Understanding the role of each stakeholder in the EPR chain.

A glimpseof each stakeholder and their responsibilities with respect to EPR mandate

Extended Producer Responsibility (EPR) derives from the broader “Polluter pays” principle which holds the producer of the polluting products responsible to bear the cost of management of it. In EPR for plastic waste management also, the government mandates the Producers and Brand Owners of the plastic that is introduced into the environment, to take back and scientifically dispose or recycle the plastic waste.

Who are the stakeholders in EPR?

Central Pollution Control Board: Nodal agency for setting up guidelines and standards related to waste management, and coordination among key stakeholders.

State Pollution Control Board: State-level bodies for implementation of PWM Rules 2016 and monitoring the activities related to that.

Producer: entity engaged in the manufacture of plastic items like sheets, films or MLP packaging items

Brand Owner: An entity that sells products in the market under its own label, for example, Nestle which sells Maggie or Marico selling Suffola oats.
EPR Agency: A waste management agency that carries out the EPR i.e. collection, transportation and scientific disposal of waste plastic on behalf of its consumers. It also helps the PIBOs in fulfilling their compliance like preparation of EPR Action Plan, quarterly reports.

Recycler: the entity which transforms segregated plastic waste into a new product or raw material for producing new products.

CoProcessor: An industrial facility like the Cement factory, which uses plastic waste as Alternative Fuel/Raw material for generating energy instead of coal.
Waste Collectors:In the formal sector, Urban Local Bodies have set up collection processes to collect waste. In an informal sector, rag-pickers are engaged in the activity of the collection of waste plastic.
Scrap Dealer: entities engaged trade of plastic waste. They source their material from waste pickers, households, societies, local kabadiwalas, and industries. They also segregate the waste and then sell it to another scrap dealer or recycler.


What are the responsibilities of each stakeholder?

  • CPCB: The Central Pollution Control Board is responsible for the following activities-:

Setting up the guidelines: It provides technical guidelines for different stakeholders (Segregation, collection, disposal, co-processing) and different types of plastic waste (Non-recyclable fraction, thermoset plastic waste). It also provides guidelines about how to comply with these guidelines by providing an action plan.

Holding stakeholder consultations: This is an important activity that CPCB carries out regularly. The participants represent the entire spectrum of plastic waste management including the ULBs, PCBs, representatives from industry associations like FICCI/CII, brand owners, NGOs, Recyclers. Most of these consultations result in addressing the issues faced by the stakeholders. The guidelines published for the Compliance related documentation is one such result of such consultations.

Coordination with State PCBs: It coordinates with the state pollution control boards to ensure regular monitoring of the stakeholders performing EPR.   

Data compilation: The CPCB receives quarterly reports from all the PIBOs performing EPR. It also performs queries and researches to verify & compile this data to prepare national-level reports.

  • SPCB: The State pollution control board is responsible for the following activities-:

Implementation of CPCB guidelines: The SPCB makes sure the guidelines provided are followed by the stakeholders performing EPR. This body conducts frequent inspections to ensure this implementation is done properly.

Action Plan: The SPCB undertakes the task of scrutinizing the action plans submitted by the PIBOs to ensure its adherence to the guidelines provided by the CPCB.

Industry authorizations: The processors, brand owners, recyclers and co-processors need permission from the government to operate. This consent to operate is issued by the SPCB and needs to be revised at expiry.

Monthly communication: The SPCB communicates all the information involving notifications, guidelines & amendments from the CPCB to the PIBOs.

  • EPR Agency: Their basic responsibility is to carry out the EPR activity on behalf of their clients i.e the PIBOs and it involves the following things.

Collection of Plastic Waste: Identifying sources of plastic waste like ULBs, Bulk generators etc. Checking the quality of the material i.e whether it contains segregated plastic waste only instead of mixed municipal solid waste. Signing official agreements with the Source for collection of plastic waste.

Scientific disposal: Identifying recyclers/processors who have valid Consent to Operate from the respective State Pollution Control Boards. The agency needs to sign agreements with these processors for scientific disposal of plastic on behalf of its clients.

Documentation: The agency needs to maintain documentation on behalf of the PIBOs for the fulfilment of EPR which includes Purchase bills, weight receipts, Lorry receipts, photos of the material, photos of the vehicle, E-way bills, material received acknowledgement from the processors, and the disposal certificates.

Compliance reports: The agency is also supposed to submit all the necessary documentation/proofs that are required by the PIBO for the preparation of Action Plan, quarterly report. These proofs can be the agreements that the agency has with the sources of waste, processors etc.

  • Producer and Brand Owners: Their role is important for financing the EPR activity. Their responsibilities include

Registration: First step in EPR is registering with the respective pollution control boards with accurate information about their plastic consumption.

Collection system: The company needs to set up a mechanism for take-back/collection of plastic waste and its scientific disposal. It can do this in 3 ways mentioned in this link. (include a link to the banner article)

Elimination of zero-value plastic: Innovation in packaging, especially by the Producers, which helps phasing out of non-recyclable plastic.

Communication with government bodies: Regular communication with the CPCB/SPCBs in the form of monthly EPR Activity, Quarterly reports, participating in the stakeholder consultations at CPCB

  • ULB & other Collection centres: ULBs generally work alongside the informal waste picker networks or organisations unifying these waste pickers. Both these can work either individually or together to meet the target of efficient collection.

Establishment of Infrastructure: It’s the primary responsibility of the ULBs to set up the infrastructure for segregation, collection, storage and disposal of plastic waste. Such an infrastructure can also be provided by individual organisations who unify the informal waste pickers.

Scientific disposal: Creating facilities for the promotion of recycling/processing units locally creates avenues for decentralized and low-cost recycling of waste. This can be a government facility or a private but government authorised one.

  • Recycler & Co-Processor: These are the endpoints in the chain of plastic waste where the plastic gets recycled or processed and attains the end of life. Their responsibilities are as follows

Authorisation: Having a valid consent to operate from the state pollution control boards and following all the standards of processing/recycling, and the pollution control norms.

Registration: Registering themselves with the PCBs and Local bodies as recyclers which can be done by issuing Udyog Aadhar Memorandum.

Regular communication with the government: Recyclers have to communicate with PCBs about their involvement in EPR activity, the details about the plastic processed, the details of the clients on whose behalf the plastic is processed.

  • Consumer: The journey of plastic gets divided into two halves when the plastic reaches the consumer. It is this point where the plastic takes the form of waste when the consumer throws it away in the dustbin.

So the responsibility of the consumer is to follow a sustainable lifestyle centred around the 3 Rs-Reduce, reuse and recycle.

Reduce: The amount of plastic entering the environment can be controlled by the consumer. Also, the type of plastic being consumed can be controlled by the consumer in the supply chain. Consumer should responsibly use the products that are packed in recyclable plastic only.

Reuse: Consumer must prefer to reuse the plastic as it is an inert, long-lasting material and can be used multiple times.

Recycle: Consumer must ensure that the plastic waste is segregated, not soiled and disposed properly to ensure recycling with maximum value.