Page 12 - Plastics News April 2023

AIPMA AT WORKT WORK
AIPMA A

EPR WORKSHOP
Initiatives taken by AIPMA to address plastic industry issues with respect to Plastic
Waste Management Rule 2016

Environment desk at AIPMA has been working with both industry and Government to facilitate the implementation
process of Extend Producers Responsibility (EPR). AIPMA has played a major role to fill in the gaps in the policy im-
plemented and enforced by Central Pollution Control Board and Ministry of Forest and Climate Change. In order to
formulate a comprehensive process, the CPCB has formed an Appraisal Committee Meeting, which includes AIPMA as
a member. Recently a second appraisal committee meeting was conducted by CPCB where some of the major issues
were put forward along with possible solution. The AIPMA representation was well addressed and most of the issues
were agreed upon by government officials. EPR has undergone some updates and changes which will make it easier for
units, primarily MSMEs, to register for EPRs.
Some of the major recommendation presented by AIPMA, which were amended in the EPR process.
S.NO. Issues raised by AIPMA Issues addressed by Ministry
1. Producers need to submit the CTO from SPCB • Provisional registration certification may be is-
without which unit is not able to proceed further sued to producers based upon the submission
with the EPR Application. of application for consent to operate (CTO).
• The tenure for provisional certificate may be
6months.
• The provisional registration may be extended
for another period of 6months.
• Direction may be issued to CPCB for directing
SPCB to delink the grant of CTO to producers
and Plastic waste processors from the penalty
for their operation without obtaining CTO be-
fore the date of application of grant of CTO.
2. In part C of EPR portal, in section 8, there are four • The provision for editing the data before sub-
subsection (A,B,C,D) required procurement and mission of application has been provided.
sales of last two financial year and • This has also been updated in manual by CPCB.
The section does not provide the opportunity to edit
once the data has been entered in the system.
3. Producers need to submit various other details such • The mandatory details such as production ca-
as production capacity, geo tagged location, pictures pacity, geo tagged location, pictures of raw ma-
of raw material storage area and production area, terial storage area as well as production area
DMP. may be taken.

• And, Extended Producer Responsibility regis-
tration certificate may contain a specific provi-
sion that all applicable statutory clearance may
be obtained by the unit.
4. Application are being rejected on the basis of dis- • An option may be provided to enable produc-
crepancy between the pre-consumption data and ers who produce plastic items other than plas-
sales data. tic packaging to mention about the quantity of
plastic raw material used for plastic items other
than plastic packaging.
5. The CPCB has introduced the concept of late fee • The late fee may become applicable after 21
mechanism where unit needs to submit certain % of days issues of show Cause Notice by CPCB/
fee ( late Fee Reply Submission) after 7 days of the SPCB.
Show Cause Notice issued by the CPCB/ SPCB.
• CPCB may decrease the quantum of late fee for
micro, small and medium producers.

12 PLASTICS NEWS April 2023