Plastic Waste EPR: registration and targets for producers, importers and brand owners.

Producers of plastic packaging, importers of plastic packaging or of products in plastic packaging, and brand owners who sell products in plastic packaging: collectively PIBOs. The obligation follows the packaging placed on the market, so a brand owner who buys packaging rather than making it is still obligated. Plastic waste processors register separately in their own capacity.

Category I is rigid plastic packaging. Category II is flexible packaging of single layer or multilayer plastic, including sheets, carry bags, pouches and sachets. Category III is multilayered packaging with at least one layer of plastic and at least one layer of a material other than plastic. Category IV is compostable plastic packaging. Targets are computed and discharged category by category, so packaging must be classified correctly. A certificate in one category does not satisfy a shortfall in another.

It depends on footprint. An entity operating in more than one state or union territory registers with the Central Pollution Control Board; an entity operating within a single state registers with that State Pollution Control Board or Pollution Control Committee. Both routes run through the centralised EPR portal, but the registering authority differs and determines who you deal with on queries.

EPR certificates are generated on the portal by registered recyclers, waste-to-energy and other plastic waste processors against the plastic waste they actually process. An obligated entity fulfils its target by acquiring certificates of the right category and quantity and mapping them against its obligation on the portal. The certificate, not a contract or an invoice, is what the portal treats as fulfilment.

It is derived from the quantity of plastic packaging the entity introduced into the market in earlier years, applied at the percentage the guidelines prescribe for the year in question, and computed separately for each category. Since the target is driven by declared quantities, the sales and procurement data behind the declaration is the foundation of the whole compliance position.

They are separate obligations under the same rules. The single-use plastic prohibition bans the manufacture, import, stocking, distribution, sale and use of specified items outright, no registration or target can make a banned item lawful. EPR governs the packaging that remains permitted, by requiring the entity that put it on the market to fund and evidence its collection and processing.

The unfulfilled portion attracts environmental compensation levied by the pollution control authority, and paying it does not extinguish the obligation: the shortfall carries forward and still has to be met, within the period the guidelines allow. Non-registration and misdeclaration carry their own consequences, including action under the Environment (Protection) Act.

The registration and the liability stay with the obligated entity. They cannot be assigned away. What can be arranged through service providers and aggregators is the practical work of sourcing certificates from registered processors and reconciling them on the portal. If those certificates are later found invalid, it is the obligated entity that is short.