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Tackling plastic waste? Govt of India 'allows' industry to continue business as usual

By Roshan Rai, Priyadarshinee Shrestha*

There has been an ever mounting concern on the issue of plastic pollution, globally and within the country. The understanding that solutions to the plastic crisis need urgent focus more at the source -- where plastic is being produced -- rather than at manager and consumer level or post disposal has been clearly established and widely acknowledged.
Studies that have highlighted that 6.3 billion metric tonnes of plastic waste generated from the 8.3 billion metric tonnes of plastics ever produced with only 9% being recycled (Geyer et al 2017) have been a wakeup call that clearly debunk recycling as a solution out of this plastic crisis.
Amidst all this, the draft notification on Extended Producer Responsibility (EPR) under the Plastic Waste Management Rules 2016 by the Ministry of Environment Forests and Climate Change, Govrnment of India (GoI), is a welcome step. However, it needs to be seen if the proposed solutions are real and effective, and how actual implementation of the rules would be carried out.
EPR as a concept is a much needed narrative change in addressing both the waste crisis, and our understanding of what Swachh and Swachhata mean. It is responsive to the plastic pollution crisis and an acknowledgement of the materiality of plastic as something that does not go away.
EPR demands for companies primarily to design better and to take responsibility for their products after they are used and not leave it on consumers and local bodies to manage the waste generated. Likewise, it challenges them to reduce material use -- plastic in this case -- and not create more waste.
Given these principles, the EPR framework in India has evolved over time after its first appearance in the Plastic Waste Management Rules in 2016. This was followed by a 2020 draft, and most recently, the 2021 draft which is now open for comments from the public.
One of the main gaps in the 2020 EPR framework was the complete absence of tackling plastic waste through design solutions as part of producer responsibility. It was suggestive that extended producer responsibility came into effect only post creation of the product.
The geographical neutrality of the rules also meant hard to service areas, such as mountainous regions received little focus from companies. This made EPR feasible only in large urban conglomerations, due to the volume of plastic waste generated.
While the 2021 draft appears improved, it still suffers from several hangovers of centralisation and limited inclusion of local institutions that manage waste on a daily basis.
The document defines EPR to be “the responsibility of a producer for the environmentally sound management of the product until the end of its life.” The rules are clear and binding when they says, “The rules cast EPR on Producer, Importer, Brand Owner for collection and recycling of plastic packaging waste. EPR shall be applicable to both pre-consumer and post-consumer plastic packaging waste.” They also provide a framework for implementation making it an applicable guideline.

The multilayered dilemma

One of the things that stood out in the Plastic Waste Management Rules of 2016 was the clause that specified ‘phasing out of multilayered plastics (MLPs) in 2 years’. MLPs refer to “at least one layer of plastic and at least one layer of material other than plastic”.
They are non-recyclable and therefore never picked up by the recyclers. However, just when the 2 years were coming to a close, the rules were amended to specify that only those MLPs would be phased out which were non-recyclable, or non-energy recoverable, or with no alternate use, thereby providing an easy escape for production of this problematic plastic to carry on unabated.
MLPs top the list of plastics that are currently being produced and disposed of. The Pan India Brand Audit 2021 showed 35% of plastic found in waste to be MLP. The Himalayan Cleanup from Home 2021 revealed that 85% of waste audited to be plastic and 71.8% to be non-recyclable, mostly multilayered plastic.
Wherever feasible, urban local bodies pay for transportation of these materials to waste-to-energy and cement plants, falsely proclaimed to be “energy recovery”, but in fact is simply burning. In most mountain cities and towns that have none of these facilities, MLP is the main volume of waste that leads to overfilled landfills and dumping sites or clog streams and rivers, and thus needs to be designed out of the system.
The current EPR framework however continues with the false solution narrative of “end of life disposal” of MLPs by burning through co-processing, waste to energy or plastic roads. Burning waste, especially plastic discards, can only generate small amounts of energy while emitting more carbon dioxide than coal fired plants for the same amount of electricity generated thus contributing to the climate crisis.
According to the UN Environment, burning a tonne of municipal waste releases nearly 1.1 tonnes of carbon dioxide into the atmosphere . On top of these emissions, incinerators also pose health and environment risks in nearby communities, through fly ash residues that are contaminated with heavy metals, dioxins, and other persistent organic pollutants.Thus burning of MLPs is not a real solution. It just shifts the problem away from our visual narrative and continues to harm our well being.
Plastic road laying has become extremely popular in India as well as globally catching the imagination of all as a quick fix solution. But promoters of plastic road laying do not critically examine the complete cycle of plastic pollution from its toxic extraction, production and consumption perspectives. It highlights the improved qualities of these roads while underplaying the potential harm of toxicity, leaching into the soil, and microplastic contamination.
The Recycling Myth, Big Oils solution for plastic waste littered with failure”, a Reuters Special Report of July 2021, highlights numerous failures of technologies like pyrolysis and conversion of plastic waste into oil including in India. This is further reiterated by the Break Free from Plastic 2021 report "Plastic Missing the Mark, Unveiling corporate false solutions for the plastic pollution crisis". The existing EPR document does not learn from these failures but continues to walk this path of failure, a path that is toxic for us and our planetary health.
The EPR framework does not put out real solutions by designing out waste, especially MLPs, with clear timelines and targets. It still follows an end of the pipeline intervention logic that does not really solve the problem but merely shifts it.
In its existing format the Govt of India has missed the opportunity to truly address the issue of plastic pollution at a systemic level 
Sustainable packaging finds a mention in one of the clauses, but a lot is left unsaid and hanging for a later time when it will be ‘prepared by CPCB, inter alia based on the following criteria (i) package designing promoting reuse, (ii) package designing amenable for recycling, (iii) recycled plastic content in plastic packaging material and (iv) package designing for environment.’
On the other hand, the EPR framework incentivises biodegradable plastics through a specific clause that relieve PIBOs of their EPR targets if they, “utilizes plastic packaging which is 100% biodegradable in the ambient environment leaving no traces of micro plastics/chemical residue/any other traces having adverse environmental and health impacts as certified by regulatory entities CPCB, BIS, CIPET”. But it is not binding on companies to work towards this goal. One must note that biodegradable plastic is controversial and still promotes single use lifestyles.

Mountain of an issue

From the earlier version where there were no geographical targets specified, the new version has made a leap in the right direction by bringing in targets for companies that are also state specific. There definitely needs more clarity on how these targets would be finalised so that no states are left behind.
There is also room to bring in more emphasis to implement EPR in challenging and critical geographies like the mountains, given their ecological significance that provide services for peoples far beyond their boundaries. In this regard, trading and purchasing of targets between PIBOs could weaken the focus that mountain states need.
EPR as a lens offers a dramatic shift in narrative that could potentially resolve the plastic waste crisis with designing out waste from the system. This is not a far-fetched idea as many of the top polluting companies at the global level in different geo-political environments are already undertaking design actions that remove problematic materials. 
Yet in the existing framework, these same companies are being encouraged to keep business as usual with the clause of “end of life disposal”. Neither have they been encouraged nor taken to task to invest in research and design or leverage their global knowledge that phases out problematic materials like MLP.
In its existing format the EPR document misses the opportunity to truly address the issue of plastic pollution at a systemic level and merely shifts the problem by looking at it from the end of the pipeline management issue only. It enables industry to continue business as usual and fails to be a visionary document that closes the tap on plastic pollution.
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*Roshan Rai works with DLR Prerna, a Darjeeling based NGO; Priyadarshinee Shreshta works with WWF India, Kanchenjunga Landscape. Both are members of the Zero Waste Himalaya family

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