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The Ministry of Environment, Forest and Climate Change, Government of India, recently released the draft?Environment Protection (#ExtendedProducerResponsibility for Packaging made from paper, glass and metal as well as sanitary products) Rules, 2024 for comments. The regulation uses a similar framework as the Plastic Waste Management Rules on EPR (5th amendment) 2022. These rules mandate that producers, importers, and brand owners (PIBOs), including online platforms/marketplaces and supermarkets/retail chain register on the centralised online portal, and fulfil their extended producer responsibility (EPR) towards recycling, recycled content and end of life disposal, meeting the targets set for each.
While the draft rules are a welcome measure, they must address these key issues if they are to actualise the vision of a #circulareconomy.
1. Need to prioritise action over aspiration : Formally set targets for reuse in glass and reduction of waste in sanitary waste
2. Need for alignment with other rules, policies and standards - Example SWM Rules 2016 and the draft SWM Rules 2024, Draft Menstrual Hygiene Policy and Bureau of Indian Standards (BIS) guidelines on packaging for glass, metal, paper and sanitary products
3. Need to recognise, acknowledge and integrate informal waste workers in the recycling value chain without creating parallel systems for collection. There is also a need to map existing recycling infrastructure in both formal and informal settings
4. Need to account for multi material packaging, and all such mixed materials will need to be factored in within the existing EPR
5. Need to account for inefficacy of EPR credits in the PWM Rules, as it has led to various malpractices, including fraud through the generation of fake EPR trading credits and sham recycling operations as this only allows temporary solutions to the problem and undermines the preamble of the rules, which is waste reduction, redesigning packaging, channelising investments in recycling infrastructure and actually fixing producer responsibility.
Vignesh Hasirudala Arpita B. Madhuvanthi Rajkumar Ambily Adithyan Dr Lata Ghanshamnani Solid Waste Management Roundtable ( SWMRT) Hasiru Dala
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