
The Central Pollution Control Board (CPCB) in India has introduced a new provision on the Extended Producer Responsibility (EPR) portal, mandating Plastic Waste Processors (PWPs) to upload GST e-invoices for the sale of their products. This move aims to strengthen the EPR certificate generation process and curb the issuance of fake certificates.
certificate generation process and curb the issuance of fake certificates. What does this mean for PWPs?
PWPs are now required to upload signed copies of GST e-invoices for all sales of finished products. These invoices must contain specific details like Buyer and Seller GST numbers, IRN number, date of sale, HSN code, invoice amount, invoice number, and a QR code. The EPR portal will then validate these invoices against the GST Network information, ensuring only valid invoices are accepted.
Scrutiny and Audit:
The CPCB, along with State Pollution Control Boards (SPCBs) and Pollution Control Committees (PCCs), will use these e-invoices to verify information like seller and buyer details, product type, quantity sold, and date of sale. This information will then be used to calculate the quantity of plastic waste processed and generate EPR certificates.
Audits of PWPs are also being conducted, with around 150 completed to date. These audits have revealed several discrepancies, including invalid documents, missing or tampered QR codes and HSN codes, and the uploading of invoices for products other than recycled products6.
Concerns and Issues:
The new provision has raised concerns about the potential for increased scrutiny and penalties. Issues related to fake EPR certificates have already been raised in various forums, including the Ministry of Environment, Forest and Climate Change (MoEFCC), the GST Council, the National Green Tribunal (NGT), and even Parliament.
What if a PWP wants to avoid scrutiny?
The sources do not offer any information or guidance on how to avoid scrutiny. However, it’s crucial to understand that the CPCB has implemented these measures to ensure compliance with EPR guidelines and prevent fraudulent activities. PWPs must adhere to the new regulations and ensure all uploaded documents are valid and accurate.
Tips for PWPs:
- Thoroughly check all documents before uploading them to the EPR portal, ensuring all details are accurate and clearly visible.
- Only upload GST e-invoices for sales of finished recycled products, avoiding any other product categories.
- Ensure all QR codes and HSN codes are valid and untampered.
- Avoid uploading the same document multiple times.
- Maintain transparent and accurate records of all transactions, including sales to sister concerns.
By following these steps, PWPs can ensure compliance and minimize the risk of scrutiny and penalties.
Remember, the EPR portal’s new provision is designed to enhance transparency and accountability within the plastic waste management system. By understanding and adhering to the requirements, PWPs can play a vital role in achieving a sustainable and circular economy for plastics.
Sources:
1. Minutes of Stakeholder consultation dated Nov 27.
2. Instruction sheet PWP sales accessible here.
Disclaimer: Above content does not constitute any legal advice and is only provided for educational purpose.
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