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Draft Environment Protection (EPR for Packaging Made from Paper, Glass, and Metal, as well as Sanitary Products) Rules, 2024: A Comprehensive Overview

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The Ministry of Environment, Forest and Climate Change (MoEFCC) introduced the draft Environment Protection (Extended Producer Responsibility for Packaging Made from Paper, Glass, and Metal, as well as Sanitary Products) Rules, 2024, on December 6, 2024 in New Delhi. These draft rules aim to enhance the management of packaging materials and ensure compliance with EPR guidelines. The goal is to ensure environmentally sound management of post-consumer paper, glass, and metal packaging (excluding non-ferrous metal-based packaging) and to promote a circular economy through reuse, recovery, and recycling.

Benefits of the EPR Rules:

The EPR on packaging and sanitary products will:

  • Promote the generation of wealth from waste.
  • Conserve resources by reducing the extraction of virgin resources.
  • Promote optimal use of materials.
  • Improve the quality of the environment across the country.

Materials Covered under EPR

The following materials are covered under EPR:

  • Packaging made of paper.
  • Packaging made of glass.
  • Metal packaging, excluding non-ferrous metal-based packaging covered under Hazardous Waste and Other Wastes (Management and Transboundary Movement) Rules, 2016.
  • Sanitary products.

It is important to note that packaging waste comprising plastic shall be governed and managed as per Plastic Waste Management Rules, 2016, as amended from time to time6.

Registration Requirements for Stakeholders

Registration Requirements for Stakeholders

To enhance the management of packaging materials and ensure compliance with EPR guidelines, the Central Pollution Control Board (CPCB) will establish a dedicated portal for the registration of various entities involved in the lifecycle of these packaging materials.

The following entities are required to register on this platform:

  • Producers: Entities engaged in manufacturing covered packaging and sanitary products, excluding micro and small enterprises as defined under the Micro, Small and Medium Enterprises Development Act, 2006
  • Importers: Entities importing covered packaging and sanitary products for commercial use, with an annual turnover of Rs. 10 crore and above 
  • Brand Owners: Entities selling commodities under a registered brand label/trade mark, including online platforms/marketplaces and supermarkets/retail chains, excluding micro and small enterprises as defined by the Ministry of Micro, Small and Medium Enterprises
  • Waste Processors: Entities processing packaging and sanitary waste made of paper (including paperboard), glass, or metal.

Note: Entities with EPR obligations for more than one type of packaging shall have a single registration.

Roles and Responsibilities of PIBOs

Producers, Importers, and Brand Owners (PIBOs) play a crucial role in implementing the EPR framework. Their responsibilities include:

  • Registering on the CPCB’s online centralized portal and providing information on their EPR target (packaging material-wise and sanitary product-wise, where applicable).
  • Reporting details of the packaging they buy from producers and importers, listing the amounts for each producer and importer separately.
  • Meeting EPR obligations for sanitary products by buying EPR certificates from registered incinerators operated by local authorities, authorised agencies, or common biomedical waste treatment facilities.
  • Operating schemes like deposit refund systems or buyback programmes to develop separate waste streams for the collection of packaging product waste and sanitary waste, preventing their mixing with other solid waste.
  • Submitting annual reports to the relevant CPCB/SPCB/PCC by June 30 of the next financial year, including details about the waste collected and processed under EPR, recycled materials used in packaging, and the registered recyclers they procured these materials from.

Roles and Responsibilities of Waste Processors

Waste processors are essential for managing and processing the collected waste. Their responsibilities include:

  • Registering with the concerned SPCB/PCC on the CPCB’s centralized online portal.
  • Submitting annual reports by April 30 of the next financial year, providing details of the type and amount of packaging and sanitary waste they have processed.
  • Issuing EPR certificates for processing packaging and sanitary waste to PIBOs, who can then use these certificates to meet their EPR requirements.
  • Ensuring that the amount of waste processed does not exceed their installed capacity and disposing of waste in an environmentally safe way, following relevant rules and guidelines.

The draft EPR Rules, 2024 represent a significant step towards promoting sustainable packaging practices and a circular economy in India. By clearly defining the roles and responsibilities of various stakeholders and setting targets for EPR, these rules aim to reduce the environmental impact of packaging waste and encourage responsible waste management practices.

Disclaimer: Above content does not constitute any legal advice and is only provided for educational purpose.

Climeto Sustainable Services Private Limited is an environmental consultancy. If you need any more information on the above you can contact us:
For Business Enquiry : business@climeto.com
For General Enquiry: info@climeto.com
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