Extended Producer

Responsibility (EPR)
for plastic waste
India’s annual plastic waste production amounts to 3.5 million tonnes, with only half of it being properly processed. The remainder
is strewn across the environment, finding its way into water bodies and landfill sites, posing significant threats to the ecosystem1.

To tackle this issue, the Ministry of Environment, Forest and Climate Change (the ministry) notified the Plastic Waste Management
Rules, 2016 (PWM Rules). These rules mandate plastic waste generators to reduce waste generation actively, prevent littering,
store waste separately at its source, and hand over segregated waste in accordance with the regulations.

In line with this effort, the ministry further released detailed guidelines on EPR for plastic packaging in February 2022. These
guidelines provide a framework for the implementation of EPR, including the roles and responsibilities of producers, importers,
brand owners, recyclers, waste processors, etc. The PWM Rules via EPR have cast responsibility on producer, importer, and brand
owners (PIBOs).

Taking a proactive stance to ensure compliance, the Central Pollution Control Board has initiated issuing show-cause notices to all
the unregistered PIBOs. This step is intended to drive them towards registration and adhere to the PWM Rules, thereby promoting
responsible waste management practices.

Entities required to get registered:

01 Producer (P) of plastic

packaging
02 Importer (I)
A producer is a person engaged in the A person who imports plastic packaging products
manufacture or import of carry bags or multi- or products with plastic packaging or carry bags
layered packaging or plastic sheets or the like, or multi-layered packaging or plastic sheets or
and includes industries or individuals using the like
plastic sheets or the like, or covers made of plastic
sheets or multi-layered packaging for packaging
or wrapping the commodity

03 Brand owner (BO) 04 Plastic waste processor

(PWP)
• A person or company who sells any Recyclers and entities engaged in using
commodity under a registered brand label or plastic waste for energy (waste to energy),
trademark. and converting it to oil (waste to oil), industrial
• BO, including online platforms/ marketplaces composting
and supermarkets/ retal chains other than
those, which are micro and small enterprises,
as per the criteria of MSME.

Notes:
• Separate registration would be required for each of the above categories.
• Registration and renewal application are to be made before the concerned State Pollution Control Board/ Pollution Control
Committee or Central Pollution Control Board (as applicable).
• Goods imported in plastic packaging by service providers (IT/ ITeS companies, R&D units, etc.) are also covered.
• Importers of various items, such as primary products, chemicals, machinery, textiles, articles, etc., which are not plastic
packaging but are packed in plastic packaging, are also required to take the said EPR registration.
1. https://pib.gov.in/PressReleseDetail.aspx?PRID=1849865

2 Extended Producer Responsibility (EPR) for plastic waste

Coverage of Extended Producer Responsibility:

Category 01 Category 02 Category 03 Category 04

Rigid plastic packaging Flexible plastic Multi-layered plastic Plastic sheet or the like
packaging of single packaging (at least used for packaging
layer or multi-layer one layer of plastic as well as carry bags
(more than one layer and at least one layer made of compostable
with different types of of material other than plastics.
plastic), plastic sheets plastic)
or the like and covers
made of plastic sheet,
carry bags, plastic
sachets or pouches

Role and responsibilities of PIBOs

• Obtain EPR registration and prepare a plan of action.
• Fulfil EPR obligations (refer Annexure 1) based on the targets provided in the guidelines for:
– Recycling
– Use of recycled content
– Reuse
– End-of-life disposal
• Maintain required records
• File annual returns

Impact of non-compliance on PIBOs

• The entities covered under the registration requirement cannot carry out business without obtaining registration.
• The entities registered under EPR cannot deal with entities required to obtain EPR registration but have not registered
themselves.
• Imposition of environmental compensation (EC) in case of failure to meet the EPR targets. Kindly note that the payment of EC
does not absolve PIBO from EPR obligations.

Extended Producer Responsibility (EPR) for plastic waste 3

How can Grant Thornton
Bharat help?
Our team of professionals can provide a solution for evaluation,
applying for registration, assisting in representing before the
authorities, including for resolution of ambiguity and assisting
in annual filings.

Evaluate registration
requirement

• Evaluate registration requirement and, if necessary,

represent before authorities for discussion and resolution of
ambiguity (if any).

Prepare and file registration

application

• Review and collate requisite documents/information/action

plan/plastic waste quantity details/ etc to prepare the
application.
• Assist in filing an application before the State Pollution
Control Board or Central Pollution Control Board as
applicable.

Support in obtaining registration

certificate and representing
before authorities

• Support in obtaining a registration certificate, including

following up with the authorities.
• Preparation of additional replies, queries, and
representation before the authorities (if necessary).

Filing annual returns

• Assist in preparing and filing annual returns.

4 Extended Producer Responsibility (EPR) for plastic waste

Annexure 1 - EPR obligations
EPR target: Obligation for recycling:
% of EPR target
Year EPR Target (% of Q)

2021-22 25 % Plastic 2027-

packaging 2024-25 2025-26 2026-27 28 and
2022-23 70 % category onwards

2023-24 100 % Category I 50 60 70 80

Category II 30 40 50 60
For producer and importer
Category III 30 40 50 60
Q = (A + B) – C
Category IV 50 60 70 80
For brand owner
Q=A+B

Where
Q: Eligible quantity in MT

A.
For producer - Average weight of plastic packaging
material (category-wise) sold in the last two financial years. Obligation to use recycled
For importer - Average weight of all plastic packaging plastic content:
material and/or plastic packing of imported products
% of plastic manufactured (P)/ imported plastic (I)/
(category-wise) imported and sold in the last two financial
manufactured (BO) for the year
years.

For brand owner - Average weight of virgin plastic

packaging material (category-wise) purchased and Plastic 2028-
packaging 2025-26 2026-27 2027-28 29 and
introduced in the market in the last two financial years. category onwards

B: Category I 30 40 50 60
Average quantity of pre-consumer plastic packaging waste
Category II 10 10 20 20
in the last two financial years.
Category III 5 5 10 10
C:
Annual quantity supplied to the brand owner in the previous
financial year. For importer - Only option is to buy EPR certificates for
fulfilling this obligation.

End of Life disposal: Additional obligations:

PIBO’s shall ensure end-of-life disposal of the plastic Additional obligation to be fulfilled based on PWM Rules
packaging waste only through methodologies specified in and EPR guidelines
PWM Rules.

Note:
Producers, importers and brand owners can also meet their EPR obligations under a category by purchasing surplus EPR
certificates from other producers, importers, brand owners and PWP of the same category.

Extended Producer Responsibility (EPR) for plastic waste 5

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