EPR-Whose waste it is??
Extended Producer Responsibility as defined in PWM Rules is the responsibility of the Producers, Importers, Brand Owners for environmentally sound management of the product until the end of its life. So the industry that uses plastic as a packaging material has the obligation to take care of their packaging waste.
EPR is a good concept and I think this will help in formalizing the plastic waste management system in India. As of now, it is proposed that the EPR shall be brand neutral. But the industry wants it's to be brand, geography, and substrate neutral and that is logical also.
Currently, major brands are fulfilling their EPR obligation with the help of PROs/Service Providers/IPs and are not quite engaged with ULBs for collection and disposal activities. But I think that Brand Owners and Producers must also engage with ULBs for collection, segregation, and Recycling of plastic waste. This will help the local bodies to use the fund to build the infrastructure as well as to set up the process and operationalization of the waste management system in their municipal limit.
As per the PWM Rules 2016, Local bodies have the responsibility of proper channelization of plastic waste but till now nothing much has been done by them on the ground. The corpus fund which will be contributed by the brand owners at Central/state level has to be utilized by the ULBs.
Medium and small scale industries also have to take the responsibility of PWM as we can't put total responsibility on the large Industries only. India is generating around 26000 TPD of plastic waste and only 60% of that gets recycled. Currently, besides big brands, small brands have not started doing anything on EPR front as they still in a hope to get some exemptions from it. But everyone has to take responsibility for fighting plastic pollution.
There is a need for a single-window clearance system along with a national portal for EPR accounting. This is pending for a long time. A Single Central body must be constituted for the monitoring of all the EPR activities at State/Central level. From the point of traceability and audit, it is most important.
Without a proper monitoring mechanism, there is a chance of duplication of documentation and maybe the same EPR credits can be sold to two different brands by a service provider. Monitoring body will also help in the implementation of various projects related to PWM across India and also in setting up the targets for the brand owner.
As producer is not required to recycle their own packaging waste but to ensure that equivalent amount of packaging waste has been recovered and recycled to meet the obligations they are mandated to acquire evidence of recycling/recovery from accredited processors, Now as EPR is about Post Consumer Plastic waste, there is maximum chances are that industrial plastic waste can be sold to Brands as EPR credits.(Plastic Credit) Most of the Plastic Recyclers in India depends on factory waste for running their plants. Industrial plastic waste can be shown as post-consumer plastic waste on paper.No one can deny this that to fulfill the compliances on paper, such a thing can happen.
So this whole EPR process needs transparency, monitoring process, traceability of documents and proper channelization of plastic waste must be ensured otherwise many industries can take advantage of these frail and vague rules. There is a requirement of a robust system to ensure transparency.
EPR will become part of the broader perspective of Circular Economy. As a nation, We must think about the adoption of Circular Economy which aims to eliminate waste not just from recycling processes, but throughout the life cycle of products and packaging. A circular economy aims to maximize the value and eliminate the waste by improving the design of materials, products and business models. Its focuses on minimizing the use of raw material and energy through the restorative system. Closing the material and energy loop is important so that leakage can be stopped. The industry must focus on sustainable packaging, which is the need of the hour.