The Ministry of Environment, Forest and Climate Change (MoEFCC), Government of India (GoI) released a draft National Resource Efficiency Policy on 23 July 2019 inviting public comments from various stakeholders. The official memorandum of the policy says that it seeks to address issues related to resource efficiency, promoting the use of secondary raw materials and upcycling of the wastes generated across all the sectors contributing to the economic growth of the nation. This is to ensure a balance between environmental well being and economic growth.
The policy comes at a time when the Indian recycling standards are way below the international benchmarks. As per CPCB, plastic waste accounts for about 8% of the total solid waste generated in India but only 60% of plastic waste is recycled. CPCB also shares that in the year 2014-15, around 91% solid waste was collected out of which only 27% was treated and the remaining 73% ended up in the landfills. Moreover, India represents an exorbitant resource extraction rate. The world average stands at 450 tonnes/acre, while the Indian rate is 1580 tonnes/acre i.e. almost 3.5 times more than the global mark. The policy is aimed at reducing the import dependency of India for various minerals like crude oil which currently stands at 80%, 90% for aluminum and 50% to 60% for copper.
What does the draft say?
The policy takes note of the fact that upsurge in economic growth and consumerism has resulted in the generation of large quantities of wastes across various manufacturing and industrial sectors contributing to the growth of the national economy. Enhancing resource efficiency and promoting the use of secondary raw materials remains the core focus of the policy. It aims to realize the balance between environmental well being and economic growth of the nation.
The policy proposes to set up a National Resource Efficiency Authority (NREA) which will derive its regulatory power from the Environment (Protection) Act 1986. The policy also proposes to create an inter-ministerial National Resource Efficiency Board (NREAB). Both the bodies will be largely responsible for coordinating among the ministries and state governments to implement the policy for resource efficiency nationwide and promote the upcycling of wastes across all sectors of the economy.
The policy includes the following resources: water, land and soil, air, fossil fuels, non-metallic minerals, metals and biomass. The policy has also defined the mandates for government agencies, manufacturers and service providers, consumers, civil society organizations, recyclers and academia. The draft discusses a number of policy instruments which could be executed to promote resource efficiency across all the manufacturing/industrial sectors like imposing taxes on virgin materials, introducing life cycle assessment based industry standards, product taxes, deposit-refund schemes, behaviorally informed interventions, green public procurement, landfilling and incineration taxes, take back schemes, soft loans to construct waste disposal facilities and providing grants for research & development (R&D).
Plastic Packaging Sector
Plastics industry remains complex in terms of its upstream and downstream processes. As per FICCI, with regards to upstream processes, industrial manufacturers control the market for the supply of 96 polymers alongside 200 equipment manufacturers which cater to roughly 30,000 plastic 97 processing units. Further downstream, collection and recycling are mainly dominated by the 98 informal sectors with about 1.5 million workers in total, catering to around 4,000 informal 99 and 3,500 informal recycling units. The policy notes that “the most common forms of plastic polymers on the market include Polyethylene terephthalate (PET), High-density polyethylene (HDPE), Low-density polyethylene (LDPE), Polyvinyl chloride (PVC), Polypropylene (PP) and Polystyrene (PS)”. It further adds that “packaging industry is the largest consumer of polymers in India. PE and PP accounted for around 33% and 29% of polymer usage respectively, followed by PET (17%), 110 PVC (7%) and others (14%) in 2016”.
Policy landscape pertaining to plastic waste management in India remains dominated by the Plastic Waste Management (PWM) Rules 2016. The legal principle of Extended Producer Responsibility (EPR) forms an integral part of PWM Rules 2016. However, the implementation and monitoring frameworks are almost ‘absent’. The policy realizes this fact too. As a result, the action roadmap for tackling plastic waste gives prime importance to the whole concept of EPR. Policy proposes to identify the strengths and weaknesses in the system for pan India implementation of EPR. The policy also adds that regulatory strengthening of CPCB and SPCBs needs to be done in order to monitor and implement the PWM rules on the ground. Inclusion of plastic waste collection targets in PWM Rules also finds the place in the draft policy document. Further, the policy sets the following targets for the plastic packaging sector:
1- 100% recycling and reuse rate for PET plastic by 2025.
2- 100% recycling of PET plastic and 75% recycling and reuse rate of other plastic packaging materials by 2030.
3- Ban on disposal of recyclable plastic waste to landfills by 2025.
Similarly, the policy has laid down targets for other sectors too like automobile, electronic waste, construction and demolition waste, solar photovoltaic sector etc. No doubt, the policy looks strong on paper but the roll-out plan and implementation of the policy remains a question. Secondly, the entire narrative of resource efficiency is still in infancy. The awareness levels regarding topics such as circular economy, resource efficiency, upcycling of waste may take some time to become mainstream and publically visible. In such a scenario, the output of policy may become slightly difficult or unclear.
Not to mention the interdepartmental coordination for the execution and monitoring of the policy is going to be a crucial factor. It remains a major challenge as red-tapism and rigid bureaucratic setup continues to dominate the Indian public policy discourse.
Also, the policy will affect the small businesses and informal sector massively. Large number of recylers, dismantlers and other sorts of waste businesses are revoling around these resources which might end up getting shut down. Therefore, holisitc rolling out of the policy remains the key for sucessful outcome of it. A consultative approach before adopting the policy will also determine the implementation and performance of the policy in the coming times.