The Central Pollution Control Board (CPCB) has mandated that all PIBOs (Producers, Importers, and Brand Owners) registered during FY 2022-24 must submit their Annual Return (AR) for FY 2023-24 by 30th November 2024. Non-compliance will have serious repercussions.
What Happens If You Miss the Deadline?
Failure to file the AR on time will lead to:
- Auto-filing of AR: The system will automatically mark the AR as submitted.
- EPR Penalty for FY 2024-25: Your EPR target will be enhanced by 25% over and above your obligations for FY 2023-24.
Is the 25% Penalty Justified?
Interestingly, there is no specific provision in the Plastic Waste Management (PWM) Rules, 2016 mandating this 25% penalty enhancement. While this directive is being enforced, it raises questions about its legal grounding and transparency.
Portal Glitches Adding to the Stress
PIBOs have reported several technical glitches while filing their ARs. Despite these challenges, there’s no indication that the 30th November 2024 deadline will be extended.
The registration period shown on the portal (FY 2022-24) has caused confusion. Clear guidance from CPCB is urgently required on this matter.
Do Entities Registered in FY 2023-24 Need to File AR?
A major concern has arisen for entities that registered only during FY 2023-24. Many of these PIBOs are seeing prompts on the portal indicating they must file AR for FY 2023-24, even though they were not registered in FY 2022-23. Clarity from CPCB is essential to avoid unnecessary filings or penalties for new registrants.
Challenges for New Entities and EC Penalty Payments
- New Entities Facing Filing Requirements: There is significant confusion among entities registered in FY 2023-24 about whether they are required to file their AR this year. In some cases, the portal suggests compliance is necessary, causing frustration and uncertainty.
- Lack of Guidance on Environmental Compensation (EC) Payments: Entities penalized for non-compliance in earlier periods are unable to find clear instructions on where and how to pay EC penalties. Without proper guidance, the resolution of these penalties remains unclear, further complicating the compliance process.
What Should You Do Now?
- File Early: Don’t wait for the deadline. If you face technical issues, reach out to CPCB or the support team for assistance immediately.
- Seek Clarifications: Contact CPCB if you’re a newly registered entity or need guidance regarding past penalties.
- Stay Updated: Keep an eye on notifications from CPCB or consult compliance platforms like Climeto for the latest updates.
The looming deadline is a reminder for PIBOs to stay proactive. While challenges persist, ensuring timely filing is critical to avoid penalties. Let’s hope for greater transparency and support from CPCB in addressing these pressing concerns.
Stay compliant, stay proactive!
Disclaimer: Above content does not constitute any legal advice and is only provided for educational purpose.
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