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Extended Producer Responsibility (EPR) Guidelines
Context:
The recent report by the Centre for Science and Environment (CSE) underscores critical gaps in the Indian government’s EPR guidelines for plastic waste management.
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Initially introduced in February 2022. While these guidelines aimed to enforce the “polluter pays” principle, the report indicates that they require stronger enforcement and accountability to achieve their intended goals.
 The “polluter pays” principle was first introduced by the Organisation of Economic Cooperation and Development (OECD) in 1972. A fundamental concept in environmental policy asserts that those who produce pollution should bear the costs associated with managing it to prevent damage to human health and the environment. |
Overview of EPR Guidelines:
- The EPR guidelines were issued by the Union Ministry of Environment, Forest and Climate Change (MoEFCC) on February 16, 2022.
- It is a policy framework that holds producers accountable for the entire lifecycle of their products, especially concerning waste management after consumer use.
- Registration Requirement: EPR requires manufacturers, producers, importers, and brand owners (PIBOs), as well as plastic waste processors, to register on a centralised portal.
- Targets include collection, recycling, end-of-life handling, recycled content usage, and selective reuse in plastic packaging.
- This approach aims to promote environmental sustainability by encouraging manufacturers to design products with recycling and waste reduction in mind.
Current Challenges in the EPR Ecosystem:
- Low Enrollment of Major Polluters: The report highlights that major plastic polluters have low enrollment in the EPR system:
- Total Registrations: 41,577, with 83% being importers, 11% producers, and 6% brand owners.
- Plastic Introduction: Producers account for 65% of plastic packaging, while brand owners contribute 26% and importers only 9%.
- Fraudulent Activities: The Central Pollution Control Board (CPCB) reported 700,000 fake certificates generated by recyclers, 38 times the legitimate capacity.
- CPCB has imposed ₹355 crore in fines for violations.
- Processing Discrepancies: Significant differences were found between reported plastic processing amounts and actual capacities.
- For instance, units claimed to process 335.4 million tonnes annually, while their capacity is only 11.4 million tonnes.
- Underreported Waste Generation: PIBOs introduced 23.9 million tonnes of plastic packaging since the EPR portal launch, indicating an annual waste generation of about 8 million tonnes—higher than CPCB’s estimation of 4.1 million tonnes.
- Lack of Representation: Key contributors like urban local bodies and informal waste collectors are excluded from the EPR framework, burdening local governments.
Recommendations for Improvement:
- Inclusion of Informal Sector: Recognising and integrating informal waste management sectors can enhance the traceability of the plastic waste value chain.
- Elimination of Fraud: Stronger measures are needed to combat fraudulent practices within the certification and recycling processes.
- Accurate Reporting: The use of the EPR portal should be improved to ensure accurate reporting of plastic waste generation.
- Benchmarking and Pricing: Conducting baseline studies for plastic waste management can help establish fair pricing for recycling certificates, thus preventing market undervaluation.
- Standardisation of Products: Implementing standardisation in packaging materials can improve recyclability and streamline waste management processes.
Future Outlook:
- There is potential for corrective measures, as the EPR guidelines are set to be implemented until the fiscal year 2027-28.
- Addressing the identified gaps can strengthen the “polluter pays” principle in India’s plastic waste management efforts.
