Page 41 - Plastics News December2018

FEATURES
In the stakeholders meeting is was suggested that ii.
only non-recyclable and non-energy recoverable
plastic should be banned. However, practically there
is no plastic which is not recyclable or non energy
recoverable. Therefore, there is no need to ban MLP.
However, the rules need to be implemented properly.
Since there is particular mention of BIS standards, the
definition excludes energy recovery as option. Energy
recovery option for all sorts of plastics to be included
in the rules.
Recommendations: The committee noted that MLPs iv.
are used world over and it is not banned anywhere.
The committee also noted that MLPs perform a
very important function, especially in the food
processing industry. The committee was of the view
that we should remove the Rule regarding banning
of MLPs from the PW Rules. MLPs waste should be v.
regulated and its use in WE plants, cement plant etc
be promoted. CPCB should modify its guidelines to
reflect the fact that MLPs would also be used in the
above plants in a safe manner.
Further the committee opined that the ‘modified EPR’
scheme outlined in its recommendations for rules 6 &
9 as mentioned above, should be adopted for MLPs as
well. Thus producers/brand owners would be required
to pay a specified fee spending on the quantum of
production of MLPs. The fees should be higher than
that of plastic producers/ brand owners to reflect the
fact that processing MLPs is a more resource intensive
operation. Details of the fund and related modalities
could be worked out separately by the committee,
once this principle is accepted.
v. Rule 13 - Registration of producer, recyclers and
manufacturer,- Every producer shall, for the purpose
of registration or for renewal of registration, make an
application to the State Pollution Control Board or the
Pollution Control Committee of the Union territory
concerned, in Form I.
Discussion: Following queries were raised through
representations
i. With respect to registration of Brand Owners
who do not have any manufacturing units, are
they required to register their administrative/
registered office as a unit?
Registration process and required documentation
as well as online registration procedures are not
clarified.
iii. Is there a Central Registration system to avoid
or duplication of registration for the same
manufacturer, in case he produces in more than
one state? Same for Brand Owners- do they need
to apply for registration in every state they
produce/sell or is there a Central Registration
System for Brand Owners as well.
Though Importers are covered under Rule 9 as
responsible for primary collection as a producer
and brand owner. However, they are not required
to register under Rules 13 nor are relevant forms
available for them.
Rule 13(10) requires pollution control board to
provide an opportunity of being heard to the
producers etc. before revoking, suspending of
cancelling of the registration. Similar opportunity
should be given while refusing the registration.
During the stakeholders consultation it was
mentioned that the definition of producers to be
corrected as it includes all the consumers in its
purview. Registration form has options only for
registration of producers and brand owners with
no provision for registration of manufactures.
Further, the rate for the registration has to be
fixed. It was also mentioned that the provisions
for registration of companies importing products
with MLP needs to be incorporated. Responsibility
for development of guidelines for national
registration is to be vested with CPCB as well
as local municipal bodies. Companies are not
being able to register as definite guidelines for
registration do not exist as of now.
Recommendation: A detailed deliberation
on the issue took place in the meeting. The
Committee recommended that a centralized
registration system should be evolved by CPCB
for the registration of the Producer/Importer/
Brand owner. The Committee referred to
the existing system adopted for the e-waste
management system for centralized registration.
The committee also noted that the centralized
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43 December 2018 Plastics News