EXTENDED PRODUCER RESPONSIBILITY AND WAY FORWARD

Presented by : Mr. Hiten Bheda

Chairman - Environment Committee, AIPMA

Immediate Past President, AIPMA

INDIA CONSUMPTION STORY

▰ 1.3 BILLION POPULATION

▰ 14 MILLION TONS OF PLASTIC CONSUMED

▰ CONSUMPTION INCREASING AT 10%

▰ GEOGRAPHICAL IMBALANCE

▰ URBAN/RURAL

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PLASTIC WASTE GENERATION IN INDIA

▰ India generates 25,940 tonnes of plastic waste every day, but 40% of it remains uncollected.

▰ Delhi, Chennai, Kolkata, Mumbai and Bengaluru combined generate more than 50% of the total plastic waste

▰ India’s Total Plastic Waste Generation –

As per the estimates by CPCB, plastic waste generated in India in the year 2017-18 was

660,787.85 tonnes.

(Mere 14 Of 35 India’s State Pollution Boards Submit Partial Information On Plastic Waste Management).

▰ Average plastic waste share in Municipal Solid waste in India : Appx. 6.92%

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Name of the SPCB or PCC Estimated Plastic Waste

generation n Tons for

Annum (TPA)

Arunachal Pradesh 6

Bihar 2280

Chandigarh 12775

Gujarat 269808

Jammu & Kashmir 27870

Madhya Pradesh 61037

Manipur 24

Meghalaya 15

Nagaland 14052

Odisha 12092

Punjab 54066

Tripura 28

Uttar Pradesh 206733

Total 660786

State wise Plastic waste generation (in tons)

Source :- CPCB Annual Report for the year 2017-18 on Implementation of

PWM

Indian Plastics Consumption And Recycling

Source : APIC 2016/2017 , Country Paper India

• Total plastic consumption projected in Indiafor 2017 is 14.5 Million ton (excludesEngineering Plastics, Goods & PackagedGoods Imported).

• Central Pollution Control Board has estimatedfor 2017-18.

Plastic Waste in India : 26,000 TPD : 9.4 MTA*

Plastic Waste Recycled : 15,600 TPD : 5.6 MTA

Uncollected and littered : 9,400 TPD: 3.8 MTA

*PWM 2016 guideline

…….High Recycling in India supported by Informal sector

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Plastic Dominates Packaging Mix of Consumer Goods in India : 2015

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Across Categories

plastic packaging dominates household

purchases of consumer

goods in India

ECO SYSTEM FOR PLASTIC WASTE

▰ PRODUCERS

▰ OPERATING UNDER LAX ENVIRONMENT

▰ PACKERS/BRANDS

▰ DESIGN SMALL THIN

▰ CONSUMER

▰ BEHAVIOURAL PROBLEM/LITTERING

▰ UDB/RDB

▰ INFRASTRUCTURE/INITIATIVE

▰ REGULATIONS

▰ PWM 2011/2016/2018 EXECUTION7

Unique situation in India

▰ Ragpickers who are the “informal”stakeholders in the waste managementsystem are a vulnerable group in India. Thisunpaid and unrecognised group form anintegral part of the waste management eco-system. The number of ragpickers in India isestimated to range between 1.5 million to 4million.

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SAVIOURS DRIVING INFORMAL SECTOR

▰ RECYCLING CLUSTERS ACROSS INDIA

▰ LOW TECH - LOW COST

▰ ISSUES WITH ENVIRONMENT

▰ SOCIAL SECURITY

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RELENTLESS ATTACKS ON PLASTICS BASED ON PERCEPTION AND PARTIAL FACTS

▰ If bags had been recycled, none of these pictures would have

been possible

▰ Problem not with plastic INDUSTRY, it requires change in

perception of SOCIETY through communication

▰ There is need to correct perception and defend against Bad

Science/ Bad Publicity through facts

▰ Responsibility of the industry to come together redesign

processes and products for industry sustainability

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WASTE MANAGEMENT RELATED RULES, 2016

Solid Waste Management Rules, 2016 (SWM)

Construction and Demolition Waste Management Rules, 2016

Plastic Waste Management Rules, 2016 (PWM) E- Waste Management

Rules, 2016

Bio Medical Waste Management Rules, 2016

Hazardous & Other Waste (Management & Transboundary Movement) Rules, 2016

Extended Producer Responsibility

FORM-1 and Registration

Consent to Operate –Take back Action plan

Environment Protection Act , 1986

Extended Producer

Responsibility

Glass, Tin,

Plastic,

Paper etc.

Air and Water Act – Consent to Operate

Amendment Rules, 2018

LEGAL FRAMEWORK

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EXTENDED PRODUCER RESPONSIBILITY (EPR)

▰ Extended producer responsibility

▻ Producers / Brand owners and Importers are responsible for recover the material placed in the market for safe disposal at their cost

▰ Definition

▻ "[EPR] is an environmental protection strategy to reach an environmental objective of a decreased total environmental impact of a product, by making the manufacturer of the product responsible for the entire life-cycle of the product and especially for the take-back, recycling and final disposal”

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EPR

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PLASTIC WASTE MANAGEMENT

NORTH AMERICA ORGANISED LOW

LATIN AMERICA EVOLVING LOW

EUROPE ORGANISED HIGH

FAR EAST MIX HIGH

AFRICA EVOLVING LOW18

PRODUCER RESPONSIBILITY ORGANIZATION (PRO)

▰ Producer responsibility organization

▻ A PRO is a European concept whereby the producer’s responsibility of managing the waste is transferred to the PRO

▻ A PRO’s aim is to bring in more efficiency, cost-effectiveness and awareness while managing the end-to-end operations associated with waste management

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GLOBAL PRO MODELS

▰ Belgium Fostplus program/ Germany Green Dot program

▰ UK Valpack (PRO)

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BELGIUM FOSTPLUS PROGRAM/ GERMANY GREEN DOT PROGRAM

▰ Packaging created and sold to the consumer

▰ PRO – Fostplus get accreditation for five year to operate Packing recovery system in a country

▰ They get funding from EPR system.

▰ They float and finalize tender for collection of packaging waste in a territory.

▰ They also float tender for Sorting of collected packaging waste.

▰ Material recovered is auctioned to the highest bidder.

▰ Viability Gap is funded through EPR liabilities fees on all kind of packaging’s (Glass, Aluminum, Paper, Plastics etc.)

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UK VALPACK (PRO)

▰ Packaging created and sold to the consumer

▰ Packaging waste collected, recovered/recycled by an accredited reprocessor

▰ PRN (Packaging Recovery Note) is generated

▰ Valpak buys PRNs to meet members' obligations

▰ Packaging data and PRNs submitted to the appropriate environment agency to demonstrate compliance with the Packaging Waste Regulations

▰ PRNs are sold on an open market which means that prices fluctuate according to supply and demand. As the diagram below shows, if there is a perceived shortage of PRNs then prices will increase but if there is a perceived excess of PRNs will decrease

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WHO PAYS FOR EPR CHARGES

▰ EPR is based on Consumer pay principal. Brands are closest to the consumer to charge for the packaging recovery costs.

▰ Type of packing is finally decided by Brand Owners depending on utility of product to be packaged.

▰ They can reduce the superfluous packaging.

▰ The proportion of cost for EPR liability compared to final product sold is marginal.

▰ Importers are equivalent to local brands, if liability is distributed to processors the importers won’t be able to pass it on their suppliers out of India. (As per PWM Rules importers have the same liability as brand owners / producers. Importer has to evolve a mechanism /system to collect back where ever he introduces any plastic packaging)

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GLOBAL PLASTICS RECYCLING RATES

▰ Europe (EU 28 + 2) Recovery of Plastics Waste 2014

24Source: Consultic Marketing & Industrieberatung

GmbH

PLASTICS RECYCLING HUBS INDIA

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S.No State Location S.No State Location

1 Bihar Patna 26 Maharashtra Aurangabad

2 Chattisgarh Raipur 27 Maharashtra Solapur

3 Chattisgarh Bilaspur 28 Maharashtra Kolhapur

4 Daman Daman 29 Odisha Bhubaneswar

5 Delhi Tikri Kalan 30 Odisha Cuttack

6 Delhi Kamruddin Nagar 31 Odisha Balasore

7 Delhi Vishwas Nagar 32 Punjab Amritsar

8 Delhi Shahdara 33 Punjab Khanna

9 Gujarat Dhoraji 34 Punjab Dhuri

10 Gujarat Ahmedabad 35 Punjab Ludhiana

11 Gujarat Bhavnagar 36 Punjab Moga

12 Karnataka Belgaum 37 Punjab Jalandhar

13 Karnataka Dharwad 38 Rajasthan Jaipur

14 Karnataka Shivamogga 39 Tamilnadu Chennai

15 Karnataka Mangaluru 40 Tamilnadu Coimbatore

16 Karnataka Davanagere 41 Tamilnadu Madurai

17 Karnataka Tumakuru 42 Tamilnadu Tiruchirappalli

18 Karnataka Bengaluru 43 Tamilnadu Tirunelveli

19 Karnataka Mysuru 44 Tamilnadu Salem

20 Kerala Kochi 45 Telangana Hyderabad

21 Madhya Pradesh Indore 46 Uttarpradesh Kanpur

22 Madhya Pradesh Bhopal 47 Uttarpradesh Meerut

23 Maharashtra Dharavi 48 Uttarpradesh Lucknow

24 Maharashtra Malegaon 49 West Bengal Kolkata

25 Maharashtra Jalgaon

India has highest plastics recycling rates

EPR OVERVIEW

▰ EPR in Canada

▻ About 50 product stewardship programs

▻ Programs are mandated

▻ An NGO typically manages the program

▰ EPR in Europe

▻ Many EU countries employ EPR

▻ Some mandated, some voluntary

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Existing EPR for Packaging

EPR for Packaging Under

Consideration

Existing EPR for Packaging

STRUCTURAL INTEGRATION OF THE INFORMAL SECTOR IN MUNICIPAL SOLID WASTE MANAGEMENT

▰ Tunisia – Case study

▰ North Carolina – case study

▰ New York Product Stewardship Council

▰ Producer Responsibility for WEEE in the European Union

▰ The Dutch system

▰ Spain

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INDIAN MODELS : MOEF&CPCB

▰ Model 1:

▻ A National Framework on EPR is proposed where the producers/importer/brand

owner is required to contribute to the EPR corpus fund at the central level.

▻ The amount to be contributed by each of the producers/importer/brand owner will

be decided based on the amount of plastic being introduced into the market by the

producers/importer/brand owner.

▰ Model 2:

▻ Targets will be assigned to producers based on the plastic put out by them in the

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INDIAN MODELS : MOEF&CPCB

▻ Producers will not be required to recycle their own plastic, but will be required to ensure

that an equivalent amount of plastic is being recycled/reused

▻ An instrument called ‘Plastic Credit’ is proposed to be introduced which is will be an

evidence of recycling or recovery

▻ Plastic credit will be issued by accredited processors in exchange of a financial

transaction to producers (or PROs)

▰ Model 3:

▻ Mix of Model 1 +Model 229

OUR RECOMMENDATIONS

▰ Clarity is required on the scope of materials products to be included under EPR. Such schemes practiced in Europe are limited to flexible packaging materials and are aimed towards popular brands with major contribution to Plastic waste. In Indian context, as India is already known to recycle around 60% of plastic waste, such scheme should focus on littered but uncollected plastic waste at least in the initial stages.

▰ Bulk of the Indian producers are in MSME segments. It is view of the industry that small producers processing less than 1000 metric tons of material or having turnover up to 25 crore be excluded from the scheme except for a lump sum annual fee based on total turnover.

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OUR RECOMMENDATIONS

▰ Typical small/ medium processing unit is entrepreneur driven with limited Human Resources and does not have time or resources to focus on additional compliance. If burdened with such additional requirement, the ease of business model will go for a toss and will put question mark to several million workers employed by the segment.

▰ Producers work on small value addition compared to brands and hence contribution computation be strictly in proportion to value addition.

▰ Implementation of EPR is not end by itself and it’s intended object I’ll be served only if requisite functions with adequate capacities like source segregation, separation, collection and subsequent recycling, end of life or waste to fuel options are in place. These we believe are prerequisites.

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OUR RECOMMENDATIONS

▰ The industry feels that ownership of portals and digital exchange should rest with the Government like GST to ensure protection and confidentiality of members data.

▰ Trade bodies and associations be accepted as aggregators for discharging EPR obligations of their members.

▰ EPR scheme should be uniform across India as any anomaly between states will complicate its implementation.

▰ Currently, states like Maharashtra have issued closure notices to many units for not implementing EPR for which there is no guidelines from the Government. It is our request that states should be asked to remove closures and allow those units to function pending finalization of EPR frame work by MOEF.

▰ Clarity is sought on usage of recycled material for non-food contact packaging applications as prescribed in Maharashtra ban notification.

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WHAT CAN WE DO FOR SUSTAINABILITY ?

▰ Drastically reduce leakage of plastics into natural systems (in particular, the ocean) and othernegative externalities by following the rules and managing the waste.

▰ PLASTICS REPLACES PLASTICS

Replacing bad plastics with good plastics

Developing new plastic materials / exploring new options that have similar properties, butstill are easy to collect and recycle.

▰ Zero Waste Programs

▰ Create an effective after-use plastics economy by improving the economics and uptake ofrecycling and reuse.

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THE WAY FORWARD – TURNING VISION INTO REALITY

Improving the economics and quality of plastics recycling

• Improve design and support innovation to make plastics and plastic products

easier to recycle

• Expand and improve the separate collection of plastic waste, to ensure quality

inputs to the recycling industry

• Expand and modernise the collection, sorting and recycling capacity

• Create viable markets for recycled and renewable plastics.

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THE WAY FORWARD

• Curbing plastic waste and littering

• Awareness creation

• Better and more harmonised separate collection and sorting system

• Driving innovation and investment towards circular solutions

• Design for Environment

• Design for Collectability

• Design for Recyclability

CONCLUSION

▰ Plastic waste is global challenge

▰ India has a unorganized recycling structure which need to be upgrades

▻ Issue of littering can be resolved though the EPR funding by adding value to non valued plastics waste

▻ This will create additional income stream for unorganized workers

▰ EPR system is at evolving

▻ It should consider packaging waste not only plastics as in Europe

▻ In plastics the focus should be on Non- valued waste for targeted resource utilization

▻ Existing system should be supplemented

▻ EPR Framework should be supported by single unified digital platform

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