Experts suggest critical interventions to make extended producer responsibility system for plastic packaging more robust

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700k fake certificates, major polluters missing: Misuse of EPR legislation worsening India’s plastic problem, shows CSE report

Experts suggest critical interventions to make extended producer responsibility system for plastic packaging more robust

Preetha Banerjee

Published:30th Oct, 2024 at 12:33 PM

While the Indian government's 2022 extended producer responsibility guidelines was a step in the right direction, it needs more teeth to truly uphold the "polluter pays" principle in the country's plastic waste management journey, according to a new report by Delhi-based think tank Centre for Science and Environment.

The report released October 29, 2024 highlighted the gaps in the existing sytem of registration and implementation of the guidelines, and also outlined a way forward.

The EPR guidelines, issued by the Union Ministry of Environment, Forest and Climate Change (MoEFCC) on February 16, 2022, require manufacturers, producers, importers and brand owners (PIBO) as well as plastic waste processors (PWP) to register on a centralised portal.

Under this, there are specific targets for collection, recycling, end-of-life, recycled content usage and selective re-use in plastic packaging.

But a closer look at the EPR ecosystem showed how it is plagued by multiple undesirable outcomes. First, the registration data showed that the stakeholders who are the biggest plastic polluters have the some of the lowest enrolment in the system.

The centralised EPR portal has received 41,577 registrations from PIBOs (till the time of the CSE assessment) — 83 per cent of the registered PIBOs are importers, 11 per cent are producers and 6 per cent are brand owners, according to the authors of the report.  

“Of these, producers are responsible for introducing the majority of plastic packaging into the Indian market — cumulatively accounting for 65 per cent of the total. Brand owners are the next biggest contributors with 26 per cent. Importers, despite being the highest in numbers to register, have only introduced 9 per cent of the plastic packaging introduced in the market.”

No manufacturers of virgin plastics feature on the portal, despite the EPR guidelines mandating registration for manufacturers.

Atin Biswas, programme director, sustainable solid waste management and circular economy unit, CSE

The report also highlights the shocking reports of fraud disclosed by the Central Pollution Control Board (CPCB) in October 2023.

CPCB and the state pollution control boards have found that 700,000 fake certificates were generated by plastic recyclers. "This is 38 times more than the certificate generation capacity of recyclers," according to the report. The CPCB has already imposed a cumulative fine of Rs 355 crore on the violators.

The CSE analysis found similar malpractices in mechanical recyclers operating in states like Delhi, Bihar, Madhya Pradesh, Andhra Pradesh and Tamil Nadu, however they have not been reported by state or central level regulators, Singh added.

“We have found huge differences between the quantity processed and the registered and verified capacities. For instance, end-of-life co-processing (cement plants) units claim to have collectively processed 335.4 million tonne per annum (TPA) of plastic packaging waste against a capacity of a mere 11.4 million TPA!” shared Shrotik Bose, research associate, sustainable solid waste management and circular economy unit, CSE, and one of the authors of the assessment.

“Such practices drive certificate prices to untenable lows, undermining the system’s credibility," said Siddharth G Singh, programme manager, sustainable solid waste management and circular economy unit, CSE

As far as we know, no action has yet been taken against the PIBOs for defeating the purpose and principles of the EPR guidelines.

The PIBOs have introduced 23.9 million tonnes (MT) of plastic packaging into the Indian market since the launch of the EPR portal in April 2022, the authors of the report stated, translating into an annual average plastic packaging waste generation of about 8 MT. “This indicates that the Central Pollution Control Board’s (CPCB’s) estimation of annual average plastic waste generation (all kinds of plastic waste) of 4.1 MT is an underestimation,” added Biswas.

Another concern, he flagged, is that key contributors to plastic waste management such as urban local bodies and informal waste collectors lack representation in the EPR framework. "This absence deprives them of incentives and support to manage plastic waste effectively, placing an undue burden on local governments.”

There’s time for turnaround

Amid the disheartening findings, the authors provide is a silver lining: There is some time for corrective measures, because the implementation of the guidelines have a timeline till the fiscal year 2027-28.

First, the informal sector and waste management agencies, who are currently missing from the EPR ecosystem, need to be recognised to increase the traceability of the value chain, according to Aniket Chandra, senior research associate, sustainable solid waste management and circular economy unit, CSE and co-author of the assessment.

Then, the malpractices need to be weeded out of the system, the authors noted. "The flow of fraudulent certificates and the operations of fraudulent processors and recyclers need to be stopped," the report stated.

The other actions highlighted in the CSE report were: Using the portal to report accurate numbers for plastic waste generation; undertaking baseline cost studies for plastic waste management to help establish a benchmark for fair pricing of recycling certificates and prevent undervaluation in the market; and product standardisation for improving the recyclability of plastic waste by ensuring that packaging materials and designs are uniform. 

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