Extended Producer Responsibility – The Complete Guide

Extended producer responsibility is a policy measure in which brands, Manufacturers, traders and recyclers should take complete responsibility for handling the waste streams and efficiently disposing of them.

EPR shifts the economic burden of recycling and disposal from the centre to producers and manufacturers and affects the economic, environmental, and social factors. Extended Producer Responsibility is a policy approach in which producers are responsible for managing products’ disposal until their end lifecycle.

The Plastic Waste Management Rules 2016 mandated the generators of waste to take specific steps to minimize the generation of plastic waste, ensure segregation, and hand over the waste to local bodies or agencies. These rules included several new provisions and the introduction of Extended Producer Responsibility.

Plastic Waste Management in India

The increase in plastic products’ use gave rise to a global concern regarding this polymer’s disposal. Its applications which include packaging, wrapping, fluid containers, shopping, garbage bags, clothing, and toys, made it an integral part of our daily lives. Recycling virgin plastic materials can be repeated two or a maximum of three times as, after every process, the material deteriorates, and its life span reduces. But recycling is not considered a permanent and safe solution for the disposal of plastic waste.

The waste generation market of plastic in India results from rapid urbanization, the spread of retail chains, plastic packaging used for grocery food and vegetable items, and many other cosmetic and consumer materials. The things that have contributed to the massive increase in plastic waste:

• The lack of a foolproof system of disposal for the plastic waste we generate daily. The centre and state governments enacted various laws but gained very little success.
• The lack of people’s will is a primary reason why almost all the laws fail miserably. The citizens are not aware and do not understand the harmful effects of plastic.
• The lack of innovation in business strategies and plans related to plastic disposal is the reason why plastic is growing rapidly. The Indian government needs to implement a national policy structure to streamline plastic waste management.

Plastic waste can be categorized into seven different types that consist of PET, PVC, HDPE/LDPE, Polypropylene, Polystyrene, and many others(Thermostat, Polycarbonate).  This waste lies in landfills untreated for years, like the plastic debris that floats on the surface of the ocean and does not decompose quickly. The burning of plastic releases toxic gases that can affect vegetation, human and animal health.

Uniform Framework of EPR

The EPR system is set up on the premise that producers should provide financial support to the collection system, recycling industry, and other processing facilities. The EPR framework gives the manufacturers and producers directions for managing Extended Producer Responsibility legislation. The framework introduced by the government consists of various rules to handle waste under the supervision of central authority.

Extended Producer Responsibility Rules

1. The Producers and manufacturers should develop a process waste collection system based on EPR and should involve the State Urban Development departments.
2. The rules state that the Producers, Brand owners, and Importers are primarily responsible for collecting multi-layered plastic sachets, packaging, or pouches to introduce the market’s products. These stakeholders need to establish a full-fledged system to collect back the waste that their product generates. While the company is applying for consent to develop, operate, or renew, submit the system plan to the SPCB (State Pollution Control Board).
3. EPR rules also include the phasing out of the multi-layered plastic that is non-energy recoverable and non-recyclable and has no alternate use. 
4. No Brand owner, Producer, or Manufacturer can use multilayered plastic for packaging without registration in SPCB or other Pollution Control Committees.

Many possibilities exist in the EPR framework for plastic waste that can control and monitor its flow.

• The Urban Local Bodies of many states have adopted house-to-house collections to sort out plastic waste.
• The waste collector picks out the plastic from the mixed waste, and the remaining waste is transferred to the dumping ground.
• In two-bin collection systems, the recyclable and biodegradable waste is separated after collection from the houses and then sent to recyclers and dumping grounds. The plastic waste is mostly grocery packaging, pet bottles, polythenes, shampoo bottles, etc.
• When the house collection is not available, the waste is picked up from the secondary collection point. Then the waste is transferred to the dumping site, to waste grounds and to energy plants.
• The other way is a plastic waste collection by the individual waste collector (called Kabadiwalas).
• The third one is the waste collection by rag pickers as they collect plastics from different places like dumpsites, streets, and markets and help in waste management.
• The road sweepers collect the plastic while cleaning the roads in the morning.
• The other one is industrial plastic waste, which is transferred to the Recycler/Dismantler after being circulated to various industries. 

The malpractices involved in breaking down non-working laptops, mobiles, and other electronic items lead to improper recycling of e-waste. The residues of EEE products dumped in rivers or drains can deteriorate the land and water quality. EEE producers must design a waste collection mechanism and channel the e-waste from consumers to dismantlers and recyclers.

PROs and Stakeholders

Producer’s Responsibility Organisations help fulfil the complete operational responsibility of different producers and manufacturers to acquire plastic credits. Producers join PROs to divide the legal formalities and other obligations to lessen their waste management burden. It is a professional organisation that helps producers and manufacturers meet their EPR targets by using various processing technologies for waste and end-of-life applications.

PR and PRO’s success depends on upstream management, like building a practical regulatory framework that can highlight other stakeholders’ various roles. The different parts of Producer Responsibility Organisations that assist the producers/brand owners:

• To achieve the waste collection target.
• To establish different collection mechanisms.
• Implementing buy and take back for the recycled waste
• Arrangement of logistics
• To ensure the traceability, channelization, and disposal of end-of-life, plastic and processed waste products.
• Adopting environmentally sound recycling and dismantling the waste
• To conduct various awareness programs for consumers, bulk consumers, and producers to introduce waste collection and channelization. 
• Support producers in filing the quarterly and annual returns as per the government rules
• To help the producers and manufacturers with the legal Extended Producer Responsibility plan.
• To specify the PROs’ capacity to handle waste, including the collection, storage, and arranged recyclers for waste treatment.

Various stakeholders are involved in the EPR schemes to be successful and function effectively.

• National PRO Advisory Committee (PROA): The National Authority manages plastic waste management across India. It ensures the strategic guidance and funding required under the rules and regulations for producers and manufacturers. 

• Manufacturers and PIBOs: Their role is to meet the recycling targets individually or collectively and report all details on an online portal. It is their responsibility to contribute to the EPR funds and submit an annual report to SPCB (State Pollution Control Board) or CPCB (Central Pollution Control Board). Some other responsibilities will include:

• Creating EPR schemers like setting up nonprofit or for-profit PROs 
• Administering and running schemes that will cover registration and product fees, building relationships with waste collectors and processors.
• Paying fee is based on the packaging material found in the market.

• Recyclers: The recyclers must get registered by CPCB or SPCB. Their primary role is to build an efficient plan for recycling and recovering waste. To collect funds from the EPR corpus funds and find an efficient way of recycling plastic.

• Waste Management Agencies (WMA): CBOs, NGOs, and other waste picker associations are responsible for collecting, segregation, recovering, and recycling. They rely on contracts with either the local municipality, PRO, individual producers, and the EPR schemes funds to handle the waste packaging. 

• Local Bodies: They retain accountability for the delivery of waste to Dry Waste Collection Centres or MRF. Then the PRO’s partner waste management agencies become active and perform the task of waste management.

• CPCB: This body works to set up an institutional mechanism for the Extended Producer Responsibility management. It coordinates with the SPCB and gives technical assistance along with necessary guidance. Some other functions of CPCB include:

• Advise the Central government on matters concerning environmental issues and how to prevent them.
• Plan and organise training for the people involved in the program to prevent, control, and abate environmental issues.
• Organize mass awareness programs for the prevention and control of environmental issues.
• Collection and compilation of various technical data and statistics related to environmental degradation
• Disseminate information related to hazardous waste materials and how to control and prevent them.

• Informal Sector: The rag pickers and independent waste collectors fall under this sector. They are a practical solution to getting rid of plastics and other hazardous waste on a local level. The rag pickers can contribute to the effective collection of recyclable and reusable waste from places that producers and other waste management authorities cannot reach.

• Consumers/Citizens and households: It is the responsibility of every citizen to return the waste at the end of their life cycle and use the waste management infrastructure appropriately. Every consumer should be aware of the products (mostly used for packaging materials and carry bags) they are using and avoid the items that can harm the environment. 

EPR Models

For ease of implementation, two different models of EPR came into play under the EPR framework. The first one is called the Fee-based model, and the other one is the PRO-based and plastic credit model.

The Fee-based model:

• This framework includes three components that are the Urban Local Bodies(ULBs), Plastic assemblers and recyclers, and IEC activity. 
• According to this framework, the primary responsibility of collecting, segregating, and disposing of the waste is handled by Urban Local Bodies. 
• The rag pickers, assemblers, and IEC activity should get support for better and more efficient waste management. 
• This model prioritizes the informal sector’s strengthening and formalizing by making them a part of the waste management cycle.
• The Producers, Manufacturers, or Brand Owners who utilize less quantity of plastic in packaging should contribute to the EPR corpus fund.
  

PRO-based and Plastic credit model:

• Producers can cooperate with the Producers Responsibility Organisations to fulfil their complete operational responsibilities. 
• In this model, the producer doesn’t have to recycle their packaging, but they have to ensure that equivalent amounts of waste are recovered or recycled to meet their obligations.
• Producers can exchange the plastic credits for financial transactions, and the collected funds are directed to the material recovery chain. The manufacturers can also exchange plastic credits through a PRO. 

Targets based on EPR Compliance

After receiving the EPR authorization from the state or central boards, the company needs to uphold various compliance forms according to internal and external standards. The companies need to set targets related to waste management to comply with relevant laws, policies, and regulations. The EPR compliance targets initially rely on the models that each producer, manufacturer, and brand owner selects. Once the different components(the rag pickers, assemblers, recyclers, MRF) of the value chain are established, collection and disposal of plastic and achieving the targets become easier.

The organization can verify their EPR compliance if they include:

• Registration of the different organizations (like recyclers, dismantlers, and other agencies) involved and cooperation in e-waste management.
• Providing information on the hazardous chemicals used in the product. If a company is using plastic packaging for materials so they should mention the:

• The type of plastic
• Plastic recyclability
• The amount used in packaging and its harmful effects

• One of the most crucial steps is the inventory of e-waste which includes the raw materials and finished goods held in bulks. The unnecessary accumulation of these materials can cause blockage in the flow of waste management. However, it is also affected by many other activities like the incapability of processes, following the procedures inefficiently, and longer changing times.
• Granting and renewing authorization is an essential target for EPR compliance. It includes the undertakings and declarations that are necessary for handling hazardous and other waste products.
• Use of different methods and mediums for spreading awareness on waste management like television advertisements, publications, hoardings, posters, and various other awareness campaigns
• Imparting various instructions on how to handle and dispose of equipment after using them.

The decision of the Producers on fixing targets for EPR compliance is based on several factors:

• The infrastructure they select for operating plastic waste collection and sorting.
• Action plan to meet the targets by appointing and contracting other agencies.
• The organisations handle the cost per kg of waste, and if the producer signs a PRO, the charge shifts to Producers Responsibility Organisations for waste management.
• Producers must finalise the quantum as per individual targets and pay to a fund for Plastic Waste Management(PWM).

EPR compliance relies more on meeting the targets than the model adopted by the producers and manufacturers. The producer’s compliance with the Extended producer responsibility can fulfil their obligations by owning credits and processing the end-of-life products.

What are EPR Credits?

Plastic Waste Management(PWM) must integrate with Municipal Waste Management systems. With the help of credit, system organisations can take credit from the PWM if they help the MSW management municipalities. MSW is a waste management process covering the collection, transfer, recycling, resource recovery, and treatment. Under the EPR credit mechanism, the collection and recycling of plastic waste will be counted as an offset for the organisation’s EPR target. 

The cost of EPR credit will rely on the market perception of relative demands and supplies. So, when the significant processes lose accreditation, the credit increases, and if there is a disruption in the end-use recycled plastic, the credit will drop. 

What is the responsibility of producers under the EPR credits mechanism?

• The producers under this mechanism cooperate with ULBs to implement the “Segregation Model” of waste management.
• The manufacturers and producers should provide management support and contribute to infrastructure development for proper implementation.
• Engagement with the waste collectors, recyclers, and segregation for the development and implementation of the EPR plan
• A permanent team should work under the producers to monitor the segregation model and keep a proper account of plastic waste management.

How to register for EPR online?

The uniform framework of EPR includes national registration and a database repository by which the online registration of all stakeholders takes place. For efficient functioning, the stakeholders should timely update the information in the database. The Ministry’s and Centre’s web portal is for consultation with the stakeholders and to govern all the transactions under EPR. This web portal helps CPCB (Central Pollution Control Board) monitor the implementation of EPR schemes and mechanisms.   

The compliance of all the registration activities is governed by the uniform framework portal as stipulated in the Plastic Waste Management Rules 2016. Any producer or manufacturer can apply for the authorization by filling out the online application at the CPCB web portal or State Pollution Control Board web portal, respectively. Follow the given procedure to register for EPR online:

1. The manufacturer and producers fill the form according to their products’ nature, expiry, and authorization period.
2. Follow the given guidelines and complete the receipt as the CPCB and SPCB are very particular when checking and scrutinizing the form.
3. The producers should verify all the documents, papers, and contracts before submitting them online. When a third party is involved, it is better to keep evidence and authentic documents.
4. After the documents are approved, follow further directions from the authority to avoid any delay in the registration.
5. Clarify any remarks raised by the board and make the suggested changes in your applications.
6. The board may take up to 25 days to verify and investigate the producer’s and brand owners’ documents and information.

The documents required for EPR registration:

• Every manufacturer and producer should prepare an EPR plan following the guidelines given by SPCB and CPCB. This plan will cover everything from the buyback, reuse, and recycling program adopted by the brand owners and producers.
• It should include declarations that have the compliance described in the format of guidelines. The manufactured products should comply with the RoHS limit (Reduction Of Hazardous substances) set by the control boards. 
• The EPR registration requires technical documents that include supplier declarations, material analytical reports, and certificates(RoHS).
• The file should contain agreements like the copies of contracts with the dismantling and recycling agencies and the Treatment Storage disposal facilities(TSDFs).
• Other necessary documents for Proprietary/LLC/OPC and Partnership Entity include:

• Authorized/Proprietor signatory KYC
• IEC code
• GST certificate
• Rent/Proof/Lease related to the ownership of the side
• Excel sheet details of imported items 

• Other necessary documents for Private Limited and Public limited company 

• Certificate of Incorporation(CIN)
• MOA
• Company’s Pan Card
• Board declaration for Signatory(Authorized)

PRO registration has three to four groups based on their experience, and the startups can also apply on the website. The different groups make it easier for the brand owners and importers to select the right PRO based on their requirements. This is an excellent platform for small-level startups to help small or local businesses in waste management. These are some guiding principles:

• The producers or brand owners on their own or through PRO ensure that an equivalent amount of plastic is processed and collected.
• According to the rules, the producers, brand owners, or PRO will implement and provide funds to support plastic recycling.
• Inclusion of waste collectors and rag pickers in a manner that will improve their incomes and condition
• Producers/Brand Owners/PRO  can obtain certificates from accredited processors by trading the recycling and evidence recovery.
• The producers or brand owners or PRO have the liberty to engage collectively or individually with the urban local bodies, processors, and the informal sectors(rag pickers and waste collectors).

Digitization and the online platform for EPR registration help keep the data on the number of collection centres, and the working waste management agencies, keep a count of Urban Local Bodies engaged, the producers who are registered and complying with the EPR, and the amount of total waste managed.

About Circular EPR 

Circular EPR is the closed-loop that builds a circular economy waste cycle that helps retain the market’s material value. It lowers the use of virgin materials and replaces them with recycled and reusable raw materials. Circular EPR helps prevent adverse effects of hazardous products in the environment by pushing the agencies to adopt sustainability. This process makes all the actors involved in the value chain responsible for end-of-life product management.

Circular EPR is a beneficial model to adopt several waste management techniques for all the stakeholders involved in the process. 

1.The circular EPR helps set renewed goals and build a standard waste management system with higher retention values. The producers/brand owners and manufacturers can monitor and regulate EPR with the help of society oversight and various government policies and gain greater profits. It gives complete access to waste traceability with an insight into the product’s history, providing data for each stage, and knowing about the distribution cycle and location covered. An added advantage of this circular EPR is that its data can be validated and seen by other actors. Still, no one in the blockchain with access to full waste traceability can manipulate or distort any information,

2.A circular economy encourages higher recovery value in the blockchain from waste materials. The most significant advantage of going circular is the increasing focus on material recovery. With this mechanism, the producers, brand owners, and manufacturers can prioritise reusing, treading, and repurposing waste products. Many producers have adopted eco designs that are way easier to remanufacture, reuse, and recycle, plus it gives a very high value of recovery.  The fee can differ depending on the product’s sustainability, which depends on its durability, recyclability, and the total percentage of material recycled.

3.Nowadays, industries and various organisations are working to minimise waste by bringing a change in the processes like redesigning and enabling industrial symbiosis. The Circular EPR helps boost productivity, shifts economics, and brings a shift in industrial growth with sustainable methods. Circular EPR is adding to the various sustainable goals of manufacturers and different organisations by:

• Introducing a business strategy that shifts focus from creating shareholder value to gaining shared value, for example, ESG incorporation and the financial returns in the organisation’s corporate strategy
• Organisations also improve the critical impact areas by identifying the sustainability issues that affect their business and handling them with proper strategy.
• Corporations with the help of a circular economy can connect their sustainability goals and measure risk management, revenue generation, and productivity.
  

4.Lack of connections, communication, and effective collaborations between different actors like manufacturers, producers, and recyclers can affect sustainability. However, further integration of recyclers and dismantlers can help reinforce cooperation in the circular EPR blockchain. A sustainable circular economy covers many aspects of intellectual property, ownership, production techniques, manufacturers’ methods, and decision-making involvement. The EPR system will cover the broader social and environmental concerns with circular EPR and help improve transparency and liability.

How to implement EPR?

• Research: Indulge in research studies related to circular EPR schemes and their provisions, including several case studies. It is crucial to study the benefits of circular EPR  scheme opportunities and go through examples.
• Government Policies: Give time to study government policies, guidelines, and legislation related to the EPR of the country. Try to consult with the key stakeholders, for example, different businesses, waste management companies, local governments, and the informal sector(rag pickers and waste collectors).
• Recycling point: It is crucial to form a network that involves the aggregation of recycling and manufacturing partners to shift the bulk waste from the collection point to the point where it will be recycled or reused.
• Methods and Techniques: The selected recycling point should know about adequate methods and techniques that can convert unwanted waste into reusable materials. Test and verify the recycled raw material by the cooperating recyclers or aggregators of your agency. 
• Infrastructure: The Producers/Brand Owners/Manufacturers must start supporting the required infrastructure and management for the waste collection process. 
• Network: Connect and try to establish a network with like-minded businesses, organizations, and corporations and do not let the communication gaps come in between. 
• Local-level: If any company wants to understand the EPR policy of a new place, contact the local government and other informal sector waste, collectors. 
• PRO: Build trust and cooperation between the different actors from PRO, the waste management cooperators, and other stakeholders involved in the process. 
• Blockchain System: By enabling a blockchain system, it is easy to track your products from the first haulers to manufacturers to all the processors. Circular EPR enables waste traceability and maintains transparency in the blockchain. It is an opportunity to unveil the unaccountability and frustration surrounding the waste management system.

Waste Traceability

It is vital to develop a mechanism through which the waste value chain works and can ensure its traceability. The entire EPR Framework relies upon the mechanism by which the waste traceability can be made transparent so that the investor can invest in it without any second thoughts. Transparency in the blockchain is crucial because of the generation of fake bills and certificates to receive plastic credits. 

The main aim of developing waste traceability is to allow organisations to track what goes on in their products, where it comes from, and what happens to them after the consumers buy them. PLM(Product Lifecycle Management) gives a point of view based on the manufacturing and creation of a product. On the other hand, supply chain management offers the opportunity to track the products from cradle to grave. The ideology of circular EPR focuses on higher material value recovery by forming a closed loop chain and allowing waste traceability.

The traceability mechanism supports insights by connecting data, so when the producers follow a value chain, they can track the information from primary production to its use and then to its disposal. How is this mechanism helpful for the producers?

• The producers can collate the sustainability credentials once they have visibility and access to all the actors involved in the process. It also allows the primary stakeholders to assess and report on the appointed supplier’s approach and contribute to the human and environmental sustainability factors. The transparency in the material flow allows government entities and many organizations to track data for cross-industry cycle analyses and monitor the environmental impact of products and value chains more accurately. 
• Transparency brings more efficiency to the value chain as it enables the building of a decentralized platform for all the stakeholders and actors part of the blockchain. The authorities can use advanced contracts to track and make transactions without any central organisation’s need or help. The cross-industry blockchain applications have the potential to increase efficiencies and reduce the overall cost. With an added layer of transparency on the blockchain, the producers/brand owners/ manufacturers can get data insights on the material flow. It will help prevent any fraud as all the actors involved in the value chain will be aware of the practices and activities involved and have all data.
• Traceability will increase the consumers’ engagement as they know about the product’s provenance and other useful information. It will make the brand or product more reliable as the consumers want to see if they are manufactured with high levels of environmental and social responsibility. The consumers can deeply connect and understand the brand’s values, and it helps maintain customer loyalty.

How to maintain Waste traceability?

• The producer’s responsibility organisations are responsible for the material flow from the waste collectors, recyclers, sorter-balers, and end-of-life processors.   
• The output’s verification takes place with advanced encrypted blockchain technology or QR codes that ensure traceability.
• Only the PROs’ safe disposal certificate is visible to the registered users on the digital platform, and all other information is confidential.
• The safe disposal certificate generated by the PRO is the only evidence that the producers offset their responsibility.
• The Regulator helps monitor if producers fulfil their responsibility of EPR or not and can take action against the ones who do not comply with their obligations. 
• Waste Traceability prevents any kind of duplication and fraud, and one receives efficient and actual work on the ground level.   

Saas platform for EPR

We at Cercle X work to quicken the transition of various global brands to circular packaging. With advanced technology, we maintain traceability and transparency for the supply of recycled materials. We are not just a tech-dependent circular waste management platform. Our team works on the grassroots level with many marginalised women who work hard to make every recycled material in our portfolio. Our team at Cercle X is working to empower and support thousands of waste warriors by providing them with wages and healthy working conditions.

Why work with us?

• Are you wondering how to reach your “Zero Waste to Landfill” goal? We at Cercle X can help you gain that target in 365 days. Our team will work on energy recovery, and the waste will either be eliminated at the source or recycled for further usage. We understand the importance of product design, novel materials, business models, industrial processes, and public infrastructure to dispose of or produce recycled material. We follow this hierarchy of material management:

• Extended Producer Responsibility and Product Redesign
• Reduce the waste’s toxicity, consumption, and packaging
• Repairing, reusing and donating 
• Recycling
• Compost 
• Down cycle 
• Waste-based energy for disposal
• Landfill waste as disposal

• We provide end-to-end reports about the waste streams, carbon emission reduction, and many other details related to the product. Our team of the young generation believes in maintaining complete transparency throughout the process. We give our clients full information on :

• Activity data: This includes waste produced(tonne/cubic meters) and the type of trash, and for each waste type a specific treatment is applied.
• Emission factors: It includes the waste type and waste treatment-specific elements, and it also provides emissions from the transportation of waste.
• Data collection: The calculated emission factors according to the guidelines, life cycle databases, and industry associations

• We handle things very quickly and manage waste online with easy access and more efficiency.  One can analyze the waste, work on fulfilling their EPR targets, and run various activation campaigns online. Waste analysis can prevent organisations, producers and manufacturers from a lot of unwanted expenses and troubles. Our team works to avoid:

• Unnecessary transportation costs 
• Excessive inventory
• Prevent overproduction and waste of resources
• Over-processing

• We at Cercle X provide high-quality source raw materials through our ethical and fair trade guarantee supply chain. We have also transformed a lot of materials into useful things, and here are some examples:

• We recycled shredded currency and changed it into notebooks and calendars.
• We used ocean plastic to make playground equipment.
• With PET bottles, we made exquisite T-shirts and blankets.
• We changed the MLP waste into park benches and bio-toilets.

Do you want the perfect Extended Producer Responsibility solution for your brand? We will help you redefine waste with innovative ideas for cost savings. We strive to help our partners no matter where they stand in the circulatory journey. We consist of a network of thought leaders, proprietary tools, and design experts to help you reach your circular economy goals.

We empower and help thousands of backward women, ragpickers, and waste collectors with fair trade in waste management. Join our community of warriors and help us bring a climate action revolution. People are our priority, and if you work with us, you empower a community as a whole. EPR is the way forward when it comes to safeguarding mother earth.