Centre for Science and Environment

  • 03 Nov 2024

In News:

Centre for Science and Environment release a report on Extended Producer Responsibility (EPR) for Plastic Packaging

Key Findings:

  • EPR Guidelines (2022) were a step towards enforcing the "polluter pays" principle, but the system faces significant issues in its implementation and registration processes.
  • Centre for Science and Environment (CSE) report, released on October 29, 2024, highlights gaps in the EPR system for plastic packaging and suggests corrective actions.

EPR Guidelines Overview:

  • Issued by: Union Ministry of Environment, Forest and Climate Change (MoEFCC).
  • Objective: Hold producers, importers, brand owners (PIBOs), and plastic waste processors (PWPs) responsible for managing plastic packaging waste.
  • Key Requirements:
    • PIBOs must register on a centralized portal and set targets for collection, recycling, and reuse of plastic packaging.
    • Registration involves compliance with targets on end-of-life recycling and recycled content usage.

Problems Identified in the Current EPR System:

  • Low Registration and Enrollment:
    • 41,577 registrations on the EPR portal, but a significant discrepancy in the type of stakeholders registered.
    • 83% of registered entities are importers, 11% are producers, and only 6% are brand owners.
    • Producers contribute 65% of the plastic packaging in the market but have low registration.
  • Absence of Key Polluters:
    • Manufacturers of virgin plastics are notably absent from the portal, despite being required to register.
  • Fraudulent Practices:
    • 700,000 fake certificates were generated by plastic recyclers, far exceeding the actual certificate generation capacity.
    • The Central Pollution Control Board (CPCB) found that such fraudulent activities are undermining the integrity of the system.
    • For example, end-of-life co-processing units (e.g., cement plants) claimed to have processed 335.4 million tonnes per annum of plastic waste, while their actual capacity is just 11.4 million tonnes per annum.
  • Underreporting and Mismanagement:
    • Despite 23.9 million tonnes of plastic packaging being introduced into the market, the CPCB’s estimation of plastic waste generation (4.1 MT annually) is underestimated.
  • Lack of Stakeholder Representation:
    • Urban local bodies and informal waste collectors—key contributors to plastic waste management—are not included in the EPR framework, which limits their incentives and support.

Recommendations for Improvement:

  • Incorporate the Informal Sector:
    • Recognize informal waste collectors and waste management agencies in the EPR framework to improve traceability and ensure better waste management.
  • Eliminate Fraudulent Practices:
    • Strict actions need to be taken against fraudulent recyclers and fake certificate issuers to restore credibility to the EPR system.
  • Establish Fair Pricing for EPR Certificates:
    • Undertake baseline cost studies to determine the true costs of plastic waste management, ensuring fair pricing for recycling certificates and preventing undervaluation.
  • Standardize Packaging:
    • Focus on product standardization to ensure that packaging materials are uniform and easily recyclable.
  • Strengthen Monitoring:
    • Improve oversight on the registration process and ensure that all polluters (producers, importers, brand owners) comply with the system’s guidelines.

EPR and Plastic Waste Management: Context and Importance

  • Extended Producer Responsibility (EPR) is a policy approach where the responsibility of managing the entire lifecycle of plastic products (from production to disposal) lies with the producer.
  • It is an essential part of India’s Plastic Waste Management Rules (2016), which mandate the recycling and proper disposal of plastic packaging waste.

Key Elements of EPR:

  • Producer Accountability: Producers are responsible for the take-back, recycling, and final disposal of plastic packaging.
  • Waste Minimization: Encourages reducing waste at the source by promoting sustainable packaging designs.
  • Lifecycle Approach: Considers the entire lifecycle of the product, focusing on sustainability from production to disposal.
  • Polluter Pays Principle: Ensures that the cost of waste management is borne by those responsible for generating the waste.