Extended Producer Responsibility or EPR, aims to make producers or generators of plastic, more responsible w.r.t. the production of plastic (up-stream process) and product life cycle through a waste management infrastructure. It was first introduced in India in 2012, for e-waste/electronic waste. EPR challenges with implementation in India are many given the volume of waste and the expanse of the country.
The work done by Central Pollution Control Board (CPCB) on the EPR implementation has been commendable. However, the mammoth task of trying to align the entire nation into the EPR scheme is no less than a challenge. The guidelines and regulations have not clearly defined:
- Role & Responsibilities of Producers, Importers & Brand Owners (PIBOs)
- EPR implementation across the country, since many regions have contrasting landscapes and hierarchy of waste management
In addition to this, the policy makers are faced with a challenge of carefully monitoring and evolving the rules/guidelines to overcome loopholes.
Too many players
Dialogue with stakeholders must be continuous and their roles in the system must be evolving – As stated by Dr Marco Buletti, Federal Office for the Environment (FOEN) from Switzerland. Unclear, and overlapping responsibilities of stakeholders in the system, will create a widespread confusion across the hierarchy of the system.
The amount of waste being generated in India is not accurately measured, thereby creating added EPR challenges. Thus, giving rise to other obstacles with regards to administration, infrastructure, policies and others. For instance, with regards to e-waste:
- There is little data on the type of e-waste generated and being imported into the country
- Lack of waste inventory with the State Pollution Control Boards (SPCBs) and Urban Local Bodies (ULBs)
- Flow of e-waste is unknown
From the implementation perspective, the biggest challenge would be monitoring the data provided by PIBOs, PROs and other stakeholders. The National registry created by CPCB is a positive step, however the accuracy and reliability of the data will be a difficult task to validate.
Lack of enforcement means
In a country as large and populated as India, there is are obvious challenges with EPR monitoring and implementation. Along with monitoring, enforcing the rules, sanctions and control is a task. Despite creating a strong stringent implementation and monitoring system, there is a possibility of non-compliance from stakeholders. Ultimately, a collective participation by stakeholders will ensure the EPR is effectively implemented.
Informal sector manages more than 90% of the waste
EPR implementation will be inefficient if the informal sector is not duly recognised and formalised. Besides being largely under-utilised, the sector has a great potential to be included into the system. There are about 2.5-4,00,000 waste collectors in India, with 1-2% of the urban population playing an active role in the recycling sector.
Aligning this sector with the mainstream waste generators, and recyclers. Consequently, there is a need for the sector to work in tandem with the latest technological developments in waste management.
Implementation EPR Challenges
Type & Segregation of waste
Lack of awareness among consumers on the nature of waste. For instance, e-waste is toxic to the environment if not disposed of consciously.
Lack of segregation at source poses a severe challenge to local authorities, burdens the waste collectors for segregation. Along with the above, poor segregation will hinder the efforts by PIBOs in implementing their EPR related programs.
The informal sector recycles the majority of the waste being generated, despite having poor infrastructure. On the other hand, the waste disposal, collection, processing, and recycling facilities in every ULBs is understaffed and lack proper infrastructure. Additionally, there is a possibility of waste leakages in the system due to inadequate infrastructure.
“Poor logistics which are complicated by the geographic variations” – Deepali Sinha Khetriwal
The awareness created by ULBs and brands on effective waste management is not translating into actions by consumers.
Gaps in the system
There is a significant gap between the recycler, aggregator, and waste generator. The gaps exist between the government authorities and the PIBOs in the jurisdiction as well. To streamline and channel the waste effectively, there is an urgent need to digitize waste management in India.
Challenges for PROs
From a PRO perspective, roles and responsibilities can be delineated between the different stakeholders, including national and local authorities, PIBOs, Recyclers, PROs, consumers and, the informal sector.
Implementation of EPR in the European Union highlighted some important points. Thus, giving insight into the challenges in India from a PRO perspective:
- A clear understanding of the Guidelines and Regulations
- Collaboration with local authorities in implementing a waste management system
- Developing efficient, transparent, traceable, and reliable data for assessing, and monitoring the effectiveness of the scheme
- Free-riding, wherein PIBOs do not provide accurate data on their products, leads to ambiguities in the data collected and waste processed
In order to overcome this challenge, Austria introduced a 2-tier audit system, which ensured utmost transparency in data collection and monitoring. The system audited the PROs, who in-turn were responsible to audit the PIBOs.
Finally, the mentioned EPR challenges are generalized to the entire nation. What are the solutions?
- Rigorous data collection and monitoring
- Digitization of the process
- Active and voluntary participation by key stakeholders. Such as Producers, Brands, Importers, Recyclers, PROs, Government Authorities, and others.
- Finally, the implementation process must evolve and be flexible.
Recykal is a registered PRO that uses its digital waste management platform to manage plastic and e-waste in India. With a growing network of Brands, Recyclers, Aggregators, and Local Waste Pickers – our EPR Loop will make you a part of this umbrella network ‘Digitally’.
We promise utmost transparency and traceability!