New Epr Framework For Plastic Waste Management

The Ministry of Environment, Forest and Climate Change has issued a Guideline Document for the “Uniform Framework for Extended Producers Responsibilit” under the provisions of the Plastic Waste Management Rules, 2016.

Salient Features of the Guideline

Introduction of a system of plastic credit, establishing Producer Responsibility Organisations (PROs) and setting up a fee-based mechanism are three different models which will be available to producers of plastic products, including FMCG companies, under this framework.

1. Plastic Credit Model: A plastic credit model is envisaged where a producer is not required to recycle their own packaging, but to ensure that an equivalent amount of packaging waste has been recovered and recycled to meet their obligation.
2. PRO Model: Under the PRO model, an organisation will manage the waste on behalf of producers. Municipal bodies can also register as PRO or waste collector. There will be a national authority - National PRO Advisory Committee - to govern plastic waste management in the country.
3. Fee-based Model: Under the ‘fee-based model’, the framework proposed that the producers will con- tribute to the EPR corpus fund at the central level. This may be an escrow account, managed by Special Purpose Vehicle (SPV), where private and other stakeholders can become members. The amount to be contributed by each of the producers will be calculated based on generation of plastic waste vis-a-yis efforts required and money spent by urban local bodies to handle the plastic part of the waste.

• The proposed uniform Extended Producers Responsibility (EPR) framework, also has provisions to impose penalties on producers if they fail to meet their targeted collection. This money will be used for creating infrastructure for plastic waste management.
• The Framework will be based on creation of national registration and database repository through which all the registration of various stakeholders will be done online.
• A single national registry will be created to enlist all stakeholders. It will improve monitoring and help bring transparency in the plastic waste management system in the country where 40% of its daily waste remains uncollected, posing a threat to environmental and human health.
• Further, the stakeholders need to timely update the requisite information in the database for proper functioning.
• The monitoring of the entire mechanism of the EPR will be the responsibility of the Central Pollution Control Board (CPCB).
• A graded approach for achieving the targets will be recommended, starting with 30% in the first year and moving up to 90% in five years.

Criticism

• A good EPR framework is one which has a lower regulatory cost and higher investments in waste management. In its current form, it is too cumbersome and un-implementable, and will not deliver the desired results.
• The draft framework is putting a disproportionately high regulatory cost on companies which will be untenable in long run. Therefore, the proposed framework, though much needed, needs serious revision.

Way Forward

• Environmental experts say the Plastic Waste Management Rules 2016 do not lay down any enforceable EPR guidelines which is imperative for its operationalisation. The sooner we have the guidelines the better or else the pollution will keep increasing unabatedly.
• The stakeholders, including producers and domain experts and the environment ministryshouldcome out with the final framework after ameliorating the concerns of business group.
• The framework should have a balanced and judicious approach to ensure the legitimate interest of all stakeholders.
• It should be simple and have objective criteriato thwart any arm-twisting or plugging the loopholes for comiptions.
• Finally, EPR must have credible targets to curtail the pollution and be accounted for at the national level without any hinderance.