Page 13 - Plastics News April 2023

AIPMA A
AIPMA AT WORKT WORK

6. Producers (in case of multiple location) need to sub- • As per clause 6.5 of guidelines on EPR for plastic
mit unit wise registration even enough within a state. packaging, more than one unit in the same state
will have one EPR registration number.

• Multiple units in the same state/UT may get all
units registered through one application. Op-
tion may be given to provide details of all units
in one application. In the same application, sepa-
rate units may be captured by giving separate
details of each unit.
• In case, where the entity fall in more than one
sub-category then separate registration will re-
quired.

• Accordingly, different units in the same state
under same sub-category will have same EPR
registration number.
7. Recording procurement and sales operation. Every • Already vide OM dated 13th March 2023, CPCB
invoice needs to be uploaded on the EPR portal. has been requested to allow for bulk uploading
of data on a quarterly basis.
8. EPR is too complex for producers. The main objec- • Micro and Small producers and importers may
tive of the rule is based on Polluter Pays Principle. be considered for EPR registration based on
self- declaration for calculation of EPR Targets.
• The requisite documents may be verified at the
time of audit.
9. Rigid plastic of industrial nature is not the part of • Already it has already been clarified vide OM
plastics waste problem. Rigid plastic is already get- dated 14th February 2023 that rigid plastic
ting recycled and is never seen in the landfill. crates would be treated as plastic commodities
and rigid industrial drums which are reused by
the industry would be reduced from EPR tar-
gets subject to provision of requisite documen-
tation prescribed by CPCB.
10. Closure notices issued to the non-registered pro- • CPCB is requested to extend the last date till
ducers after 31.03.2023. 30th April 2023.

11. Country doesn’t have sufficient plastic waste pro- • At present cumulative EPR targets for around
cessing facility. 6300 registered PIBOs is 2.32 million tonnes
per annum.
EPR framework is based on the premise that credits
generated by plastic waste processors in the form of • The recycling capacity of around1600 registered
EPR certificate will be available for PIBO- Producers, plastic waste processors is 15 million tonnes per
Importers, and Brand Owners. annum. There is ample recycling capacity avail-
able.
If plastic waste processing capacity is not available in
the country, then sufficient EPR certificates will not • PIBOs need to be part of effective utilisation
available and such a business model will not work of existing capacity as well as any expansion, if
and EPR framework cannot be successfully imple- needed as PIBOs have been given the independ-
mented. ence about the adoption of modalities to meet
their EPR targets.
Environmental Compensation for current year may
be waived off if possible.

PLASTICS NEWS 13
April 2023