CPCB issues notification on Directions for the provision of GST invoices of transactions related to plastic packaging by Producers/ Importers/ Brand owners (PIBOS) and Plastic Waste Processors (PWPs)

The Central Pollution Control Board (CPCB) has issued a notification on Directions under Section 5 of the EPA, 1986. The notification was issued on December 21, 2022. The notification deals with the provision of GST invoices of transactions related to plastic packaging by Producers/ Importers/ Brand owners (PIBOS) and Plastic Waste Processors (PWPs).

The Ministry of Environment, Forest, and Climate Change had previously issued the Guidelines on Extended Producer Responsibility (EPR Guidelines) for Plastic Packaging in Schedule II of the 4th amendment of Plastic Waste Management Rules, 2016. These Guidelines were issued on 16th February, 2022.

Howerver, it is observed that verified details of all plastic waste/ packaging transactions between PIBOS & PWPs are required for:

  1. foolproof method of calculation of EPR Target of PIBOS,
  2. cross-checking of transactions between PIBOs
  3. as well as generation of EPR Certificates by PWPS and PIBOS (Use of Recycled

Section 9 of the EPR Guidelines states that Environment Compensation (EC) shall be levied by CPCB/SPCB/PCC on PIBOS for the non-fulfillment of their EPR targets, responsibilities, and obligations in these guidelines.

According to EC Guidelines framed by CPCA, EC, at the rate of Rs.5000/- per ton is to be levied for the shortfall in the EPR target on defaulting PIBOS.

It is observed that non-fulfillment of EPR Targets by PIBOS not only has huge financial implications but also has a severe adverse environmental impact

GST invoice provides verified details of all transactions sales/purchases including that related to plastic waste /packaging transactions by PIBOs/PWPS.  Furthermore, the EPR Guidelines mandate PIBOS to provide details of sales & procurement of plastic packaging. Additionally, GST details are to be incorporated in the Certificates generated by PWPS. 

The EPR Portal allows for the generation of EPR Certificates. This is based on the actual sales figures of PWPS /PIBOs. The portal also has a provision for the transfer of certificates between PWPS/PIBOS.

The notification further directs all PIBOS and PWPs to upload GST E- invoice details of all transactions (sales /purchase) related to plastic packaging and plastic waste on the centralized EPR Portal for ensuring compliance.

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