures of
details such as mw material storage arca as well as
production cupacity, geo production areca may be taken.
tagged location, pictures And, Extended Producer Responsibility
of raw material storage (EPR) registration certificate may contain a
area and — production specific provision that all applicable |
area, DMP statutory clearances may be obtained by the
_ (Disaster Management unit,
Plan.

Application are being An option may be provided to enable|

rejected on the basis of producers who produce plastic items other
discrepancy between the than plastic packaging to mention about the
pre- consumption data quantity of plastic raw material used for
and sales data, plastic items other than plastic packaging.

The CPCB has The late fee may become applicable afer
introduced the concept 21 days after issue of Show Cause Notice
of late fee Mechanism by CPCB/SPCB,
where unit needs to CPCB may decrease the quantum of late
submit certain % of fee fee for micro, small and medium producers,
(late Vee Reply
submission) afler 7 days
of the Show Cause
Notice issued by the
CPCB/ SPCB.
Producers (in case of| As per clause 65 of Guidelines on
multiple location) need Extended Producer Responsibility for
to submit unit wise plastic packaging. more than one unit in the
registration even cnovgh same state will have one EPR registration |
within a state, number.
Multiple units in the same state(JT may
get all units registered through one
application. Option may be given to
provide details of all units in one
application.ln the same application,
separate units may be captured by giving
Separate details of cach unit.
In case, where the entity fall in more than
one sub-category (-Producer, l-Importer,
HO-Brand Owners) then = separate
registration will be required,

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Accordingly, different units in the same |

state under same sub-category (P-
Producer/l-Importer/BO-Brand = Owners)
will have same EPR registration number,

Recording procurement Already vide OM dated 13" March 2023,

and sales operation, CPCB has been requested to allow for bulk
Every invoice nceds to uploading of data on a quarterly basis.
be uploaded on the EPR j
portal,
EPR is too complex for ‘Micro and Small producers may be
Micro and considered for EPR registration based on
small producers. self-declaration for calculation of EPR
targets.
Small importers( using plastic packaging
for importing products below a certain
threshold to be decided by CPCB) may be
considered for EPR registration based on
self-declaration for calculation of EPR
targets,
EPR is too complex for Micro and Small producers and importers
Producers, The main may be considered for EPR registration
objective of the rule is based on self-dectaration for calculation of
based on Polluter Pays EPR targets.
principle. The requisite documents may be verified at
the time of audit.

10. Rigid plastic of Already it has already been clarified vide

industrial nature is not OM dated 14" February 2023 that rigid
the part of plastics waste plastic crates would be treated as plastic
problem. Rigid plastic is commodities and rigid industrial drums
already which are reused by the industry would be
getting recycled and is reduced from EPR targets subject to
never seen in the provision of requisite documentation
tandfill, prescribed by CPCB,

Closure notices issued to CPCB is requested to extend the last date

the non-registered till 30" April 2023,
Producers aller
31.03.2023,
12, Country doesn’t have AU present cumulative EPR target for
sufficient plastic waste around 6300 registered PIBOs is 2.32.
processing facility. million tonnes per annum.
The recycling capacity of around 1600_
EPR framework is based registered plastic waste processors is 15
on the premise — that million tonnes per annum, There is ample |
credits generated — by recycling capacity available,
plastic waste processors PIBOs need to be pant of effective |
in the form of EPR | utilisation of existing capacity as well as 4 |

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i | certificates will be any expansion, if needed as PIBOs have

available for PIBO- been given the independence about the
Producers, — Importers, | adoption of modalities to meet their EPR
_ Brand Owners. targets.

if plastic waste
processing capacity is
not available in the
country, then sufficient
EPR Certificates will not
available and such a
business model will not
work and EPR |
framework cannot be
successfully
implemented.

Environmental
compensation for current
year may be waived off
if possible, ee ee
13. | Manufacturers of plastic e¢ CPCB is requested to extend the last date
raw material will not till 30" April 2023.
supply raw materials to
the unregistered
Producers after
31.03.2023.

3. CPCB is requested to take steps for implementation of the issue-wise way forward
given in the table at paragraph 2 above.

4. This issues with approval of Competent Authority,

AM
(Dr, Amit Love)
Scientist E/ Additional Director

To,
Member Secretary,
Central Pollution Control Board

Copy for kind information:

|. PPS to Secretary (EF&CC)

2. PPS to AS (NPG)