Nalini Shekar and Kabir Arora
A decade ago, the term ‘Extended Producer Responsibility’ (EPR) was either found in the textbooks of Environment Sciences or in the forgotten reports of many parliamentary committees. At that time as organisers of waste pickers and environmentalists, whenever we emphasised that the producers must pay for recycling or disposal of packaging material, we were ridiculed and mocked. People considered it an alien concept and difficult to implement in India.
Fast forward to 2021, and the National Green Tribunal has ordered the Union Ministry of Environment, Forest and Climate Change (MoEFCC) to frame guidelines for EPR. This is in response to the increasing public and international pressure to reduce plastic pollution and for resolving the crisis of waste management. Due to the increased spotlight on plastic pollution, a lot of large Fast Moving Consumer Goods (FMCGs) companies are announcing plastic waste reduction targets. To take it forward, a few of them have post-production plastic recycling and disposal systems in place, as it is easier to collect and is mostly homogenous material. The real test for any EPR system is post-consumer plastic waste. Some plastic waste streams like PET Bottles, HDPE (water drain pipes, plastic jugs and jerry cans, chairs and tables) have functional and diverse recycling value chains. They do not pose a major challenge. It is the plastic material that brings in zero value i.e. non-recyclable multi-layered plastic packaging of chips and other edibles and shampoo and other toiletries’ packaging, which is the biggest cause of concern. The given material is being collected and aggregated by many facilities operated by waste pickers organisations in cities like Bengaluru, Mumbai, Delhi, Pune and others. No buyer is coming forward. The only available options (not the most eco-friendly or economically viable options) are to send it to cement kilns, where they use the given material as fuel for co-processing or for the construction of the roads.
Some companies like Tetrapak, HUL and ITC have taken initiatives to set up systems for collection, recycling or disposal of post-consumer plastic. Most of these systems are voluntary and are at a nascent scale. India’s plastic waste problem is the size of the Antarctic Blue Whale (the largest mammal on the planet) and the given solutions are the size of an ant. We are not saying that this problem is so big that it cannot be solved, rather than the existing solutions are too small to bring any meaningful change.
In plastic waste management, the biggest problem in front of us is post-consumer non-recyclable and multi-layered plastic (including reject waste like diapers and sanitary pads), which has no takers in the market. Most of the FMCG companies are not in the business of plastic waste recycling and disposal. Considering the requirement of commitment and scale of operation, it will be very difficult for them to enter into the recycling business. In other words, they will be dependent on ‘external agencies to provide them with this support. There is no better ally and partner than waste pickers’ organisations and informal waste recycling businesses, which already have expertise in this area.
India is home to the world’s largest recycling industry. To illustrate the scale of recycling in India, we are taking the example of Bengaluru city. On average, 3500 Metric Tons of plastic waste are traded every day. A significant part of this material is not even accounted for in the official estimates of waste generation in Bengaluru, and it is picked up by an army of unknown environmental warriors, waste pickers, sold to scrap dealers and from there to aggregators and at last to re-processors. There are around 95,000 workers in the informal waste recycling sector and a substantial number of them are women.
Waste pickers and other informal recyclers are subsidising the environmental mandate of the producers, consumers and the government. They are providing an important service and yet paid meagrely. Recognising their contribution and strength, both Solid & Plastic Waste Management Rules 2016 mandated their integration. The Bengaluru municipal authorities have involved waste pickers and other informal waste collectors in the door to door collection of dry waste (recyclable and non-recyclable inert waste) and operations of Dry Waste Collection Centres (waste sorting and aggregating facility set up at the municipal ward level). Many other corporations have instituted similar measures. The integration of waste pickers is an ongoing process and is complementing the existing low-cost informal waste recycling chain, providing important solutions, but existing in secrecy.
Most of the existing informal and formal recycling units- homes of waste-pickers used as personal sorting places, Dry Waste Collection Centres, Material Recovery Facilities, Scrap Shops, Aggregation Centres, Waste Material Godowns and Small Recycling factories- are functioning out of crumbling infrastructure, have less than fair remuneration and no safety net for the workers. The strength of the given system is its skilled work-force and ability to collect, sort and aggregate large amounts of plastic material in a short span of time.
Any proposed EPR system should be considerate of these realities and actors and push for their inclusion. Waste pickers and the informal waste recycling sector (with near to no physical infrastructure) at large contributes to the visual cleanliness of the city, safeguards the environment and provides jobs to the most marginalised. Thanks to the Swachh Bharat Abhiyaan and organising work done by many organisers, many cities have (like our own Bengaluru) waste- pickers organisations, self-help groups and cooperatives in place. Some of our ally waste pickers organisations are undertaking large scale operations of collection and aggregation of various streams of waste. Some of us, including Hasiru Dala, has also partnered with a few FMCG companies for piloting and innovating EPR systems. All these actions are voluntary and are being undertaken as a goodwill gesture by the companies. Voluntary systems do not last long. This is why there is a push for a mandatory EPR system at the national level.
It is high time that those who are engaged in informal waste recycling for survival are recognised as entrepreneurs and supported through the proposed mandatory EPR system. There are few primary needs that require support through the EPR system. The current system of recycling may seem opaque to the eyes of outsiders, especially those in the large FMCG companies. The most important requirement of the EPR system is going to be transparency and traceability. FMCG companies are formulating targets and they would like to see results against their commitment. Transparency and traceability of material flow are important to ensure that there is double accounting of the costs and materials sent for recycling and for avoiding leakage of material within the system. Opaque informal recycling systems and transparency seem to be distant twains, but they need to meet.
The regulatory regimes of labour, taxation, urban planning and pollution control have always scared informal recycling entrepreneurs, thanks to them, most of the informal recycling enterprises function under the constant fear of displacement and eviction. Therefore, they prefer to work in hiding. If they are to be included in the EPR framework, they should be able to stop fearing the regulatory system. We as waste pickers organisations can help in that. We organise waste pickers and informal waste collectors for livelihood and social protection. We have networks in the informal recycling supply chains. We can be that bridge that can connect the informal waste recycling sector with the FMCG companies.
To be a bridge, the first thing we ask for is the seat on the table (as equals) where the nitty-gritty of the EPR system is discussed and decided. The second is capacity building and infrastructure upgradation. An EPR system needs elements of transparency and traceability in place. This will be a common expectation of any prospective FMCG company that is seeking to partner with waste pickers organisations and through them connecting with the informal waste supply chains. As a part of EPR, we would like the financial and intellectual investments to be made in training sessions for waste pickers organisations and other actors in informal waste supply chains on ways to bring in elements of transparency and traceability as well as an understanding of regulatory regimes to make the lives of informal enterprises easy. One of the major strengths of waste-pickers organizations is undertaking frequent training sessions and workshops on a large scale. Thanks to the emphasis on organizing and skill-up-gradation for better vocation, many waste-pickers have developed an innovative methodology for the facilitation of workshops and training. Recognizing our strength in training and facilitation of workshops, various government bodies and consortiums of private actors including think tanks have regularly approached us for training officials of urban and rural local bodies’ officers and other workers in waste management facilities. A financial and intellectual investment in existing training systems of waste-pickers organizations can create spaces for collaboration and innovation.
The current infrastructure for recycling including the units operated by waste-pickers organizations is rudimentary and dilapidated. It requires up-gradation of technology as well as physical infrastructure. An investment in the infrastructure of recycling in consultation with waste-pickers organizations and other actors in the informal recycling sector is needed. Waste management including plastic waste management is a domain of urban and rural local bodies, their participation in decision making for investments in the sector is a must.
The third and the most important expectation is to focus on post-consumer non-recyclable material and fair remuneration for its collection, aggregation and transportation. Most streams of plastic waste materials have some or other form of recycling going on, even though one cannot be sure of fair remuneration. What we as waste pickers organisations seek is that we start with collection, aggregation and recycling of post-consumer non-recyclable material and set up standards of fair remuneration. If we are able to set up fair standards of engagement with the waste pickers organisations, it will boost the confidence of the informal waste recycling sector at large and pursue them to join the system.
All three requirements: representation and consultation, capacity building and infrastructure up-gradation, and fair remuneration, have emerged from long deliberations undertaken by the waste pickers organisations and other actors in the informal recycling supply chains. If these three basic requirements are satisfied, then India will have an outstanding EPR model.
Nalini Shekar is the co-founder of Hasiru Dala, Bengaluru based waste pickers organisation. Kabir Arora is the national coordinator of the Alliance of Indian Waste-pickers, a network of waste pickers organisations.