Brand Owner: “Brand Owner” means a person or company who sells any commodity under a registered brand label or trademark.
However, if the brand owner are micro or small under MSME (Ministry of Micro, Small & Medium Enterprises) they are exempted from the EPR regulations.
As brand owners navigate the complexities of Extended Producer Responsibility (EPR), accurate calculation of pre-consumer and post-consumer waste generation is crucial. The Plastic Waste Management Rules (PWMR) define these terms as follows:
– Pre-consumer waste: Scrap generated during the packaging process.
– Post-consumer waste: Waste generated after the consumer has used the product.
Calculating Pre-Consumer Waste
To calculate pre-consumer waste, brand owners can use the following data points:
- Sales of plastic scrap under HSN 3915 in the accounting system.
- Accounting system data on scrap of plastic packaging sold.
Calculating Post-Consumer Waste
For post-consumer waste, there are two approaches:
Approach 1:
- Identify the quantity of plastic packaging issued from stores.
- Subtract pre-consumer waste from this quantity.
Assumption: All packaging issued and used will be put in the market in the same financial year.
Approach 2:
- Identify the quantity of packaging for each unit of SKUs.
- Multiply this quantity by the number of each SKU sold.
Challenges:
– Identifying the quantity used for each SKU.
– Accounting for secondary and tertiary packaging.
State-wise Division of Post-Consumer Waste
Once the post-consumer waste number is calculated, it needs to be divided state-wise. This can be done by:
– Referring to actual figures.
– Using state-wise sales as a proportion.
Categorization of Waste
It’s essential to classify the waste figures category-wise (Cat 1, 2, 3, or 4) as defined in the rules.
By understanding these calculations and challenges, brand owners can better navigate EPR requirements and ensure compliance.
Disclaimer: Above content does not constitute any legal advice and is only provided for educational purpose.
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