Skip to main content

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.
---
*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

Comments

Anonymous said…
thanks
Anonymous said…
thnks

TRENDING

Reducing emission? India among top nations whose coal as energy source going up

By NS Venkataraman*  The State of the Global Climate report by the World Meteorological Organization (WMO) confirmed that the year 2023 was the warmest year on record, with the global temperature of 1.4 degree celsius above pre-industrial 1850-1900 base line.

Lockdown 'total failure' of science more than of politics: Open letter on 4th anniversary

Counterview Desk  In an open letter to fellow academicians, scientists and medical practitioners in India, marking the fourth anniversary of India's lockdown (25 March 2024), the Managing Committee* of the Universal Health Organisation (UHO) has insisted on the need to "repair two years of immense damage to science".

Insider plot to kill Deendayal Upadhyay? What RSS pracharak Balraj Madhok said

By Shamsul Islam*  Balraj Madhok's died on May 2, 2016 ending an era of old guards of Hindutva politics. A senior RSS pracharak till his death was paid handsome tributes by the RSS leaders including PM Modi, himself a senior pracharak, for being a "stalwart leader of Jan Sangh. Balraj Madhok ji's ideological commitment was strong and clarity of thought immense. He was selflessly devoted to the nation and society. I had the good fortune of interacting with Balraj Madhok ji on many occasions". The RSS also issued a formal condolence message signed by the Supremo Mohan Bhagwat on behalf of all swayamsevaks, referring to his contribution of commitment to nation and society. He was a leading RSS pracharak on whom his organization relied for initiating prominent Hindutva projects. But today nobody in the RSS-BJP top hierarchy remembers/talks about Madhok as he was an insider chronicler of the immense degeneration which was spreading as an epidemic in the high echelons of th

Magnetic, stunning, Protima Bedi 'exposed' malice of sexual repression in society

By Harsh Thakor*  Protima Bedi was born to a baniya businessman and a Bengali mother as Protima Gupta in Delhi in 1949. Her father was a small-time trader, who was thrown out of his family for marrying a dark Bengali women. The theme of her early life was to rebel against traditional bondage. It was extraordinary how Protima underwent a metamorphosis from a conventional convent-educated girl into a freak. On October 12th was her 75th birthday; earlier this year, on August 18th it was her 25th death anniversary.

Savarkar 'criminally betrayed' Netaji and his INA by siding with the British rulers

By Shamsul Islam* RSS-BJP rulers of India have been trying to show off as great fans of Netaji. But Indians must know what role ideological parents of today's RSS/BJP played against Netaji and Indian National Army (INA). The Hindu Mahasabha and RSS which always had prominent lawyers on their rolls made no attempt to defend the INA accused at Red Fort trials.

'Wrong direction': Paris NGO regrets MNC ArcelorMittal still using coal-based steel

By Rajiv Shah  A new report by Paris-based non-governmental research and campaigning organization, Reclaim Finance, has blamed the MNC ArcelorMittal – formed in 2006 following the takeover and merger of the western European steel maker Arcelor (Spain, France, and Luxembourg) by Indian-owned Mittal Steel – for using use “climate destructive” metallurgical coal for its projects in India.

'Flawed' argument: Gandhi had minimal role, naval mutinies alone led to Independence

Counterview Desk Reacting to a Counterview  story , "Rewiring history? Bose, not Gandhi, was real Father of Nation: British PM Attlee 'cited'" (January 26, 2016), an avid reader has forwarded  reaction  in the form of a  link , which carries the article "Did Atlee say Gandhi had minimal role in Independence? #FactCheck", published in the site satyagrahis.in. The satyagraha.in article seeks to debunk the view, reported in the Counterview story, taken by retired army officer GD Bakshi in his book, “Bose: An Indian Samurai”, which claims that Gandhiji had a minimal role to play in India's freedom struggle, and that it was Netaji who played the crucial role. We reproduce the satyagraha.in article here. Text: Nowadays it is said by many MK Gandhi critics that Clement Atlee made a statement in which he said Gandhi has ‘minimal’ role in India's independence and gave credit to naval mutinies and with this statement, they concluded the whole freedom struggle.

A Hindu alternative to Valentine's Day? 'Shiv-Parvati was first love marriage in Universe'

By Rajiv Shah*   The other day, I was searching on Google a quote on Maha Shivratri which I wanted to send to someone, a confirmed Shiv Bhakt, quite close to me -- with an underlying message to act positively instead of being negative. On top of the search, I chanced upon an article in, imagine!, a Nashik Corporation site which offered me something very unusual. 

Attack on foreign students: Gujarat varsity's reputation, ranking at stake, say academics

Counterview Desk  Expressing anguish over the attack on international students in Gujarat University hostels, a letter claimed to have been signed by 122 current and former academics has asked the Gujarat Vice Chancellor, Dr Neerja Gupta, to provide emotional support to the attacked students and to ensure their physical safety.  

As double engine takes backseat in Odisha, BJP is pitted against 'firmly rooted' BJD

By Sudhansu R Das  BJP has got 25 years to build its party base in Odisha. After 25 years, it felt helpless and insecure to fight elections on its own strength. The party was almost crazy to have an alliance with the ruling BJD in Odisha.  Looking for alliance at the time of election shows that the party has not groomed its grassroots level workers into potential leaders.  The state BJP leaders woke up and convinced the Central leaders that they are capable of going solo; the alliance was stillborn. The question is can BJP defeat BJD which is firmly rooted in Odisha after launching piles of populist programs in the state.