Challenges in EPR

Looking back at four years of producers taking responsibility for waste generation in India- where do we stumble?

Post the industrial revolution, the population of the world has multiplied dramatically.  The increase in average Disposable Personal Income (DPI) (Breaking the link between economic growth and waste generation)has been observed to be proportional to the increasing amount of waste.  To handle the excessive waste different initiatives have been undertaken, one of which is the introduction of incentive-based policies. Seen as a way of correcting market failure in a cost-effective manner, incentive-based approaches include pollution (Pigovian) taxes, tradable credits, deposit-refund systems/ liability requirements and Extended producer responsibility (EPR).

Extended Producer Responsibility (EPR) is increasingly recognised worldwide as an efficient waste management policy to help improve recycling and reduce landfilling of products and materials. The mandate of EPR is that producers assume responsibility for managing the waste generated by their products introduced in the market. On the other hand, under an EPR scheme producers are incentivised to maximise the material benefits from their products throughout the value chain.

EPR according to the OECD journal, “The State of Play on Extended Producer Responsibility (EPR): Opportunities and Challenges” has succeeded in the EU region and is widely recommended in other countries also. But these policies are facing hardships in the African and Asian countries due to varied reasons.

In accordance with the polluter’s pay principle, EPR was first coined by  Thomas Lindhqvist (Concepts of EPR) in 1990 and was first instituted in Germany in 1991 to avoid packaging waste. This long-running and established responsibility was officially introduced in India in‘plastic waste management rules-2016’. 

What ails EPR?

EPR for every industry includes a chain of responsibilities assigned to each stakeholder. An EPR will only be successful when each stakeholder understands it’s responsibility and acts according to the guidelines. There are numerous issues that ail the process which begins with understanding of the process, regulations, responsibilities, ways of compliance, documentation and maintenance of transparency. Communication is also one of the major issues that are encountered by both ends, the government as well as the stakeholders.

Regulation Issue:

The guidelines have shown a gradual progression towards clarity. In the amendments, there has been an attempt to include and address the concerns of all stakeholders. However, a lot more work needs to be done with respect to defining the scope, inclusion of products, timelines and the targets.

It has been observed that the stakeholders find it difficult to understand and decode their individual responsibility in the entire juggle of EPR.

For example, a stakeholder like a pharmaceutical company which technically lies in the ambit of EPR remains unaware of its EPR responsibility even after going through the government documents. The same has been observed for numerous industry participants like the Agro-industry, the online food delivery industry etc.

Institutional Issues:

The institution problem starts with the inability to identify the list of producers of branded, unbranded and orphaned products and also traders and importers. This list helps in mandating the EPR and ensuring compliance.

Lack of accurate figures for rapidly increasing waste volumes generated domestically and by imports from other countries also render it difficult to enforce the rules properly.

Lack of adequate staff to design, monitor and communicate EPR activities is resulting in poor implementation of EPR.

Insufficient effort to train and build capacities of existing staff for effective implementation of EPR has resulted in institutions acting as per one’ understanding instead of in cohesion.

Documentation Difficulties:

Documentation is the proof of the EPR activity performance. The companies find it difficult to understand the procedure and the sequence of documentation.

Technology Bottlenecks:

Current technologies applied at the collection centres are hardly enough to hold the increasing amounts of waste generated by the cities. Inadequate infrastructure, distance and connectivity to the recycling centres make it difficult to process all the waste that comes in.

The informal waste economy is not yet formalised and hence remain unseen and non-inclusive.

The recycle mechanisms that are used here, in India are still in their initial development stage and are in-efficient to handle and process large amounts of waste at a time. Further, they are not designed to recycle MLPs effectively. The PET recycling infrastructure needs to upgrade to be comparable to some European countries. There are grey areas with the technology imports from other countries in relation to the rules, political will and awareness.

EPR in India is looking ahead at a long winding road with severe bumps to overcome. Let’s hope a proper structured operational process flow for the entire EPR regime will follow soon.