As a trusted partner for over 400 clients in the plastic EPR landscape, we at Climeto have observed a recurring practice among Producers, Importers, and Brand Owners (PIBOs): the uploading of consolidated statements as part of their compliance submissions for FY 23-24. This raises a critical question: Is this practice allowed? And more importantly, Is it the correct way to meet compliance requirements?
The Background: Consolidated Statements in EPR Compliance
The Standard Operating Procedure (SOP) for registration in the EPR framework initially allowed PIBOs to upload consolidated statements for sales and purchase transactions. This was further endorsed by the Central Pollution Control Board (CPCB) for FY 22-23, when a general notice permitted consolidated statements to be used in compliance submissions.
However, the landscape appears to have shifted for FY 23-24. As we delved deeper into the updated SOPs and the guidance documents for the EPR portal, a crucial change became evident.
FY 23-24: A Shift in Compliance Requirements
Upon reviewing the SOPs and the guidance document for the EPR portal, we noticed that the procedure for entering sales and purchase transactions has become more stringent. The guidelines now explicitly require each transaction to be recorded individually, along with the corresponding invoice.
To ensure our understanding was accurate, we cross-checked this information with CPCB officials multiple times. The response was consistent and clear: each transaction must be uploaded separately.
This shift underscores a critical point for PIBOs: the compliance process for FY 23-24 mandates individual transaction entries. Each sales transaction entered on the portal generates a unique EPR Invoice Number, which must be included in the GST E-Invoice and shared with the purchaser of the plastic packaging.
The Challenge: Managing Compliance with Individual Entries
For many organizations, the requirement to upload each transaction individually, along with the associated invoice, is not just a procedural change—it represents a significant logistical challenge. The process can be tedious, time-consuming, and prone to human error, especially when dealing with a high volume of transactions.
Climeto: Your Partner in Efficient Compliance
At Climeto, we understand the complexities and demands of the compliance process. That’s why we’ve developed robust in-house systems capable of uploading up to 5,000 transactions on the portal in a single day, complete with the necessary invoices. Our expertise ensures that your compliance submissions are handled with the utmost accuracy and efficiency, minimizing the risk of errors and streamlining the entire process.
Disclaimer: Above content does not constitute any legal advice and is only provided for educational purpose.
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