The ground reality of EPR and recycling is hot topic at flexible packaging summit

Jeevaraj Pillai (JP) (opening comments): Addressing the complex circularity, it has got a few distinctive features, unlike the ones which are published by the global fraternity; It lays down a roadmap for the future. It recognises the lack of infrastructure for collection and recycling and hence provides a five to ten years time frame for 100% compliance; It comprehensively addresses the issue of both the collected as well as uncollected waste; It fosters an ecosystem where the producers, importers and the brand owners all come on a single centralised digital platform to transact business.

The manufacturers of the product, create and design a product which can be put to reuse easily and can be restored multiple times through either recycling or upcycling; It allows sale and purchase of the surplus EPR certificates. This triggers the market mechanism, any guideline and enforcement which does not trigger a market mechanism is bound to fail. We have a panel today to discuss the ground realities of environmental issues, how the EPR will help reach the projected circularity and demystifying certain elements of the EPR guidelines.

JP: Vijay Habbu, my first question is to you. There has been a grave concern and worry amongst the stakeholders that in the absence of a robust collection system, how effective will the EPR compliance be?
Vijay Habbu (VH): I think it's been said already since morning that an essential ingredient of recycling is the collection then comes segregation, cleaning and transportation. These are the four basic ingredients before the material reaches the recycling structure. We heard that unless collection is in place, no technologies such as recycling, mechanical recycling, chemical recycling and end of life are doable. The problem is if there is no collection of waste, then there is no recycling and hence, the system has to be redesigned on how to manage the waste after it goes to the litter.If we want to extract value out of resources, then bringing it back into the recycling stream is essential. 

India has a robust recycling collection system, which is called Rack because waste pickers give about 60 to 65% of recycling rate for plastics. The industry should think about it as a cohesive unit to tackle this problem. Therefore, the focus of everybody should be how to make the plastic packaging, whether it's rigid or flexible; more collectible, more remunerative and more easy for collection.

JP: So there are two elements to it. One is the regulator and the other is the industry which is facilitating recycling. But the missing element is an organised collection infrastructure, which is essential to the success of EPR. My next question is to Ashok Kumar Tyagi. Sir, the success of EPR will depend on how good or bad the collection cost is. What have you factored in as a cost impact of the EPR implementation on the ground? Are the brand owners aware of this? Will it be passed on to the end consumer?
Ashok Kumar Tyagi (AT): EPR implementation is a very new game to our industry, which we have implemented in the last few years. The cost of EPR implementation is somewhere between five to seven rupees per kg depending upon the location from where you are collecting the EPR waste. We are not passing this cost of EPR collection to our end consumer and we don't plan to do so in the future as well. We are bearing this cost to our bottom line.

JP: So, we have heard that tax avoidance is smartness and tax evasion is crime. In EPR, also, there is a possibility of EPR avoidance by using biodegradable plastics, but certainly there is no provision for EPR evasion. The question is to Srikrishna Balachandran, as always will the industry look for possible loopholes? Or would they genuinely make an attempt for compliance? 
Srikrishna Balachandran (SB): It's an interesting question. I think it's both ways. Industries would want to comply, but they want to comply at the lowest cost with the lowest impact in the margins. We cannot generalise industry, because there are a variety of industries that take proactive steps and wait for the rules to come in. 

Also there are industries which trade and therefore, I think in terms of compliance, nobody wants to be non compliant. Because it affects the business. Everybody wants to comply but what is the cost of compliance and how that compliance can also be turned into a business advantage? This is what the industry works towards as well. But if there are some loopholes, companies will try to gauge the risk and take a record to measure in the case they need legislation. EPR is no different from that.

JP: The PCR plastics collected from the MRF's in India have a lot of oil and food elements which are normally not found in the western world. Hence, the recycling system has to be properly designed for Indian conditions and it has to be customised to handle the plastic waste available in our country. My question is to Aditya Dalmia, how can designing help recycling?
Aditya Dalmia (AD): Designing can help recycling in a large way. As Vijay Habbu said, we have a very robust collection system that includes the rack picker and the housekeeping staff. These people only pick up something that has value and the non-value things will find its way to the landfill. The landfills will only find non recyclable products.

The designing should be done in a way where it creates value, whether it's for rigid or flexible packages. Both would get picked up to the chain of collectors that we have and the stress on the landfill would reduce substantially.

JP: The EPR draft when it was published, first in January, there are two components to it. One is the responsibility to collect, and then there are obligations which would mean that some portion of the material has to be recycled.  This was mandated from 2023 - 2024. But in the final guidelines, it has been shifted to 2024 - 2025. My question to Mani is that by allowing MLPs to be sent to submit claims for till 2024 - 2025 and encouraging brands to do more of the same, what would incentivize brands to switch from MLPs to recyclable or generally more sustainable materials? How do we catalyse design for recyclability in flexibles?
Mani Vajipey (MV): Perhaps the same way we've catalysed design for rigids. In the last 12 months, over 500 million FMCG bottles for shampoos, lotions and other home personal care applications in India were recycled and the bottles that you find on the shelves in India are made from recycled plastic. The packaging made from mono materials catalyses the informal recyclers to pick the materials and bring them to recyclers like Banyan nation or Dalmia Polypro. 

I think in the EPR regulations, enforcement of use of recycled material back in packaging is a tremendous driver for companies to make packaging recyclable in nature. If you don't design for recyclability, it's going to come and bite you in the back. As much as other companies are innovating in paint removal and ink removal, design for recyclability and use of recycled plastic back again in the packaging is a great catalyst.

JP: My next question is to Habbu. How does the regulatory system distinguish between the users of certified biodegradable materials and claimed biodegradable materials in India? Do you think the enforcement will be critical and difficult?
VH: It is difficult to identify which one is biodegradable and which one is not. Not only by using visual looks but also using analytical tools, we cannot identify the difference. Because these biodegradable materials are additive based materials. There is a gap of what samples are submitted for testing to get approval and what actually gets added because the industry will always work to save costs.

Plastics is a material invented after 2500 years. So far a new material that has been with us only for 100 years; to find all remedies to all these problems within a fraction of 10 years because there is a global noise against plastic litter is not doable. Industry uses the word plastics without knowing that plastics are based on polymers. There is very little polymer science being used to address various problems. 

Innovation is different materials and different combinations of materials to bring about a certain set of properties and functionalities. Therefore, the more complex we make the more difficult it becomes to recycle. And hence, innovation and recycling are not happening together. The only remedy is the use of polymer science. 

So, therefore, we are in a state where we need to go back to basic polymer science. Otherwise, things and concepts like biodegradable material will only be avenues for evading enforcement.

JP: We are in the middle of the EPR regime and we have to comply. My question is to Ashok Tyagi, in terms of compliance, what is the ground reality? 
AT: Compliance has always been a top priority for us. We not only do compliance but also check whether we are contributing to the environment. We have made a joint venture with HR Recycling. The waste we collect from the market next year will be given to HR Recycling and have the plastic removed. And this waste will be used for making different products like furniture.

The panel discussion on ground realities of EPR and sustainability brought about points such as; its implementation process, the waste management and waste collection.

Habbu said that the need for recycling plastics will be fulfilled with the start and application of basic polymer science. Hence, creating opportunities for sustainable development.