Context

In October, the Environment Ministry published draft regulations on Extended Producer Responsibility (EPR), set to come into effect by the end of this year. These regulations denote a backslide, particularly with respect to integration of the informal sector.

What is EPR?

• Extended Producer Responsibility (EPR) requires the manufacturer of a product, or the party that introduces the product into the community, to take responsibility for its life cycle.
• An FMCG company should not only account for the costs of making, packing and distributing a packet of chips, but also for the collection and recycling/reuse of the packet.

Shortcomings in the guidelines

The guidelines fall short in three areas: people, plastics and processing.

[1] Integration of informal sector is lacking

• By failing to mention waste pickers or outlining mechanisms for their incorporation under EPR, the guidelines are retrogressive.
• For decades, waste pickers, working in dangerous and unsanitary conditions, have picked up what we throw away.
• Besides, by diverting waste towards recycling and reuse, waste pickers also subsidise local governments responsible for solid waste management.
• Further, they reduce the amount of waste accumulating in cities, water bodies and dumpsites and increase recycling and reuse, creating environmental and public health benefits.
• Between 1.5 and 4 million waste pickers in India work without social security, health insurance, minimum wages or basic protective gear.
• Suggestions:  An effective EPR framework should address the issue of plastics and plastic waste management in tandem with the existing machinery, minimise duplication and lead to a positive environmental impact, with monitoring mechanisms including penalties for non-compliance.
• EPR funds could be deployed for mapping and registration of the informal sector actors, building their capacity, upgrading infrastructure, promoting technology transfer, and creating closed loop feedback and monitoring mechanisms.

[2] The scope of plastic covered need to be altered

• The EPR guidelines are limited to plastic packaging.
• There are other multi-material plastic items like sanitary pads, chappals, and polyester that pose a huge waste management challenge today, but have been left out of the scope of EPR.
• Three categories of plastic packaging: Plastic packaging can be roughly grouped into three categories: recyclable and effectively handled by the informal sector, technologically recyclable but not economically viable to recycle, technologically challenging to recycle (or non-recyclable).
• [1] Rigid plastics like PET and HDPE are effectively recycled.
• Suggestion: The government could support and strengthen the informal recycling chain by bridging gaps in adequate physical spaces, infrastructure, etc.
• [2] Typically flexible plastics like LDPE and PP bags are recyclable, but due to their contamination with organic waste, lightweight, and high volume, the costs of recycling are prohibitively expensive relative to the market value of the output.
• Suggestion: Market value for these plastics can be increased by increasing the demand for and use of recycled plastics in packaging, thus creating the value to accommodate the current costs of recycling.
• [3] Multi-layered and multi-material plastics are low weight and voluminous, making them expensive to handle and transport.
• Since they are primarily used in food packaging, they often attract rodents, making storage problematic.
• Even if this plastic is picked, recycling is technologically challenging as it is heterogeneous material.
• The Plastic Waste Management Rules mandated the phase-out of these plastics.
• However, in 2018, this mandate was reversed.

[3] Processing technologies need to be closely evaluated

• Not all processing is recycling.
• Processes like waste-to-energy, co-processing and incineration have been proven to release carbon dioxide, particulate matter, harmful dioxins and furans which have negative climate and health impacts.
• While the environmental impact and desirability of these processes continues to be debated, the draft regulations legitimise them to justify the continued production of multi-layered plastics.
• Technologies like chemical recycling and pyrolysis are capital-intensive, yielding low returns and running into frequent breakdowns and technological problems.
• They also release carbon dioxide and other pollutants.
• These end-of-life processes are economically, environmentally and operationally unsustainable.
• A number of gasification, pyrolysis and other chemical recycling projects have figured in accidents such as fires, explosions and financial losses.

Way forward

• Address issues of the informal sector: The consultation process should involve informal workers.
• Alter the scope of plastics covered: The scope of plastics covered by the guidelines could be altered to exclude those plastics which are already efficiently recycled and to include other plastic and multi-material items.
• Processing technologies should be closely evaluated: And end-of-life processing technologies should be closely evaluated, based not only on their health and environmental impacts, but also on the implications for continued production of low-quality and multi-layered plastics.

Consider the question ” The Environment Ministry published draft regulations on Extended Producer Responsibility (EPR). Examine the issues with the regulations and suggest the way forward” 

Conclusion

In conclusion, the government should redo the consultation process for the draft guidelines.

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