NEW EPR Guidelines: Mandatory use of recycled packaging.

Targets given to producers not just for recycling but also the use of recycled packaging.

The new draft notification for Extended Producer Responsibility was released by Ministry of Environment, Forest and Climate Change on 6th October, 2021 under the plastic waste management rules 2016.

It covers three categories of plastic packaging namely:

Category 1: Rigid plastic packaging,
Category 2: Flexible plastic packaging made of single layer or more than 1 layer with different types of plastic &
Category 3: Multi-layered plastic packaging: at least 1 layer of plastic & at least 1 layer of material other than plastic.

EPR regulation covers reuse, recycling, use of recycled plastic content & end of life disposal. The draft specifies the quantity of waste that will have to be managed by producers, importers and brand owners who generate plastic packaging waste in India

It also for the first time mandates the use of recycled plastic content in packaging for all entities: Producers, Brand owners & Importers.

The draft gives producers, importers, and brand owners of plastic waste an opportunity to trade in EPR certificates. Surplus EPR certificates can be used for offsetting previous years shortfall; carry forward for use in succeeding year and it can be sold to other producers and brands.

Here’s a brief summary.

OBLIGATIONS Brand Owners Producers Importers
EPR target

Average weight of fresh plastic packaging purchased in last 2 years+ average quantity of pre-consumer plastic packaging waste in last 2 years.

Targets defined for each: Rigids, Flexibles and MLP by percentage year wise, increased to 100% for 2023/2024.

Average weight of plastic packaging sold in last 2 years. +average quantity of pre-consumer plastic packaging waste) – supplied to other entities in the last year.

Targets defined for each: Rigids, Flexibles and MLP by percentage year wise, increased to 100% for 2023/2024 and onwards.

Average weight of all plastic packaging or packaging of imported products imported & sold in last 2 years. +average quantity of pre-consumer plastic packaging waste in last 2 years)- packaging supplied to other entities.

Targets defined for each: Rigids, Flexibles and MLP by percentage year wise, increased to 100% for 2023/2024

Re-use

Targets defined for rigids only by percentage year wise, increased to 85% for 2026/2027 and onwards.

None

None
Recycling target for each entity

Minimum level of recycling (excluding end of life disposal) of plastic packaging waste collected under EPR targets for each entity: Brand owners, Producers & Importers. 

Rigid:
50% for 2023/2024
60% for 2024/2025
70% for 2025/2026
80% for 2026/2027 and onwards

Flexible:
30% for 20223/2024
40% for 2024/2025
50% for 2025/2026
60% for 2026/2027 and onwards

MLP:
30% by 2023/2024
40% for 2024/2025
50% for 2025/2026
60% for 2026/2027 and onwards

End of life disposal 

MLP only to be sent 

 

Use of recycled content for each entity (Mandatory)

Minimum level of use of recycled material in packaging defined as follows, common for all Brand owners, Producers & Importers. Recycled plastic used in imported material will not be counted toward fulfillment of obligation.

Rigid:
30% for 2023/2024
40% for 2024/2025
50% for 2025/2026
60% for 2026/2027 and onwards

Flexible:
20% for 20223/2024
20% for 2024/2025
30% for 2025/2026
30% for 2026/2027 and onwards

MLP:
5% by 2023/2024
5% for 2024/2025
10% for 2025/2026
10% for 2026/2027 and onwards.

 

Extended Producer Responsibility schemes are a vital part of any nation’s path towards achieving a Circular plastics economy in which waste is a valuable resource used to address a range of economic, social and environmental challenges. Lucro highly welcomes these new guidelines on Extended Producer Responsibility as a means to stimulate the transition towards a circular economy in India. EPR is needed to translate principles into action and is therefore crucial for a circular plastics economy, contributing to sustainable development.

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