As reported on our website www.packagingsouthasia.com, the government has considerably eased restrictions on the use of Multi-layered Structures and Mixed Plastic Materials for packaging. In a major relief for industry and consumers, the Government has issued new rules for Plastic Waste Management that supersede the PWMR 2016 and allow the continued use of Multilayered Plastic Structures. The new rules – called the Plastic
Waste Management Rules, 2018 – have been notified on 27 March 2018.
In a major change of thinking, the government has introduced the concept of a new ‘alternate use’ process viz. ‘energy recovery,’ which it defines as “energy recovery from waste that is conversion of waste material into usable heat, electricity or fuel through a variety of processes including combustion, gasification, pyrolisation, anaerobic digestion and land fill gas recovery.” It now bans the use of only “multi-layered plastic which is non-recyclable or non-energy recoverable or with no alternate use.” In effect, almost all existing packaging structures currently in use can continue to be used.
The rule relating to explicit pricing of carry bags has been omitted.
The government needs to be complimented on its realization that PMWR 2016 was not a practical concept and could have caused severe hardship on brand owners and consumers. While the government has done its bit to provide relief, it is now up to brand owners, the packaging industry and municipal agencies to step up to the plate and do their bit to fulfill their responsibilities as laid down under extended producer responsibilities in the Act.
I would first like to reiterate the following two relevant clauses of the PWMR 2018 act categorically laid down under Responsibility of Producers, Importers and Brand Owners:
The producers, within a period of six months from the publication of these rules, shall work out modalities for waste collection system based on Extended Producers Responsibility and involving State Urban Development Departments, either individually or collectively, through their own distribution channel or through the local body concerned.
Primary responsibility for collection of multi-layered plastic sachets or pouches or packaging is of Producers, Importers and Brand Owners who introduce the products in the market. They need to establish a system for collecting back the plastic waste generated due to their products.
This is actually a massive and elaborate mandate that industry should already have addressed. Strictly speaking, they are already well behind the deadline of six months (this was originally notified on the 18 March 2016) and the government would be well within its rights to question why no progress has been made on this front.
I would once again like to point out that this mandate needs to be addressed on a collective basis and needs a multi-pronged action plan to be drawn up. To break down the plan into its recommended constituent initiatives, some of the broad objectives that have to be formulated and implemented post-haste are listed below:
- Initial consumer education and communication.
- Setting up waste segregation systems.
- Setting up collection systems for segregated waste.
- Changes in labelling and package communications.
- Organization and setting up of agencies for recycling and waste reprocessing.
- Developing new technologies for waste reprocessing and regeneration of resources to
- effectively reuse of collected waste as a “resource”.
- Setting up systems for consolidation of collected segregated waste and delivery to recyclers and re-processors.
- Develop new applications and new markets for reuse of reprocessed waste into equivalent products (and not down-cycled applications) so that it becomes a self-sustaining business.
Each of these has to be a long-term and ongoing process and of course,each of these broad objectives has its own special needs for communication and education.
Let us now look at each of these objectives in a little more detail.
Consumer education and communication
First and foremost, the average consumer and all supply chain partners have to be educated on their responsibilities and on how things are going to work; this can only happen through a massive and extensive communication program. The campaign will have to be progressive and ongoing and will have to be carried out not only by brand owners and industry but also by government bodies like law-enforcement agencies, various government ministries, municipal agencies, all kinds of media (print, outdoor, digital, POP, retail, distribution, text books, teaching apps), consumer agencies, educational institutions and the like to name only a few.
It will have to be drilled into consumers and average citizens that there is a severe crunch on non-renewable resources and the question is not if we will run out on them but when this will happen. Sustainability consciousness just has to be developed as a universal ethos and everybody has to be trained to consider it as important as observance of laws and social responsibilities.
We will also have to explain how systems to regenerate resources from waste are going to work and put in place suitable laws and statutes, as necessary. Established consumer behavior has to be changed and modified in line with sustainability objectives.
This is only so far as primary consciousness and sensitivity is concerned. A lot more has to be done, as described later.
This is not only an extensive exercise, it is going to be very expensive to execute well. So, who is going to do this? Surely, this cannot be done effectively by an individual corporate or industry. This has to be a collective effort involving practically everybody including the powers that be and the Government.
Again, as mentioned above, each separate objective has its own set of communications and consumer education to be addressed and, therefore, effective and tailor-designed communications transcend the entire gamut of what needs to be done.
Waste segregation systems
The setting up and communication to consumers of segregation systems has to start from the very basic concepts as the average Indian man in the street has no exposure to them at all. How uphill a task this is can be gauged from an excerpt from the report on “New Plastics Economy” published by Project Mainstream (a joint initiative of the World Economic Forum, Ellen MacArthur Foundation and McKinsey) that states, “Today – more than 40 years after the first introduction of the first universal recycling symbol – only 14% of plastic packaging is collected for recycling, even though almost all plastics used for packaging are mechanically recyclable with little or no quality impairment. Plastics that do get recycled are mostly recycled into lower-value applications that represent their final use, as they cannot be recycled again (economically).” This quantum is paradoxically the experience of the developed countries as good segregation and recollection systems exist only in those countries. The developing nations and backward countries do not even have in place any segregation systems worth the name.
Industry will not only have to formulate, standardize and implement universal segregation symbols but communicate them across the board and incorporate them in all their packages, production, distribution, package and product communications and chain of segregation, waste collection and waste reprocessing systems. These will also have to be communicated to all government and municipal bodies involved as this have been clearly designated as extended producer responsibilities.
Each household will not only have to be educated but provided with various ‘cyclable’ bins for storage of segregated waste in accordance with material classification. Consumers have to be trained to strictly follow segregation norms. (A system will also have to be worked out for collection of bins on a periodic basis and their replacement with fresh bins to make the waste segregation and collection an ongoing circular process. This has been described later in more detail.) It also has to be ensured that the segregation is done without contamination by organic waste or food and or product scrap so that the recycling and or reprocessing can be carried out hygienically and without safety concerns.
Collection systems for segregated waste
Elaborate and extensive systems for collection of segregated waste will have to be designed and implemented. The systems will have to cater to the requirements of even the smallest village or residential unit, industrial units and institutions like hotels, hospitals, educational institutions and offices etc. The total task involves:
- Educating every household or consumer.
- Building up a sense of responsibility and accountability in every individual.
- Making sure that everyone involved in the process diligently follows system requirements.
- Each household has to be provided with multiple ‘recyclable’ storage bins as necessary to store all waste material classifications. The bins have to be color-coded so that even small children can make out which bin has to be used for which class of material.
- These bins have to be collected periodically and replaced with fresh bins.
- Collected scrap will have to be consolidated and delivered to recyclers and or reprocessors.
- Some amount of sorting may also be necessary after collection so that scrap is not contaminated or have content that could affect efficacy of further processing.
In the next part of this article to appear in the July issue of Packaging South Asia, we will address the other objectives listed above.