Plastics, while useful for their versatility, durability, and low cost, pose environmental challenges, especially in terms of waste and pollution. Today, even when we know that plastics is a wonderful materials, human greed and powerful lobbyists have made it to be a devil in many eyes. This is what we need to reimagine the way we produce, consume and dispose of plastics. That too, how much responsibility. The world is joining hands together to find solutions amicably in agreeing approaches and systems through a commonly decided international instrument as “International Legally Binding Agreement” (ILBA) between all nations as a – ‘Plastics Treaty’. The fifth round of negotiations for the Global Plastic Treaty recently concluded in Busan this December 24 could not address the most controversial proposals on the agenda – a cap on global plastic production. Maybe we all could not agree because the problem is complex; we all need to understand that all plastics are not bad-the benefits of plastics are more than the annoyance caused by the plastics packaging which is projecting the debate. We have to find a way to neutralise the problems from plastic packaging. We cannot have the aesthetics (in packaging) overrun the environment. Today we have reached a stage to save ourselves rather than to save the planet.
YES, demand for plastic has boomed over the past two decades – much of it driven by China. In 1992, China accounted for less than 10 per cent of global plastics demand; today, it accounts for 40 per cent, making it the single largest market in the world for plastic. India is not far behind. Globally from 1950 till 2022 globally we have produced nearly 0.8 billion tons of plastics. Packaging accounts for around 40% of total plastic production globally. This equates to approximately 160,000,000 metric tonnes annually, based on global plastic production of about 400 million metric tonnes per year as of 2021-2023 estimates. Varying figures exist for how much of it has been recycled and rest all is lying unattended effectively. But for this we homo-sapiens (humans) are to be blamed for the mess in plastics – for plastics does not walk or talk by itself; its only we humans – make it walk and talk the way we want it. Today that has become a challenge for ALL of us. Sooner we realize the better it is.
Here’s the breakdown of plastic used in packaging by material type. Polyethylene (PE) has 36% share of packaging plastics; polypropylene (PP) used in food containers, caps and closures has nearly 19% share. PET has nearly 12%; Polystyrene and expanded polystyrene nearly 6%; polyvinyl chloride (PVC) nearly 4%. And other plastics, e.g. polycarbonates, bioplastics, 23%. By application food and beverage packaging takes away nearly 50% of packaging plastics. Industrial and transport packaging takes away 25% of plastic – includes shrink wrap bubble containers and pellet straps. Healthcare and pharmaceuticals, another 10% e.g sterile packaging and blister packs. Personal care and household products nearly 15%. Another feature we need to understand is how in geographies we are consuming the plastics globally. Asia Pacific’s largest producer and consumer due to manufacturing industries, accounts for 45% of global packaging plastic consumption; North America heavy use in food and beverage Packaging accounts for nearly 20% full storm. Europe focus on recycling and sustainable packaging accounts for nearly 20%. Latin America, Africa, Middle East, smaller markets, but growing very rapidly account for 15%. Therefore, today, the need of hour is how we can successfully bring back the plastics to maintain better circularity. Therefore, Extended Producer Responsibility (EPR) becomes one of the most important tools globally.
Several steps have been undertaken by numerous governments, and manufacturers of virgin plastics resins; producers, importers, brand owners, (PIBOs) globally to create more circular systems – minimization of waste, regenerative thinking, reuse the rigid (India has created a law), reduce over time plastic production, redesign, processes optimization and refurbishing to overcome the problems created by packaging plastics. Yes, the new policies afloat include a more commonly accepted across nations – the introduction of the extended producer responsibility,’ (EPR) regimes for material(s) resource efficiency brought in plastics, electronic goods, etc. In india in the last one year. It has been extended to rubber & tires; used oils, glass, paper, sanitary and batteries etc. key strategies to address circularity and sustainability.
Extended Producer Responsibility (EPR) in plastics can certainly be seen as a blessing in disguise for businesses, society, and the environment. The public consultations, representations made over the last three years by industry, civil society, independent think tanks, states and academics has led into addressing a complex yet viable solution to a problem. The Government of India has been rather proactive in making 8-9 amendments plastics EPR till finally released in March 2024 and thereafter; since it was first released in February 2022. Therefore, to satisfy divergent and diverse stakeholders has been seen as an Achilles heel! Many path breaking features of the recent amendment created are seen as.
- EPR certificates provided by PIBOs and manufacturers and registered PWP shall be verified and in case of difference, the lower figure shall be considered towards fulfilment of EPR obligation under these rules.
- Central pollution control board (CPCB) will issue Authorization guidelines for establishment of electronic platform for trade of EPR certificates between obligated entities
- Highest and the lowest price for EPR certificates which shall be equal to 100% and 30% respectively, of the EC leviable, i.e., Minimum of 30% of Rs. 5000/- Rs. 1500/MT, and Maximum 100% of Rs. 5000/- Rs. 5000/MT.
- Producer definition revised to include Contract Manufacturers and manufacturers of intermediate materials.
- Micro & Small Producers not obligated EPR Liability but mandated to register, (Manufacturer to take obligation of such MSME producers).
- Importer definition revised to Include Commercial use only and resins or pellets or intermediate materials
- Category V- Biodegradable plastics introduced and manufacturer to take obligation for items made up of biodegradable plastics.
- Manufacturers of permitted items made from compostable plastics or biodegradable plastics shall fulfil the EPR obligation through procuring certificates from Local body.
- Marking & Labelling update on each recycled plastic packaging or commodity and adhere to IS 14534:2023.
- On the Centralized EPR Portal, Brand Owners need to enter plastic procurement and Producers need to enter the plastic packaging sales information. In the case of Contract Manufacturers involvement, the loop was not getting closed.
- Hence, CPCB in its recent amendment has introduced the registration of Contract manufacturers under the ‘Producer’ category so that the track of liability shift from plastic packaging producers to registered Contract Manufacturers to registered Brand owners can smoothly take place.
- Environment compensation has been in built to check gross violations. This is strict and now is being administered with greater authority.
But still the debate continues in many corridors that we need more to be addressed in the plastics ecosystem. While I personally see that EPR moving in the right direction.
- Encourages Innovation
Blessing: EPR drives producers to rethink product design, packaging, and supply chains to make them more sustainable. This can lead to the development of innovative materials, energy-efficient production methods, and better recycling technologies. Example: Companies today are investing in redesigning packaging (Colgate toothpastes) to be biodegradable or easier to recycle.
- Enhances Brand Value
Blessing: Businesses that proactively embrace EPR often improve their standing as socially and environmentally responsible. Consumers are increasingly favouring sustainable brands. Example: FMCGs have gained customer loyalty by adopting sustainable practices.
- Promotes Circular Economy
Blessing: EPR reassures the transition from a linear economy (make-use-dispose) to a circular economy, where materials are reused, recycled, repaired and repurposed. This reduces the need for virgin resources and further minimizes environmental degradation. Example: Electronics manufacturers creating programs to refurbish and resell used devices.
- Prepares Businesses for Future Regulations
Blessing: By realizing EPR now, companies are better prepared for stricter environmental regulations in the future. This reduces compliance risks and avoids potential penalties. Example: Companies in the EU aligning with directives like the Waste Electrical and Electronic Equipment (WEEE) Directive.
- Drives Cost Efficiency in the Long Run
Blessing: Although EPR may initially seem costly, it often leads to long-term cost savings through resource efficiency, reduced waste disposal costs, and the creation of secondary raw materials. Example: Reusing recovered materials can lower production costs compared to sourcing new raw materials.
- Catalyses Social and Environmental Benefits
Blessing: EPR contributes to cleaner environments, reduced greenhouse gas emissions, and healthier communities, aligning with global UN sustainability development goals (SDGs). Example: The reduction of plastic pollution through EPR programs improves marine ecosystems and biodiversity.
In nutshell while EPR might initially appear as a regulatory burden, it can ultimately drive innovation, profitability, and sustainability, benefiting businesses, consumers, and the planet.
The floor does not end here; we still want more. A few views emerging in the plastics EPR ecosystem in various workshops and meetings are
- The EPR is making rich the richer and the Informal sector waste i.e. waste management agencies – (as entrepreneurs), who actually manage waste through safaii sathis (waste pickers) and aggregators (kabadiwallas) is left to market forces. Need for formal recognition and aligned with mainstream systems.
- Yes, when talking with many waste processing agencies, they do point out that the producers, importers and brand owners (PIBOs) must invest in the supply chain and the systems; at least 50% of their EPR payment obligations for the ‘’certificates” to the recyclers and balance 50% should be considered for investments in infrastructure, and inclusivity. Yes, EPR remains a disconnect between recyclers, aggregators, and waste management agencies and generators.
- Stakeholder dialogue must be continuous and ongoing by the regulators and the policy formulators to keep abreast of the practical challenges enroute for solutions.
- Monitoring at the portal at Central Pollution Control Board or state boards is still not user-friendly. There is difficulty in monitoring and enforcing EPR regulations as a priority.
- With PVC plastics commonly used in packaging need more focus at the portal. The EPR plastics portal currently lacks records for polyvinyl chloride recycling facilities. This is leading PVC being processed in the informal sector without following necessary regulations and permits.
- Audits and inspections need to be made more realistic, and prioritised. There needs to be actions against the defaulters. Today this is in fact happening.
- More focus needs to be on the education, communications and management of packaging waste reduction as shared in the photo below.
- GST rates for Recycled Plastic Equal to Virgin Plastic; This is not Compatible and Discouraging for Recyclers. This makes recycled plastic content less financially attractive. Recyclers are often faced with higher operational costs, and this pricing structure discourages traceability and most of the billing is done in cash and in the bargain the government loses GST. We need to seriously focus on this. Infact, we need to create the recycling industry laced with tax incentives for industries that use recycled plastics in their products beyond the EPR bindings; encouraging a shift towards circular economies.
- Provide tax credits or financial incentives to recyclers for processing and producing high-quality recycled plastics with greater traceability.
- Clearly define roles for all stakeholders in the plastic waste management ecosystem, including formal and informal waste pickers, processors, collectors, and municipalities.
The floor does not end here; we still want more. A few views emerging in the plastics EPR ecosystem in various workshops and meetings are
- The EPR is making rich the richer and the Informal sector waste i.e. waste management agencies – (as entrepreneurs), who actually manage waste through safaii sathis (waste pickers) and aggregators (kabadiwallas) is left to market forces. Need for formal recognition and aligned with mainstream systems.
- Yes, when talking with many waste processing agencies, they do point out that the producers, importers and brand owners (PIBOs) must invest in the supply chain and the systems; at least 50% of their EPR payment obligations for the ‘’certificates” to the recyclers and balance 50% should be considered for investments in infrastructure, and inclusivity. Yes, EPR remains a disconnect between recyclers, aggregators, and waste management agencies and generators.
- Stakeholder dialogue must be continuous and ongoing by the regulators and the policy formulators to keep abreast of the practical challenges enroute for solutions.
- Monitoring at the portal at Central Pollution Control Board or state boards is still not user-friendly. There is difficulty in monitoring and enforcing EPR regulations as a priority.
- With PVC plastics commonly used in packaging need more focus at the portal. The EPR plastics portal currently lacks records for polyvinyl chloride recycling facilities. This is leading PVC being processed in the informal sector without following necessary regulations and permits.
- Audits and inspections need to be made more realistic, and prioritised. There needs to be actions against the defaulters. Today this is in fact happening.
Sr. Program Director (Circular Economy) CEE