Plastic Waste Management (PWM) — Annual Return for FY 2024–25 extended to 30 November 2025

The Ministry of Environment, Forest and Climate Change (MoEFCC) has extended the due date for filing Annual Returns under the Plastic Waste Management Rules for FY 2024–25 to 30 November 2025. The extension applies to entities operating under the Extended Producer Responsibility (EPR) framework—namely PIBOs (Producers, Importers, Brand Owners) and Plastic Waste Processors (PWPs) registered on the EPR portal.

Failure to file within the stipulated timeline may attract Environmental Compensation (EC) under CPCB/MoEFCC guidelines, in addition to potential restrictions on future transactions on the portal.

1) Scope and legal context

• Regulatory framework: Plastic Waste Management Rules, as amended (EPR framework); associated guidelines issued by CPCB/MoEFCC.
• Obligated entities:
  • PIBOs registered on the EPR portal, including imported and domestically manufactured plastic packaging.
  • PWPs (recyclers, co-processors, waste-to-energy, waste-to-oil, end-of-life handlers) engaged by PIBOs to meet EPR targets.
• Reference year: FY 2024–25 (1 April 2024 to 31 March 2025), with consolidated Annual Return due 30 November 2025.

2) What the Annual Return must cover (data structure & granularity)

A compliant Annual Return typically consolidates and reconciles the following (aligned to the portal’s sections/fields):

A. PIBOs

1. Entity & licence details: EPR registration number, GSTIN, registered addresses, authorised signatory.
2. Packaging scope mapping (aligned to PWM categories):
   • Category I – Rigid plastic packaging
   • Category II – Flexible plastic (single/multi-layer), plastic sheets, carry bags
   • Category III – Multi-layered plastic (plastic + at least one non-plastic layer)
   • Category IV – Compostable plastic packaging/sheets
3. Material balance for FY 2024–25 (by category & polymer family where required):
   • Introduced to market (ITM): domestic production + imports – exports/returns
   • EPR target (calculated from ITM and applicable target % by category/year)
4. Fulfilment details (transaction-level or aggregated with traceability):
   • Recycling: quantities processed; recycler/PWP registration IDs; certificates/evidence
   • End-of-Life (EoL): quantities sent for co-processing/cement kilns, waste-to-energy, waste-to-oil; processor IDs; evidence
   • Reuse/Refill (if applicable): counted as per guidelines
   • PCR Content (post-consumer recycled content) achieved in packaging (where mandated), with supporting documentation
5. Geographical distribution (if required): state/UT-wise returns to support SPCB/PCC oversight.
6. Documentary evidence: invoices, PWP acknowledgements, unique transaction/reference IDs generated on portal, reconciliation statements.

B. PWPs

1. Entity details: registration number, authorisations, capacity, process type (recycling, co-processing, WtE, etc.).
2. Processing ledger: input waste type, source (linked PIBO transactions), output material/end use.
3. Certificates issued: transaction IDs, quantities verified, date of processing, destination/use of output (e.g., granules, clinker feed).
4. Mass-balance compliance: input–output yield, rejects handling, disposal route documentation.

3) Data integrity, reconciliation & audit trail (recommended controls)

• Control totals: Reconcile ITM vs. sales vs. stock adjustments; ensure EPR target derivation matches portal logic.
• Transaction pairing: Ensure every PWP certificate maps to a corresponding PIBO liability (category/year) with unique portal transaction IDs.
• Deduplication: Avoid double counting across recyclers or between recycling and EoL streams.
• Temporal checks: Only claim processing completed within FY 2024–25 (unless guidelines allow carry-forward/back provisions).
• Evidence pack: Maintain a digital pack (invoice PDFs, weighbridge/manifest, geo-tagged evidence where applicable, SPCB/PCC NOCs/consents) for each claimed tonne.
• Third-party assurance (optional but recommended): Pre-filing compliance review to reduce risk of EC and queries.

4) Environmental Compensation (EC): risk & computation pointers

• Trigger: Non-fulfilment of EPR targets, delayed/incorrect filing, or unverifiable claims can lead to EC.
• Computation: As per CPCB EC guidelines (category-wise, shortfall-based, and year-dependent). Rates, interest and escalation may apply.
• Adjustment/closure: EC may be partially adjustable against future over-compliance per applicable rules/guidelines. Keep documentary proof ready for any representation.

5) Practical filing workflow (PIBOs & PWPs)

1. Pre-recon: Freeze FY24–25 ledgers; lock control totals by category (I–IV).
2. Portal readiness: Verify active registration, authorised signatory, and access rights; test CSV/XML templates if the portal supports bulk uploads.
3. Document collation: Invoices, agreements, PWPs’ certificates, state-wise splits, capacity letters (for PWPs), consent/authorisation validity.
4. Draft return: Populate all mandatory fields; attach evidence where the portal allows; ensure correct mapping to categories.
5. Internal QA: Cross-verify numbers against finance and logistics; sample-check PWP certificates.
6. Final submission: File well before 30 November 2025; download acknowledgement and freeze copy for records.
7. Post-filing: Track any portal queries, SPCB/PCC clarifications, and close them promptly.

6) Common pitfalls to avoid

• Category misclassification (e.g., mis-tagging multilayer as flexible single-layer).
• Claiming outside the year (processing dates beyond FY24–25).
• Unlinked certificates (missing transaction IDs or PWP not registered/active).
• Mismatch between ITM and target base (incorrect deductions for exports/returns).
• PCR claims without substantiation (supplier declarations not backed by lab/chain-of-custody evidence).
• State-level inconsistencies (totals not matching across state filings where required).

7) Timeline & next steps

• Due date: 30 November 2025 for FY 2024–25 Annual Return (PIBOs & PWPs).
• Action now: Close books for FY24–25, complete reconciliations, secure PWP certificates, and file early to avoid last-minute portal congestion or EC exposure.

How C-PRAV can help

• Gap assessment & category mapping (I–IV)
• Target computation & reconciliation (ITM → EPR liabilities → fulfilment)
• Evidence pack assembly (invoice trails, transaction pairing, mass-balance checks)
• Portal filing & query management (including SPCB/PCC follow-ups)
• Readiness for audits/inspections (standard operating dossiers, data room)

For clarification or filing support, contact India@c-prav.com.