Extended Producer Responsibility:
A strategy to achieve circular economy in plastic packaging

 

Countless applications of plastic along with its matchless characteristics have resulted in the exponential growth in its consumption across the globe. Its durability, one of its hailed benefits, is at the same time being reviled as the biggest threat the polymer is posing to the environment. BBC recently reported the discovery of a plastic sandwich wrapper from Scotland’s Cairngorms National Park dating back by almost three decades with no signs of degradation, which clearly demonstrates its durable nature and threat.

Based on the 'polluter pays' principle, Extended Producer Responsibility (EPR) for the plastic sector was first introduced in India under Plastic Waste Management (PWM) Rules, 2016. The rules imposed the onus of collection, transportation, scientific disposal and management of post-consumer plastic on its producers, importers, and brand owners (PIBOs). Though the rules mandated installation of the waste collect-back system and respective plan submissions by PIBOs to the state pollution control boards (SPCBs), the lack of clarity of the mechanism, registration norms, unpreparedness of PIBOs and poor municipal capacities resulted in poor implementation of these regulations.

It was in FY 2018 that the country started taking meaningful steps aligned with EPR, following an amendment of the PWM rules providing clarity on the registration norms. Recently, in FY 2020, the Ministry of Environment, Forest and Climate Change (MoEFCC) has introduced the draft Uniform Framework for EPR, spelling out the responsibilities of the centre, urban local bodies (ULBs), and PIBOs as well as other specifications. Three models proposed in the framework for waste collect-back systems include a polluter fee, Producer Responsibility Organisation (PRO) and the plastic credit model.

Under the fee-based model, PIBOs are mandated to contribute to an EPR corpus fund at the central level based on the normative cost borne by ULBs to manage the waste generated. Under the PRO model, PIBOs rely on a certified PRO who manages the recycling on its behalf for a negotiated sum. Under the plastic credit model, PIBOs need not recycle their own waste but recover/recycle an equivalent amount of waste to meet the obligation. Under all models, PIBOs are mandated to furnish appropriate evidence for the waste processed from accredited processors. The framework has held the Central Pollution Control Board (CPCB) as the body responsible for forming a national level PRO Association and monitor and report the entire EPR mechanism.

The countries that have successfully implemented the EPR have limited their scope to specific types of plastic waste and have an established segregation system. However, India's draft framework has not clearly defined its scope nor does it have a solid segregation system. The devolution of the EPR corpus fund from the centre to the local level can improve its accessibility and reduce approval and permission timeline enabling faster implementation. The framework currently based on the 'polluter pays' principle should take into consideration the strategies to minimise the production by introducing regulations for design improvements such as design for environment, design for collection, and design for recycling/reuse to delay the end of life and provide other incentives and impose punitive measures at the upstream sector.

The framework should also consider listing feasible alternative materials having evaluated its sourcing sufficiency and environmental footprint in comparison to plastic. Additionally, systematising steps to link back waste to its producers and ensuring proper enforcement and monitoring, EPR will prove to be one of the powerful tools to curb the plastic waste crisis in India.

References

 

Sherine Thandu Parakkal
stparakkal@devalt.org
 

 

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