The Extended Producer Responsibility (EPR) framework underwent a significant overhaul with the amendment issued on March 14, 2024, marking a pivotal step forward in the country’s environmental regulations. This amendment introduced critical changes aimed at broadening the scope and bringing more stakeholders under the EPR compliance umbrella. The main highlights include:
- Inclusion of Importers and Manufacturers of Raw Materials: These entities are now officially part of the EPR framework, making them accountable for the lifecycle of plastic raw materials they handle.
- Inclusion of Sellers of Raw Materials: Sellers now share the responsibility for the plastic that enters the supply chain, bringing about an added layer of accountability in tracking and reporting plastic flow.
- Introduction of Category 5 for Plastic: Biodegradable plastic packaging and commodities have now been added to the existing categories, reflecting the government’s effort to encourage more sustainable plastic alternatives.
Despite these progressive steps, critical features to meet these new regulations are yet to be introduced on the EPR portal, raising questions about their implementation timeline.
The Gaps Identified in the Fourth EPR Appraisal Committee Meeting
The recent Minutes of Meeting (MoM) from the Fourth EPR Appraisal Committee further highlighted two key aspects:
- No EPR Targets for Micro and Small Producers: A noteworthy development for smaller businesses, the committee announced that micro and small producers would be exempt from EPR targets. Instead, these entities would be either pushed forward or absorbed into other segments of the supply chain, reducing their direct burden of compliance. However, it is unclear how the status (micro, small or medium) of the producers will be auto fetched from Udyam portal.
- Reporting Past Plastic Consumption: Entities that are yet to register on the portal are now expected to report their plastic consumption from previous years, going back to FY 2021-22. This retrospective reporting is designed to ensure that any liabilities from past activities are addressed and fulfilled through the portal.
- Unsurety of compliance cost newly included entities may incur: Companies who are importing or manufacturing raw material are unsure of the compliance cost they might incur in the future and how will they be able to manage the upcoming costs.
However, these updates bring up a key concern: the features to meet these provisions have not been introduced on the EPR portal. This not only hampers compliance for the newly included stakeholders but also leaves registered companies in a state of uncertainty about how to adjust their operations in line with the new requirements.
The Pending Implementation: A Cause for Concern
Given the important nature of these changes, the absence of necessary features on the EPR portal poses a pressing question: When will these functionalities be introduced?
As it stands, businesses are in limbo—eager to comply but unable to act due to the absence of proper tools and updates on the portal. For instance:
- Raw material manufacturers and sellers are unclear on how to log their inputs.
- Micro and small producers are left uncertain about how their shift in the supply chain will be reflected.
- Entities are unable to report previous years’ plastic consumption, thus failing to fulfill their retrospective liabilities from FY 2021-22.
These gaps create operational challenges for companies committed to maintaining compliance under the new amendment and fuel concerns about the timeline for the portal’s update.
Conclusion
While the amendment of March 14th and subsequent committee meetings show that the government is moving in the right direction toward more comprehensive plastic waste management, the EPR portal needs to keep pace with these changes. Until the portal’s functionality is aligned with the updated guidelines, stakeholders are left navigating uncertainties. It is now crucial for the CPCB to expedite the integration of these features into the portal, allowing businesses to effectively meet their EPR obligations.