April 16, 2023, Sunday

12 noon – 1 pm

• In 2016, the Government of India had notified different rules in waste management: solid waste management, plastic waste management, hazardous waste management, construction and demolition waste management.
• Various amendments have been made in the plastic waste management rules.
• In the 2022 amendment, the concept of EPR was introduced. Basically, EPR means extended producer responsibility i.e., responsibility of the producer for environmentally sound management of the product until the end of life. 
• The EPR guidelines were notified by the MOEF&CC on February 16, 2023 vide fourth Amendment to PWM Rules, 2016.
• The Central Pollution Control Board (CPCB) has developed a dedicated portal for this: eprplastic.cpcb.gov.in. All producers, importers and brand owners (PIBOs), plastic waste processors (PWPs), those engaged in recycling, waste to energy, waste to oil, industrial composting have to mandatorily register on this portal. SOPs have been uploaded.
• PIBOs, which are operational in 1 or 2 states have to register in SPCB. Others which are operational in more than 2 states have to register in the CPCB portal.
• EPR is a wonderful concept, which ensures that the organization which are using plastic to package their products, they are made responsible for ensuring its collections, channelising for recycling as waste to energy and coprocessing, which are different avenues for different categories of waste.
• Every plastic cannot be recycled. There are different types of plastic that are being used and therefore there are different end of pipe collections or waste to energy solutions.
• There needs to be a public-private partnership for waste management as we are a resource-constrained country.
• All PIBOs have to see how they can reduce their material. The more the plastic used in the packaging of their products, more is the responsibility under EPR.
• EPR is a penalizing policy tool that forces the organization to reduce their plastic consumption. It is defined as “an environmental policy approach in which a producer’s responsibility, physical and/or financial, for a product is extended to the post-consumer stage of a product’s lifecycle.
• It marks the shifting of responsibility upstream towards the producer and away from the municipalities and provides incentives to producers to include environmental considerations such as reducing material consumption, using more secondary material and promoting product eco-design in their product design.
• Plastic waste management rules do not apply on biodegradable and compostable plastic. Hence, it is an incentive for organisations to move towards these kinds of packaging.
• There are various tools under the EPR strategy. These include administrative tools (such as collection and/or take back, recycling targets, emission limit), economic tools (such as material or product taxes, subsidies), informative tools (such as environmental reports) and agreements (such as social contracts). Tools are the structures that have been given to ensure the collection. While these tools are academically good, in our country, we have a very different value proposition when it comes to waste.
• There has been a steep jump in plastic consumption in 2020-21, which is primarily because of the after effects of pandemic. People have moved towards packaged foods, wherever they had a choice. And it is expected to increase.
• There was an intent by the government to have a very clear and transparent mechanism so that each ton of plastic could be traced. Hence, the need for bringing in e-governance in EPR implementation. 
• India’s plastic waste generation is the 5th highest in the world. India generates around 4 million tonnes of plastic waste every year; 43% of this is packaging waste. So, we need to focus on packaging waste, which is found littered on roads, choking drains, rivers, etc.
• Successful implementation of EPR would address a big share of the plastic waste problem in the country.
• The focus of government currently is on plastic packaging waste. 
• Some reports say that in India we already have 85% of PET bottle collection in the country. There is a very efficient informal system, which is working. 
• The ones with no or little value (Single use plastics and low-value non-recyclable plastics) are littered and then collected through municipal collection systems ending in dumpsites or incinerated for energy recovery.
• Multilayered packaging (MLPs) is currently going mostly in cement kilns for coprocessing. But in the coming years, it is expected that MLPs will also be recycled.
• There is also an initiative related to cradle-to-cradle recycling of plastic. 
• To ensure circular economy, the government is mandating obligated use of recycled content in their packaging for PIBOs. But every sector cannot specifically comply with this such as the food sector.
• Every PIBO has to comply with targets like EPR target, minimum level for recycling, end of life disposal and obligation for use of recycled content.
• They must also adhere to a minimum level for reuse.
• Different categories of plastic packaging have been defined under the rules. Category 1 is mostly the rigid plastic e.g., plastic jars. Category 2 is mostly flexible, transparent plastic, which is used for packaging. Category 3 includes MLP and Category 4 is compostable plastic. Different targets have been given for Category 1, 2 and 3 and 4 plastics.
• Targets for reuse for Category 1 (rigid plastic packaging) are applicable from 2025-26. Time has been given to the industry to gear up for this kind of system, where reuse is implemented and captured by the regulator. But the overall mechanics are not yet clear.
• The PIBOs have to declare the amount of packaging they are bringing into their system and how much they are giving to the next supply chain partners after processing.
• If brand owners are reusing some quantity of packaging, that quantity would be deducted from their EPR targets.
• There have been key policy changes over the last 5 years. The government is shifting gears for enhancing the circular economy in the country. The focus has moved from administrative regulatory compliance to facilitating growth of recycling infrastructure in the country. There is more emphasis on recycling than waste to energy or co-processing and efficient compliance monitoring as e-governance model with analytics assist regulator. There are fewer hassles on report filing and renewal application by PIBOs. A more transparent credit mechanism to ensure proper collection and recycling of plastics.
• There are many challenges that have been brought to the notice of the environment ministry and CPCB. 
• The plastic credit movement is yet to be fully functional and though work has been done, payments have been made, the credit is not showing on the portal. PWPFs are not verified by the concerned SPCB. The renewals of PIBOs is pending for a long time.
• The upload of procurement data invoice-wise is a herculean task due to the business processes. 
• Data privacy is a serious issue. All details are available on a dashboard on the CPCB portal, which is vulnerable to theft and misuse.
• On EPR portal, there is a tab of training, which has two sections. One is basic training and other is advanced training. Basic training, we find various modules. Advanced training explains many portal-related things are explained such as common mistakes.
• In food sector, big brands like Pepsi, Cola make up only 40% of the FMCG (fast moving consumer goods). There is a need to bring in the remaining 60% of the FMCG into the system. E-governance may help to do this.
• EPR can be implemented nicely if the municipal collection of waste is segregated.

Participants

Dr Anil Kumar

Mr Kamal Sharma

Dr SK Gupta

Mr Pradeep Khandelwal

Ms Ruchika Sethi Takkar

Dr S Sharma