Extended producer responsibility is a practice and a policy approach in which manufacturers / producers / brand owners of plastic take responsibility for the management of the disposal of products they produce once those products are no longer useful or durable by consumers. Responsibility for disposal may be fiscal, physical, or a combination of both.
Increased consumption patterns by consumers including Fast Fashion, Food packaging, Agri Pharma has created a need for packaging that is versatile and airtight.
For Micro, Small and Medium Enterprises (MSME), using non-recyclable plastics in packaging at this point of time has fallen through the cracks for EPR.
The nature of most packaging is now composite (multilayer plastics or laminates) which has become a major challenge in the solid waste management system. According to the Plastic Management & Rules 2016 and its amendments in 2019, the burning of plastic packaging in cement plants is considered recycling and is referred to as “co-processing.”
Raw materials for co-processing need to be dry or low moisture post-consumer packaging which is available only when waste is segregated at source. However, many times this material ends up in dump sites, drains and ultimately water bodies because moving this material from the cities to far off cement plants is very expensive and collection is very difficult due its lightweight materials.
To discourage usage of such materials and to establish the producers responsibility of post-consumer package waste, the central government first introduced the EPR guidelines in 2011 and asked companies to set up collection centres. However, there was no tool to regulate this process to get the companies to comply with these guidelines.
There is a mention of EPR in the Solid Waste Management Rules 2016 and stronger regulatory obligations laid down in Plastic Management Rules 2016. According to section 9 of Plastic Waste Management and Handling Rules 2016, producers had to develop a proper plan for management of wastes within six months of publication of rules.
Increased consumption patterns by consumers including Fast Fashion, Food packaging, Agri Pharma has created a need for packaging that is versatile and airtight.
Challenges
While legislative frameworks mandate that all plastic manufacturers and brand owners work on waste collection systems, the clarity on how the collection should be made is not clear. Plastic Waste Management Rules, 2016 (PWM Rules), states that all the companies that use plastic packaging must register as a “producer” or “brand owner”. If they are in operation in more than two state, they need to register under Central Pollution Control Board (CPCB)
With all this confusion, EPR’s effectiveness is yet to be experienced on the ground. CPCB has recently published guidelines for Uniform framework for EPR under plastic Waste management Rules, 2016 and objections are called and the deadline for objection is July 2020.
While CPCB is setting up the process for traceability of the movement of the plastic Ministry of Housing and Urban affairs is setting up details of the technical aspect of co-processing.
For the informal sector there are major challenges:
- The informal sector does not understand the need for traceability, so when new players come into the system, they disenfranchise the informal sector, and challenge the livelihood for traditional players in this sector.
- Since multi-layered plastic is light weight, the cost of recovery is higher than the monetary value generated by such items. This means that the collection can only happen in the door to door collection situation. This omits the informal workers. This challenges the infrastructure of the local government to cope.
- The reason informality exists in this sector is purely cost. The collection, aggregation of plastic which is the primary activity for the recycling industry is poorly paid. Formalizing these activities will incur huge cost nearly 40% more expensive (based on Hasiru Dala’s Experience)
Another challenge specifically for Bengaluru is that Cement plants are at least 12 hours away in north Karnataka.
Our Approach
Hasiru Dala is trying to ensure that the Extended Producer Responsibility policy is pro-worker and does not exclude the millions of people dependent on collection, segregation and disposal of waste in India. The EPR policy, in India, places a responsibility on the State Governments to monitor the manufacturers, producers and recyclers
The organization is providing training to waste pickers about EPR rules and encouraging them to collect material which can’t be recycled also.
Bringing awareness about traceability of materials among informal players and training on data collection, traceability to the small informal waste traders, encouraging waste pickers to become formal entrepreneurs.
We are working with policymakers to advocate for use of plastic material which is reusable and recyclable. Further, the organization is advocating that the companies should incentivize the collection of non-recyclable waste and take responsibility or play a role in its disposal.
We did a pilot study of Zuvari cement plants and the utilization of waste as a resource by BBMP. This was the first experiment of collecting segregated combustible fraction (SCF) [1] and sending it to a cement plant in Bengaluru, that was experimented in 2014.
[1] These fractions can be processed and converted to refuse derived fuel (RDF), which carries significant calorific value, and can be utilized as alternative fuel in various industries in line with the principle of waste to wealth.