Extended producer responsibility (EPR)

Extended producer responsibility (EPR)

News Analysis   /   Extended producer responsibility (EPR)

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Published on: December 28, 2021

Issue related to Environment Pollution 

Source: The Indian Express


In October, the Environment Ministry published draft regulations on Extended Producer Responsibility (EPR), set to come into effect by the end of this year. Disregarding the commitments made by the Solid Waste Management Rules, 2016; the Plastic Waste Management Rules, 2016; and the Swachh Bharat Mission (SBM), these regulations denote a backslide, particularly with respect to the integration of the informal sector.


Plastic packaging can be roughly grouped into three categories:

  • Recyclable and effectively handled by the informal sector,
  • Technologically recyclable but not economically viable to recycle,
  • Technologically challenging to recycle (or non-recyclable).


 The Concept of Extended Producer responsibility (EPR)

EPR requires the manufacturer of a product or the party that introduces the product into the community, to take responsibility for its life cycle.

An FMCG company should not only account for the costs of making, packing, and distributing a packet of chips, but also for the collection and recycling/reuse of the packet.

Before 2016 rules: EPR was left to the discretion of the local bodies.

Now: Producers and Brand owners have been made responsible for collecting waste generated from their products. They have to approach local bodies for the formulation of a plan/system for plastic waste management within the prescribed timeframe.


Waste segregation & Collection system in India - the backbone of EPR:

For decades, waste pickers, working in dangerous and unsanitary conditions, have picked up what we throw away. In India, producers have externalised these costs due to the presence of a robust informal sector composed of waste pickers.

They form the base of a pyramid that includes scrap dealers, aggregators, and re-processors. This pyramid has internalised the plastic waste management costs of large producers.

Besides, by diverting waste towards recycling and reuse, waste pickers also subsidise local governments responsible for solid waste management.

Further, they reduce the amount of waste accumulating in cities, water bodies and dumpsites and increase recycling and reuse, creating environmental and public health benefits.


Problem with the recently released guidelines:

Rag-pickers not included: It fails to mention waste pickers or outlining mechanisms for their incorporation under EPR.  

Disregard of the existing chain: The SBM Plastic Waste Book attributes India’s high recycling rate to the informal sector. The guidelines don’t involve them as stakeholders in formulating the guidelines, instead, it directs producers to set up a private, parallel plastic waste collection and recycling chain. This contributes up to 60% of their incomes, which will likely be siphoned away from them and channelised into the new chain.

No Social security: Unfortunately, most informal waste pickers remain invisible. Between 1.5 and 4 million waste pickers in India work without social security, health insurance, minimum wages, or basic protective gear.

Limited scope: It is limited to plastic packaging, while a large part of single-use or throwaway plastic packaging are other multi-material plastic items like sanitary pads, chappals, and polyester that pose a huge waste management challenge today, but have been left out of the scope of EPR.

Issue of recycling of contaminated plastics: Typically flexible plastics like LDPE and PP bags are recyclable, but due to their contamination with organic waste, lightweight, and high volume, the costs of recycling are prohibitively expensive relative to the market value of the output. Market value for these plastics can be increased by increasing the demand for and use of recycled plastics in packaging, thus creating the value to accommodate the current costs of recycling.

Multi-layered and multi-material plastics to continue: These are low weight and voluminous, making them expensive to handle and transport. Since they are primarily used in food packaging, they often attract rodents, making storage problematic. Even if this plastic is picked, recycling is technologically challenging as it is heterogeneous material. The Plastic Waste Management Rules mandated the phase-out of these plastics. However, in 2018, this mandate was reversed.

Misunderstood Processing: Not all processing is recycling. Processes like waste-to-energy, co-processing, and incineration have been proven to release carbon dioxide, particulate matter, harmful dioxins, and furans which have negative climate and health impacts.

No case for investment support: Technologies like chemical recycling and pyrolysis are capital-intensive, yielding low returns and running into frequent breakdowns and technological problems. They also release carbon dioxide and other pollutants. GAIA estimated that such technologies wasted at least $2 billion in investments, due to permit complications, operating costs, etc. While the environmental impact and desirability of these processes continue to be debated, the draft regulations legitimise them to justify the continued production of multi-layered plastics.

Way Forward:

Involve ragpickers: An effective EPR framework should address the issue of plastics and plastic waste management in tandem with the existing machinery, minimise duplication and lead to a positive environmental impact, with monitoring mechanisms including penalties for non-compliance. 

Fund and Utilize exiting chains: EPR funds could be deployed for mapping and registration of the informal sector actors, building their capacity, upgrading infrastructure, promoting technology transfer, and creating closed-loop feedback and monitoring mechanisms. For easily recycled plastics, EPR requirements could have been fulfilled by formalising and documenting the work of the informal sector and adequately compensating them.

Government must regulate the job: Without strong government regulation, the millions of workers who have shouldered the burden of waste management for decades will stand to lose their livelihoods – only so that companies can keep meeting their targets to continue producing plastic.

Addressing infrastructure needs: the government could support and strengthen the informal recycling chain by bridging gaps inadequate physical spaces, infrastructure, etc.

The mandated use of recycled plastics, as prescribed in the draft regulations, is a strong policy mechanism to create this value.


The government should redo the consultation process for the draft guidelines and involve informal workers. The scope of plastics covered by the guidelines could be altered to exclude those plastics which are already efficiently recycled and to include other plastic and multi-material items. And end-of-life processing technologies should be closely evaluated, based not only on their health and environmental impacts but also on the implications for the continued production of low-quality and multi-layered plastics.

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