The Central Pollution Control Board (CPCB) has issued an important notice to solve the shortage of EPR certificates in plastic packaging categori    es. This issue affected Category II and Category III under the recycling segment. Many Producers, Importers, and Brand Owners faced problems while meeting EPR targets for FY 2024–25.

Under the Plastic Waste Management Rules, 2016, every registered PIBO must ensure recycling of collected plastic waste. From FY 2024–25 onward, recycling targets became mandatory. Due to limited availability of recycling certificates, compliance became difficult. CPCB examined the issue after receiving several representations and decided to introduce temporary relief measures.

Legal Background Under PWM Rules, 2016

Rule 7(b) of the Plastic Waste Management Rules, 2016 requires PIBOs to meet minimum recycling levels for plastic packaging waste. This rule applies every year and excludes end-of-life disposal.

Further support comes from Rule 15A, added through the amendment dated 30 October 2023. This rule allows the use of EPR certificates from other categories where surplus exists. CPCB holds the power to decide the quantity and type of certificates that can be used to cover shortages. This rule aims to balance recycling capacity and compliance costs across plastic categories.

New Flexibility for Cat II and Cat III Compliance

To resolve the shortage, CPCB introduced an additional compliance option. EPR obligations under Cat II and Cat III recycling categories can now be fulfilled using End of Life (EOL) EPR certificates of the same categories.

The conversion ratio has been clearly defined. One tonne of recycling obligation under Cat II or Cat III can be fulfilled using 1.5 tonnes of EOL EPR certificates from Cat II or Cat III. This step ensures continuity of compliance while maintaining environmental accountability.

This flexibility applies only for FY 2024–25 and remains valid until the Annual Return filing deadline.

How PIBOs Can Use the EPR Portal

PIBOs can transfer Cat II or Cat III EOL certificates directly to the Annual Return section on the EPR portal. This transfer helps meet recycling obligations as per the new relaxation.

Entities that already filed Annual Returns with a shortfall can also benefit. The EPR portal provides an offset option under the credit exchange section. Through this option, eligible EOL certificates can be adjusted against recycling deficits. CPCB will consider such adjustments as valid compliance for the respective category.

All registered PIBOs must follow this updated process for smooth implementation of EPR Guidelines for Plastic Packaging. The notice remains effective only for FY 2024–25 and has received approval from the competent authority.