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EPR Compliance In India
Overview
India faces a significant challenge with its daily production of thousands of tonnes of plastic waste, exacerbated by the fact that only 60% of this waste is collected, leaving the remaining 40% unaccounted for and posing serious environmental and health risks. To address this issue, India has introduced Extended Producer Responsibility (EPR) compliance regulations under its waste management rules. These regulations mandate that producers, manufacturers, and importers take responsibility for recycling the waste they generate annually, thereby mitigating environmental impact and safeguarding public health.
Understanding EPR Compliance in India
The EPR Policy in India is founded on the 'Polluter Pays' principle, where producers are responsible for managing and disposing of their products once they are no longer needed or usable. Adopted by the Government of India, this policy mandates that businesses go beyond manufacturing and distributing products by ensuring the proper disposal or recycling of waste generated from their goods. EPR, which stands for Extended Producer Responsibility, holds producers accountable for maintaining a clean and safe environment through effective waste management practices.
Different Types of EPR Compliance in India
Extended Producer Responsibility (EPR) compliance varies depending on the type of waste, such as Electronic Waste (E-Waste), Battery Waste, Hazardous Waste, and Plastic Waste. In India, producers must obtain certificates under specific rules governing each waste category, ensuring proper management and processing.
E-Waste: When an electrical or electronic product is discarded due to malfunction or any part failure, it typically undergoes refurbishment or repair. If it fails these processes and cannot be restored, it is classified as e-waste.
EPR Compliance for Plastic Waste: Plastic waste encompasses discarded plastic materials that are no longer required and have become waste. This category includes a wide range of plastic products like packaging materials, single-use plastics, plastic bottles, containers, and other disposable plastic items.
EPR Compliance for Battery Waste: Battery waste refers to the waste produced from cells, batteries, or their components, including accumulators. These items generate electrical energy through the direct conversion of chemical energy and encompass both disposable primary and secondary batteries.
EPR Compliance for Tyre Waste: Tyre waste denotes tires that have been discarded or used to the point where they are no longer functional and have become waste. Tires are employed in a range of vehicles such as cars, trucks, and buses, and they transition into waste when they are damaged, worn out, or exchanged for new ones.
Advantages of EPR Compliance in India
The Extended Producer Responsibility (EPR) Policy was introduced with the aim of achieving multiple environmental benefits. Additionally, it offers advantages to producers, governments, and society at large. These benefits of the extended producer responsibility policy can be categorized as follows:
Benefits for the Government: Annually, the government allocates substantial funds towards waste management. EPR serves as a viable solution by transferring the responsibility for waste management, disposal, and recycling entirely to producers. This significantly reduces government expenditure, freeing up resources that can be redirected towards various other schemes instead of managing waste generated by businesses.
Benefits for Society: Under EPR, producers are mandated to conduct awareness campaigns that educate citizens on recycling processes and waste collection. These initiatives play a crucial role in fostering a more informed society that actively participates in the country's sustainable development efforts.
Benefits for the Environment: EPR encourages producers to minimize the use of hazardous substances in their products. This initiative aims to reduce the circulation of harmful chemicals and toxins, thereby lowering the environmental risks associated with exposure to these substances.
Benefits for the Producers: Through this approach, the government incentivizes producers to prioritize the development of environmentally-friendly products whenever feasible. Producers are motivated to adopt such practices not only to enhance environmental sustainability but also to mitigate EPR costs associated with product recycling.
Fostering a Culture of Recycling: EPR promotes a recycling culture within society by not only engaging producers but also educating citizens through awareness campaigns. This encourages consumers to responsibly deposit recyclable materials, which producers then collect and recycle as part of their EPR obligations.
Who Must Adhere to EPR Compliance in India?
In India, compliance with EPR regulations is mandatory for producers, manufacturers, brand owners, importers, recyclers, refurbishers, resellers, and other waste generators dealing with specified waste types under the waste management rules. These waste categories encompass E-Waste, Plastic Waste, Battery Waste, and Hazardous Waste, each governed by distinct regulations. Businesses engaged in activities such as battery recycling, solar panel production, or use of plastic packaging must adhere to all relevant EPR guidelines.
The Producer's Responsibilities
Producers responsible for generating waste that requires treatment to maintain a clean and healthy environment are obligated to comply with EPR regulations in India. This ensures they take responsibility for mitigating the environmental impact caused by their business operations. The scope of responsibility includes
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Promoting Waste Management
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Promoting Waste Management
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Collection of EPR Certificates
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Label their products with appropriate recycling instructions
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Collect their end-of-life products
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Direct the waste for recycling or refurbishing
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Directing waste to Treatment, Storage, and Disposal Facilities (TSDFs)
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Fulfil EPR Targets on a yearly basis
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Filing of returns to the CPCB Portal
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Provide information on waste collection centers in conjunction with product sales
Upon obtaining EPR Registration via the EPR Portal of the Central Pollution Control Board, businesses must adhere to various waste management compliances. Failure to comply may result in penalties or revocation of the authorization issued by the department. Penalties typically involve environmental compensation measures.
Documentation Needed for EPR Compliance in India
Verification Requirements for Companies
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KYC Certificate
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Authorized Signatories
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Board Resolution
Verification Process for Land Ownership
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Rent Deed, or
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Lease Deed, or
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Land Ownership Certificate
Verification of Tax Liability
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Company Pan Card
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Company Pan Card
Responsibility in EPR Compliance
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Responsibility in EPR Compliance
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EPR Plan
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EPR Certificates
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Annual Filing Receipt
Renewal of EPR Obligations and Adjusted Targets
If producers fail to meet their EPR targets in the current financial year, any remaining extended producer responsibility obligation will be carried forward and added to their next year's requirement. These recycling targets are defined in the waste management rules and regulated by the Ministry of Environment, Forest and Climate Change. Monitoring is overseen by the respective Pollution Control Board or Committee. The targets depend on the quantity of products introduced to the market by the company in the previous financial year and the accumulated EPR obligation carried forward.
WHY USE ABSOLUTE VERITAS (AV) FOR EPR CERTIFICATION?
Absolute Veritas is a prominent organisation from the private sector of India primarily dealing with the Inspection, Testing, Audits, Certification of products& consulting services to various industries in India and worldwide, ensuring compliance with regulatory standards and industry requirements. Offering a comprehensive range of services including product certification, testing, training, auditing, and compliance services, Absolute Veritas helps manufacturers and importers achieve higher production efficiency and quality standards.
Absolute Veritas (AV) will handle end to end pre-registration request, sample preparation, documentation, testing and application process for EPR Certification
For any questions regarding the most recent update on EPR registration licenses, please reach out to us via email at cs@absoluteveritas.com
Frequently asked questions (FAQ)
What does EPR mean?
EPR represents a method to address the increasing challenge of waste management, involving producers taking responsibility for managing the waste generated by their businesses.
What is EPR Compliance?
EPR Compliance pertains to adhering to regulations set for producers concerning waste management related to their businesses. This entails registering with the CPCB and adhering to specific waste management guidelines.
Who Must Comply with EPR Regulations?
Businesses generating waste regulated by the CPCB must adhere to all EPR compliance requirements outlined in the respective waste management rules. These regulated wastes encompass categories such as E-Waste, Plastic Waste, Battery Waste, and Tyre Waste.
Which EPR Regulations Are Currently Effective?
The Ministry of Environment, Forest, and Climate Change issues regulations for waste management, including the notification of the E-Waste and Battery Waste Management Rules in 2022. Additionally, amendments were made to the 2016 rules governing Plastic Waste and Hazardous Waste Management in the same year.
What does the Polluter Pays Principle entail?
The 'Polluter Pays' principle assigns waste management responsibility to businesses that generate waste through their products circulated in the market. According to this principle, producers are accountable for recycling, refurbishing, and disposing of waste generated from their products at their own expense.
What is the Extended Producer Responsibility (EPR) policy in India?
Under India’s EPR Policy, both State and Central Governments register producers, oversee their activities, maintain product-related data, and allocate annual EPR obligation targets. Producers must meet these targets by year-end; any unmet obligations are carried over to the following year.
How are EPR obligations adjusted annually?
If a producer fails to meet their EPR target by the end of the current financial year, any outstanding EPR obligation will be carried forward and included in their EPR obligation target for the following year.
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