On the 20th of November 2023, the Central Pollution Control Board (CPCB) issued a directive alert, extending the deadline for filing the Annual Report for FY 2022-23 on the Centralised Extended Producers Responsibility (EPR) Portal for Plastic Packaging. The new deadline for compliance is set on or before the 30th of November 2023.
Understanding Plastic Waste Management – CPCB Compliance
Plastic waste poses a significant challenge, and the CPCB is dedicated to environmental protection. The directive issued on the 20th of November 2023 urges all registered Pollution Implementing and Beneficiary Organizations (PIBOs), including producers, importers, and brand owners, to complete the filing of their Annual Returns by the 30th of November 2023 for the fiscal year 2022-23.
The Centralized EPR Portal for PIBOs and plastic waste processors (PWPs) was introduced on the 5th of April 2022. Since then, the CPCB has been encouraging all PIBOs to obtain their EPR certificate and submit their Annual Report.
Embracing Extended Producer Responsibility – EPR Compliance for Plastic Waste
EPR Compliance for Plastic Waste is a call for producers, importers, and brand owners to contribute to a sustainable environment by ensuring optimal waste management. Failure to comply with EPR guidelines carries penalties.
Who is Obligated to Follow EPR Compliance in India?
Producers, importers, brand owners, and plastic waste processors must strictly adhere to EPR Compliance in India when dealing with specified waste types outlined in the Plastic Waste Management Rules, 2016. This includes PIBOs engaged in recycling, waste-to-energy conversion, waste-to-oil processes, and industrial composting. Non-compliance may lead to penalties and environmental compensation.
Plastic Packaging Categories Covered Under EPR
The CPCB categorizes plastic packaging into the following:
| EPR Category | Plastic Category |
|---|---|
| Category I | Rigid plastic packaging |
| Category II | Flexible plastic packaging of single-layer or multi-layer plastic sheets |
| Category III | Multi-layered plastic packaging |
| Category IV | Plastic sheets or carry bags made of compostable plastics |
Setting EPR Targets
EPR targets, calculated category-wise, are outlined as follows:
| Category | Year | EPR Target |
|---|---|---|
| I | 2021-22 | 25% |
| II | 2022-23 | 70% |
| III | 2023-24 | 100% |
The increasing targets aim to promote higher reuse and recycling of plastics.
Details of Recycling
Section 15 of the EPR guidelines mandates that only recycling certificates from registered recyclers will be accepted while filing annual returns. The report must include details of the quantity sent for end-of-life disposal.
Timely Compliance to Avoid Penalties – CPCB Guidelines
The Ministry of Environment, Forest & Climate Change (MoEF&CC) has extended the timeline for filing annual returns twice to protect companies from penalties. Timely compliance not only upholds environmental responsibility but also prevents financial implications associated with non-compliance.
Penalties Structure
The CPCB outlines penalties for non-compliance:
- First Violation: Environmental compensation at Rs. 5000/- per ton
- Second Violation: Environmental compensation at Rs. 10000/- per ton
- Third Violation: Environmental compensation at Rs. 20000/- per ton
Repeated violations incur higher penalties, emphasizing the importance of timely submission of Annual Returns.
Procedure for EPR Certification
Under the Plastic Waste Management Act of 2016, obtaining an EPR certificate involves the following steps:
- PIBOs register through the Central EPR Portal Form-I of Plastic Waste Management Rules 2016.
- The application is reviewed by the State Pollution Control Board/Pollution Control Committee within 7 days.
- Registration is granted if the CPCB has not responded within one month.
Procedure for Filing Annual Reports
As of the 20th of November 2023, all PIBOs must submit their annual reports by the 30th of November 2023. This involves:
- Submission of Form IV under rule 17(1) of the Plastic Waste Management Rules.
- The report is submitted to the State Pollution Control Board/Pollution Control Committee/Central Pollution Control Board.
- A consolidated report is submitted in Form VI by the State Pollution Control Board based on the annual reports.
End-to-End EPR Services
CliniExperts provides comprehensive end-to-end EPR services, covering every aspect of compliance. From initial registration to compliance management, target achievement, and essential annual return filing, our services ensure your company complies with environmental regulations, minimizing the risk of penalties and damage to your reputation.
On-Demand EPR Add-on Services
In addition to core EPR services, CliniExperts offers on-demand EPR add-on services tailored to your company’s specific needs. Whether you require assistance in specific compliance areas, focused support to meet EPR targets, or advice on best practices, our adaptable add-on services have you covered.
Conclusion: Act Now for Lasting Compliance
The CPCB emphasizes the importance of timely compliance to avoid penalties, with the Annual Return filing deadline approaching swiftly. CliniExperts’ end-to-end EPR services provide a comprehensive solution to manage the complexities of EPR effectively. With our knowledge and experience in handling EPR compliance, we are the ideal partner to meet the 30th of November 2023 deadline and stay in compliance with the CPCB directive.
Partner with us to navigate the EPR landscape successfully. Contact CliniExperts today.