Exploring EPR Targets for Plastic Waste Regulations: A Guide to Achieving Compliance

In this blog, we will discuss EPR Targets assigned to Producers, Importers, and Brand Owners. We will explain how these targets are calculated for plastic waste, the rationale behind them, the different types of targets, ways to meet them, and the consequences of failing to meet the targets. It is important to read this blog until the end as it provides crucial information.

Understanding the Flow of Plastic Packaging Waste in our Society

To grasp the concept of EPR (Extended Producer Responsibility) targets, it is essential to understand the flow of plastic waste. This involves understanding where plastic packaging comes from and how it eventually becomes waste. There are two main categories responsible for introducing plastic packaging into the market: Producers and Importers. Producers are companies involved in the manufacturing and supply chain of plastic packaging, while Importers are companies that either import plastic packaging directly or use plastic as packaging for their products. These Producers and Importers introduce plastic packaging into the market and usually sell it to Brand Owners (BO), who then sell the packaged products to consumers. Once consumers use the products, the plastic packaging often ends up in the trash or is improperly disposed of, thereby contributing to uncollected and unrecycled plastic waste, which harms the environment. For instance, when we buy a packet of chips, the packaging would have been manufactured by a Producer, purchased by the chips’ Brand Owner, and then sold to us as consumers. After consuming the chips, we often dispose of the packaging improperly, resulting in it becoming plastic waste. Unfortunately, not all of this waste is collected and recycled, which is detrimental to the environment. This scenario highlights the need for responsible management of plastic packaging and waste.

Keeping this concept in mind, we will now explain how targets are defined for Producers, Importers, and Brand Owners in the following sections. [If you have not yet applied for EPR Registration and are unsure if your company requires it, please check our blog on this topic, which also explains the entire registration process on the CPCB Portal – “Who needs EPR Registration and What is the Process?”]

EPR Target for Producers under Plastic Waste Management Rules

The image below depicts how EPR targets are calculated for Producers:

[Insert image – EPR Targets for Producers under Plastic Waste Management Rules]

The formula to determine the target is (A + B) – C. Here, A represents the average weight of plastic packaging material (categorized) sold in the last two financial years. B represents the average quantity of pre-consumer plastic waste in the same period. The image also provides a definition of pre-consumer plastic waste, which is self-explanatory. C is a crucial factor and represents the annual quantity supplied to Brand Owners and Registered Producers in the previous financial year. This means that Producers are assigned a target to recycle as much plastic waste (categorized) as they have sold, minus what they have supplied to Brand Owners or other registered Producers. In other words, Producers are not solely responsible for recycling the plastic waste they sell to registered Brand Owners and Producers; they can transfer that responsibility. The quantity transferred will be subtracted from their liability as Producers.

Refer to the following Hindi YouTube video for a detailed explanation of how EPR targets for plastic waste are calculated for Producers, Importers, and Brand Owners (BO) – with the logic behind them, different target types, ways to fulfill them, and the consequences of not meeting the targets.

EPR Target for Importers under Plastic Waste Management Rules

The image below illustrates the formula for calculating EPR targets for Importers:

[Insert image – EPR Targets for Importers under Plastic Waste Management Rules]

The formula to determine the target is (A + B) – C. Here, A represents the average weight of plastic packaging material and/or plastic packaging of imported products (categorized) imported and sold in the last two financial years. B represents the average quantity of pre-consumer plastic waste in the same period. C is a crucial factor that represents the annual quantity supplied to Brand Owners in the previous financial year. Similar to Producers, Importers can also transfer their liability to registered Brand Owners, and the quantity supplied to them (C) will be deducted from the Importers’ liability. It is important to note that these targets must be fulfilled in metric tons (MT) and by category for each financial year when filing the Annual Report.

EPR Target for Brand Owners (BO) under Plastic Waste Management Rules

Unlike Producers and Importers, the formula for determining the EPR Target for Brand Owners (BO) is simplified to just A + B, as shown in the image below:

[Insert image – EPR Targets for Brand Owners [BO] under Plastic Waste Management Rules]

Here, A represents the Average Weight of Virgin Plastic packaging material (categorized) purchased and introduced in the market in the last two financial years. B represents the average quantity of pre-consumer plastic packaging waste in the same period. As discussed earlier, once the plastic packaging leaves the Brand Owners and reaches the consumers, Brand Owners cannot transfer any liability further. Therefore, Brand Owners cannot pass on any liability, and their responsibility is directly tied to the total quantity resulting from A + B. Brand Owners are required to recycle this quantity category-wise annually and obtain EPR certificates/Credits before filing the Annual Report.

EPR Target Comparison for all categories

The table below provides a brief comparison of EPR targets for Producers, Importers, and Brand Owners. It is important to note that Producers and Importers have the option to transfer their obligation to registered Plastic Waste Processors (PIBOs), whereas Brand Owners cannot transfer their obligation. Understanding and accurately complying with EPR targets is crucial to avoid increased targets and difficulties in meeting the obligations.

[Insert table – EPR Target Comparison for all categories]

In conclusion, EPR targets play a vital role in responsible plastic waste management. Understanding how these targets are calculated and fulfilling them accurately is crucial for a sustainable future.

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