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Can EPR contribute to the improvement of the informal sector?

EPR holds significant potential for integrating the informal sector into formal waste management systems. But what’s the ground reality in India? Shriyal Sethumadhavan reports.


Filed under
Waste Management
 
June 7 2024
 
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Image credit: Saahas Zero Waste

Urban local bodies (ULBs) in India encounter significant challenges in waste management, primarily stemming from the lack of source segregation, inadequate infrastructure, and low awareness of ethical disposal practices. India's solid waste, comprising approximately 60% wet, 30-35% dry, and 5-10 % inert and biomedical materials, faces transportation and handling cost escalations due to insufficient source segregation.

Abhishek Agashe, Co-founder & CEO, Elima, emphasises inadequate land allocation for decentralised waste management activities. “Waste is transported over long distances to processing or disposal sites, further escalating costs and complexity.” 

Radhika Kalia, Managing Director, RLG Systems India Pvt Ltd, underscores cultural, logistical, regulatory, participatory, and environmental challenges in waste management. She says, “Public perception of waste as disposable rather than recyclable complicates efforts, requiring extensive education on recycling’s importance.”

Sourabh Manuja, a waste management expert based in Delhi, adds, “Waste management, particularly collection, should be provided and charged as a service by the industry. Processing or linking each waste category for recycling or processing should be identified as the management option. Only rejects should be disposed of.”

Highlighting the fragmented waste collection in cities due to diverse terrains and narrow roads, Shobha Raghavan, CEO, Saahas Zero Waste, emphasises scheduled collections and persistent information dissemination as essential. “Extended Producer Responsibility (EPR) can mandate brands to support the collection of non-valuable waste, focusing on training the informal sector to improve material recovery quality.” 

Reducing landfill dependency

In India, landfill dependency is a big challenge that involves more than just collecting waste.

Reducing landfill dependency in India necessitates addressing historical waste through bio-mining to recover and repurpose land, according to Raghavan. She suggests setting targets to reduce landfill dumping to 10% over the next five years, advocating for scientific waste management, effective segregation, and appropriate waste-to-energy utilisation. Agashe identifies the challenges of recycling low-value materials and emphasises the need for homogenous, easily recyclable product designs. He advocates for the conversion of wet waste in to biogas or compost to reduce waste handling costs and landfill dependency.

Kalia emphasises the need for a comprehensive waste collection and segregation system, pointing out deficiencies in recycling infrastructure, logistical challenges, regulatory gaps, financial constraints, and the integration of the informal sector.

Informal sector challenges

Approximately 1% of India’s urban population works in the informal solid waste management sector, including individuals, families, and micro-enterprises. These entities handle roughly 90% of residual waste through their informal practices, efficiently collecting, sorting, and recycling waste materials without formal organisation, sponsorship, financing, contracts, governmental recognition, management, taxation, or reporting.

The informal waste management sector, comprising waste-pickers and kabadiwaalas, plays a crucial role in India’s circular economy despite facing hazardous working conditions and social stigma, according to Tejashree Joshi, Head Environmental Sustainability at Godrej & Boyce.

Manuja highlights the sector’s role in meeting waste processors’ demand and adds that organising waste pickers into self-help groups (SHGs) or societies is essential to improve operations. 

On her part, Raghavan stresses the importance of upgrading informal sector operations and fostering trust through infrastructure, digitisation, and formal salaries.

The waste recycling and processing involve various stakeholders, including waste collectors, scrap shops, and aggregators, working in an efficient, decentralised supply chain to ensure recyclable materials reach processing units.

Efforts must be made to formalise the informal waste management sector through policies providing financial incentives, training, and recognition, according to Agashe. This approach bridges the gap, enhancing efficiency and sustainability in waste management.

EPR implementation impact

India has been proactive in adopting EPR policies, applying them to various waste streams such as plastics, e-waste, batteries, and tyres, with plans to extend to oil and textiles.

Kalia observes, “India’s EPR scheme that made producers accountable for the lifecycle of their products, including waste management, drew attention as a model for sustainable waste management.”

Despite having some of the best EPR regulations globally, Raghavan points out that implementation has been slow. “Since the first plastic waste rules in 2016, there have been many amendments, progressively moving towards a circular economy. The Central Pollution Control Board (CPCB), state boards, and multiple parties are involved, leading to interest and capacity issues. However, brands now understand the importance of EPR.” She adds that efforts are underway to ensure proper waste management through EPR, but unethical practices have emerged, as tracking low-value plastic recycling is ineffective. Technology interventions by the CPCB aim to address these issues, but more brand commitment is needed.

“By requiring producers and brand owners to pay an EPR fee, the system subsidises the costs of collection and logistics, making formal recycling more competitive with informal systems,” says Agashe, adding, “Ensuring that producers view EPR as a beneficial strategy rather than a mere expense is vital for the long-term success.”

Manuja notes that EPR implementation in India primarily involves Public Interest Bodies (PIBOs) and Producer Responsibility Organisations (PWPs), with ULBs not directly benefiting. “PIBOs lack state-specific targets and may use non-post-consumer waste to meet their goals. Tracking credits generated for plastic packaging waste versus other plastic waste processed is challenging. EPR should be operationalised in ULBs through deposit refund systems and packaging waste collection mechanisms alongside municipal systems. Further investments in R&D for sustainable packaging and waste management are crucial. Our priority should be waste reduction in cities.”

EPR and informal sector integration

EPR holds significant potential for integrating the informal sector into formal waste management systems.

Joshi views the integration of informal into formal waste management systems as a major aspect of creating decent work opportunities. “For the informal workforce, this entails acknowledging their historic contributions towards a circular economy and recognising their right to safe and dignified work.” Godrej & Boyce employs members of the waste picker community in its waste management initiatives, offering stable incomes and benefits like health insurance. “Our collaboration with Producer Responsibility Organisations (PROs) ensures traceability and accountability in recycling efforts.”

According to Agashe, “Leveraging EPR fees enables the formal sector to invest in decentralised waste collection infrastructure and allocate a portion of these fees to informal waste collectors. This encourages informal collectors to sell waste to formal players, bridging the gap between the two sectors.”

While the EPR regulations mention integrating the informal sector, what’s happening on the ground does not reflect true integration. “We need more funds,” says Raghavan. “We need to provide incentives to prevent child labour, move workers into formal spaces, integrate data into their operations, and ensure they have suitable vehicles.” 

Under EPR, producers are responsible for their products’ entire lifecycle, including disposal, fostering structured and sustainable waste management, says Kalia. EPR, aligned with Niti Aayog’s Resource Efficiency strategy and the Panchamrit Objectives, is seen as crucial for India's net-zero and circular economy goals. “It incentivises formalisation by providing financial resources for infrastructure and training programmes, encourages safer recycling practices, inspires collaboration among stakeholders, and raises consumer awareness about sustainable waste management practices.”

The potential for success will depend on the establishment of state-specific targets and targets specifically for post-consumer waste, says Manuja. PIBOs will need to engage in tri-party agreements with ULBs and PWPs to operate Material Recovery Facilities (MRFs) in cities, facilitate the transfer of EPR credits (from PWPs to ULBs), and involve informal actors in MRF operations within cities. 

However, achieving these objectives will require robust behaviour change practices, stringent monitoring, and collaboration between Self-Help Groups (SHGs) and NGOs.

Waste management strategies

In the future, key strategies for improving waste management in India include integrating the informal sector and implementing EPR effectively. Industry recommendations are:

  • Strengthen and refine EPR regulations to ensure higher compliance and accountability. Create financial incentives for formal-informal sector collaboration.
  • Invest in infrastructure, develop local recycling units and composting facilities to support decentralised waste processing, prioritising high-waste-generation areas.
  • Promote PPP collaborations between government, private sector, and NGOs to drive innovation in waste management.
  • Raise public awareness about waste segregation, recycling, and responsible disposal to encourage active participation.
  • Lower GST rates on scrap materials to reduce financial burden on recyclers and incentivise formal transactions for the informal sector.
  • Integrate the informal sector by forming waste picker organisations, providing incentives, training, legal protection, and safety standards.
  • Channel funds from producers to establish collection centres and recycling facilities. Promote safer recycling methods, monitoring, and reporting.
  • Involve SHGs, NGOs, and informal actors in waste collection and sorting, linking sorted waste with markets. Mandate such systems in states and cities.
  • Implement state-specific EPR regulations targeting post-consumer waste recovery. Involve PIBOs, PWPs, and ULBs in waste processing, particularly plastics.
  • Establish mechanisms to track, measure, and report social impact of EPR, focusing on formalising and elevating informal sector workers' conditions.