Key Takeaways from Plastic Waste Management (Amendment) Rules, 2024

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The Ministry of Environment, Forest and Climate Change has notified an amendment to the Plastic Waste Management Rules, 2016, titled the Plastic Waste Management (Amendment) Rules, 2024, on March 14, 2024. Here are the key takeaways for Producers, Importers, and Brand Owners (PIBOs).

1. Definition of Producer Expanded
Producer now includes entities engaged in manufacturing plastic packaging, intermediate materials, or contract manufacturing using plastic packaging for brand owners or similar arrangements.
2. Registration and Reporting Obligations for Manufacturers and Importers
Manufacturers and importers of plastic raw material are required to apply for registration with the State Pollution Control Board using Form III.

Additionally, they must submit quarterly and annual reports, as specified, by the respective deadlines (last day of month following the quarter and an annual report by 30th June of every year).
3. Introduction of Sellers
Sellers are defined as entities who sell plastic raw material such as resins or pellets or intermediate material used for producing plastic packaging. They are mandated to submit an annual report detailing transactions to the relevant pollution control authorities by June 30th each year.
4. New Biodegradable Plastics Category (V)
A new category for biodegradable plastics (Category V) has been introduced, with specific labelling requirements and separate markings to be designated by the BIS.
5. Thickness Requirement Exemption for compostable/biodegradable Carry Bags
“Carry bags made of virgin or recycled plastic shall not be less than fifty microns in thickness,” while compostable/biodegradable carry bags are exempted from this requirement.
6. Pre-consumer Waste Processing Obligations
Manufacturers are obligated to process pre-consumer plastic waste generated in the form of reject or discard material at the stage of manufacturing and report these activities to the SPCB/CPCB.
7. Minimum Recycling Target Introduction
Manufacturers/importers must meet minimum recycling levels for plastic packaging waste as specified in the Extended Producer Responsibility (EPR) targets, categorized and outlined in the provided table.

EPR Plastic Waste minimum recycling target
8. Micro and Small Enterprise Exemption from EPR Obligations
Micro and small enterprises, as per the MSME Development Act, 2006, are exempted from direct EPR obligations. Instead, these obligations are shifted to the manufacturer or importer of plastic raw materials supplying to such entities. However, it is mandated that these entities fulfill the target for the use of recycled plastic content (as per table below).

(% of manufactured plastic for the year)
Mandatory use of recycled plastic content target - EPR Enviraj
9. Price Cap Implementation
The CPCB is tasked with establishing high and low price caps for EPR certificates, ensuring a standardized pricing mechanism.
10. Annual Filing Deadline Extension
The deadline for filing annual returns for the financial year 2022-2023 has been extended until March 31st, 2024.

Use Plastic EPR Liability Calculator to estimate your EPR plastic waste liability as per the CPCB guidelines.

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