EPR Registration for Plastic Waste Management
Plastic packaging is an essential part of today’s business. Plastic waste management is now an essential part of it too. The Plastic Waste Management rules have made it mandatory for Producers, Importers, and Brand Owners (PIBOs) to adhere to Extended Producer Responsibility (EPR).
Whether you are using plastic packaging in India or not, EPR registration is applicable to you.
What is Extended Producer Responsibility (EPR) for Plastic?
Extended Producer Responsibility is a system whereby a producer is made legally responsible for ensuring that their product is disposed of in an environmentally safe way throughout its entire life cycle, from production to final disposal.
Pertinently, under the Plastic Waste Management Rules, 2016 (amended), PIBOs are obligated to ensure that the plastic packaging they introduce into the market is:
- Collected
- Recycled
- Reused
Or disposed of in an environmentally safe way
The EPR for Plastic is enabled by a centralized portal created by the Central Pollution Control Board (CPCB), under the Ministry of Environment, Forest and Climate Change (MoEFCC).
Who Requires EPR Registration for Plastic Waste?
The following are required to obtain EPR Registration:
Producers
Persons who produce plastic raw material or components of plastic packaging
Importers
Persons who import plastic packaging material or products in plastic packaging
Brand Owners
Persons who sell products under their own brand using plastic packaging, including e-commerce platforms
Plastic Waste Processors (PWPs)
Including:
Recyclers
Waste to Energy
Waste to Oil
Industrial Composters
Registration Authority
If Operating in 1-2 States/UTs
Register with concerned State Pollution Control Board (SPCB)/Pollution Control Committee (PCC)
If Operating in more than 2 States/UTs
Register with Central Pollution Control Board (CPCB)
Operating without EPR
Registration is a violation and may attract environmental compensation.
Plastic Packaging Categories Under EPR
The EPR applies to the following plastic packaging materials:
- Rigid plastic packaging
- Flexible plastic packaging, multi-layered plastic packaging, carry bags, plastic sheets, sachets, pouches
- Multi-layered packaging consisting of plastic and non-plastic materials
- Plastic sheets for packaging, compostable plastic carry bags
Our streamlined process ensures smooth approval from application to certification.
Key Responsibilities Under EPR
The key responsibilities under EPR are as follows:
Registered PIBOs are required to:
Register on CPCB EPR Portal
Complete online registration with accurate details
Submit an Action Plan
Develop a detailed plan for the collection and recycling of plastic waste
Meet Assigned EPR Targets
Fulfill their obligations as per the plastic packaging put into the market
Ensure Recycling/Reuse
Verify that plastic waste is being processed through a recycler
Use Recycled Content
Mandatory tie-ups with Recyclers for the disposal of E-Waste
Obtain Plastic Waste Processing Certificates
Also referred to as Plastic Credits from the respective PWPs.
File Annual Returns
Regular filing of compliance reports on the EPR Portal.
Documents Required for EPR Registration
For Producers, Importers, Brand Owners:
PAN Card of Company
GST Registration Certificate
CIN (Company Incorporation Certificate)
IEC (Import Export Code) – in case of Importers
Aadhaar/PAN of Authorized Signatory
DIC Registration – in case of applicability
Details of Plastic Packaging Categories
Quantity of Plastic Placed in the Market
EPR Action Plan
Proof of Registered Office
Board Resolution / Authorization Letter
or Plastic Waste Processors (PWPs) — in addition:
SPCB Consent to Establish & Operate
Process Flow Diagram
Geo-tagged Photographs of Facility
Waste Processing Capacity Details
Pollution Control Equipment Details
Plastic Waste EPR Registration Process
Our Plastic Waste EPR Consulting Services
We at SR Services offer complete EPR consulting services for plastic waste management.
Complete EPR Registration Support
End-to-end support for CPCB/SPCB Portal Registrations
Action Plan Preparation
Strategic planning document detailing your plastic waste collection and recycling strategy
Target Calculation & Compliance Strategy
Accurate calculation of EPR targets based on your plastic material use.
PWP Tie-Ups & Plastic Credit Management
Access to authorized Plastic Waste Processors and plastic credit management
Annual & Quarterly Return Filing
Timely compliance filing to remain in good regulatory standing
Renewal & Continuous Compliance Support
Timely renewals and ongoing support for changing regulatory requirements
Advisory on Single-Use Plastic Restrictions
Advisory on restricted single-use plastics and available alternatives
Plastic Waste EPR Registration – FAQs
- 1 Is EPR registration compulsory for plastic packaging?
- Yes. All Producers, Importers, and Brand Owners (PIBOs) using plastic packaging have to register under the Plastic Waste Management Rules.
- 2 Is it applicable to small businesses?
- Yes. It does not matter whether the business is small or large. If plastic packaging is used in the business, compliance with the regulations is a must.
- 3 What are the consequences of non-compliance?
- Non-compliance may invite environmental compensation, seizure of products, and legal consequences. CPCB may impose a heavy penalty.
- 4 Can I engage a PRO to handle my EPR obligations?
- Yes. A Producer Responsibility Organization (PRO) can be engaged to handle the Producer Responsibility Obligation. However, the obligation remains with the PIBO.
- 5 How often do I need to file returns?
- Annual returns need to be filed on the CPCB portal. Quarterly returns may also need to be filed in some states.
- 6 What single-use plastics are banned?
- Plastic cutlery, plates, cups, straws, earbuds with plastic sticks, and sachets are among the single-use plastics banned from July 1st, 2022.
- 7 Do you help with recycler tie-ups?
- Yes. SR Services helps with recycler tie-ups and with transactions involving plastic credits with authorized Plastic Waste Processors.