The Extended Producer Responsibility (EPR) framework is basically reshaping India’s waste recycling landscape. At the recent Plastics Recycling Conference India, a panel discussion moderated by Shailendra Singh, Founder & CEO, SustainMantra, brought together brand owners, recyclers and compliance experts to examine the evolving realities of Extended Producer Responsibility (EPR) – its progress, gaps, costs and opportunities.   

Providing a brand owner’s perspective, Chinmaya Dandekar, General Manager, Godrej Consumer Products Ltd., reflected on how India’s sustainability ecosystem has changed in two decades. “When I started my journey 20 years back, sustainability was only being talked about. But with the introduction of the Waste Management Rules in 2016 and later amendments including a strong EPR framework, we have entered a progressive phase.”

He noted that mandates on recyclability and PCR have pushed brand owners to rethink packaging design and material choices. The launch of digital monitoring platforms has been a turning point, he stressed. Visibility of numbers is critical and without statistics, there will not be serious investments in the sector, he noted, adding that the improvements in the last 3-4 years is offering a “positive outlook for the future.”  

Yash Sharma, Director, Ganesha Ecopet Pvt. Ltd., said, “We have started mapping and understanding material flows, but we still have a long way to go.” He highlighted the complexity of dealing with diverse plastic grades, each with unique recycling challenges. He stressed that grouping materials into broad categories like PET is insufficient to achieve circularity, and called for better categorization and focused interventions.

“EPR means different things to different people, but fundamentally its strength lies in diverting waste away from landfills and water bodies,” said Saurabh Shah, Managing Director, Landbell GreenForest Solutions India. He argued that EPR succeeds when every piece of scrap, from a chocolate wrapper to a bottle, holds enough value to make collection and recycling worthwhile. While acknowledging the significant expansion of recycling capacity since EPR’s introduction, he warned that difficult-to-recycle materials still lack adequate processing capacity. True success, he said, will come when EPR makes even low-value plastics financially viable to collect and recycle.

Pranay Jain, Founder & Managing Director of EcoBlue Ltd., offered comparative insights. He said, “EPR is working reasonably well in India compared to many other Asian countries where the debate is still stuck at the draft regulations stage.” There may be gaps that need to be addressed such as incentives, certifications, etc., but the direction is promising, he noted, also reminding everyone that the purpose of EPR is simple: to increase recycling rates. 

Navigating cost, consumer awareness and material reduction

Moving to a sensitive but practical subject, the cost factor, Singh said EPR introduced a new expense that wasn’t part of the regular cost structure until a couple of years ago. He raised the question: How are brand owners working to account for this cost, or make it cost-neutral, and what strategies are they adopting? 

Dandekar acknowledged the problem. “Awareness is still low and there is no willingness to pay a premium for packaging with PCR content.” He explained that lack of awareness around EPR makes price pass-through nearly impossible. So, what’s the strategy? Reduction first, he said. “Identify what’s unnecessary in packaging and remove those first. Reduction improves sustainability and the P&L immediately.” He also recommended improving sourcing of recycled granules to minimize cost and quality impacts. He urged recyclers to supply high-quality material at more stable costs.

Sharma agreed that some brands are genuinely interested in EPR implementation, but he also pointed out that expectations must be realistic. Virgin plastic is heavily optimised and mass-scaled, while PCR, by comparison, is still climbing the maturity curve. “Today the cost of recyclate doesn’t match virgin plastic,” and it’s not a level playing field for the brands that want to adopt PCR, he noted, also pointing out that the solution lies in partnerships across the value chain.

Providing a regional angle, Jain revealed that many brands operating in Thailand are quietly scaling back their voluntary sustainability targets. “Many global brands have cut their recycled content commitments. Those who pledged 25 percent PCR may end up at just 10 percent. These were the brands buying from us. The international markets remain open, but demand fluctuations are real.”

Meanwhile, Shah made a sharp observation: “Producers do not love EPR, and if the regulator drops the price to half, no one will object.” He described the tension between brands and recyclers, noting that companies often fight harder against EPR in newer markets despite paying much higher rates in Europe, etc. Yet, he argued, there’s no escaping the responsibility: packaging has an end-of-life cost. Enforcement must remain strong to ensure fair pricing and systemic improvement over time, he said.

The exemption and data dilemma

With nearly 90 percent of India’s plastic processing industry falling under small and medium enterprises (SMEs), Singh posed a critical question: is their exemption as per EPR rules justified?

Shah said, “Bringing every player into EPR is practically difficult – the value chain is too complex.” For now, letting the buck stop with the brand owner is fair, he noted. Attempting to register thousands of small players could overwhelm the system, but, over time, accountability must extend across the chain, he added. 

Shailendra went on to question whether anyone truly knows how much plastic scrap is in circulation or if there is a methodology in place to address the issue.

The panelists acknowledged that India’s data on plastic waste remains incomplete and stressed that data is key to closing loopholes and keeping the right materials in the supply chain.

Shah said, “quantification is essential.” In his view, the fact that the CPCB portal now records nearly 40 lakh tonnes of plastic waste is an enormous leap from 2019’s data vacuum. He also urged continued improvement through municipal data, import/export records, and consumption analysis.

“Exempting small and medium players won’t help build accurate data,” Sharma cautioned, adding that everyone in the value chain needs to share the data on the CPCB portal to achieve the EPR goals.

Jain suggested a technology-led solution based on their experience: “Using blockchain, we track every point – from waste collectors to aggregators to recyclers. It gives 100 percent certainty about the material and the source, and ensures that money reaches those who need it.” That is the degree of traceability that data can bring in for everyone to improve efficiency, he observed. 

The panel also put the spotlight on the informal waste pickers who are an important part of the value chain, but rarely receive official attention. They are missing in the regulatory framework, which puts them at a disadvantage especially when it comes to benefits. Jain’s blockchain example hinted at a future in which they could finally become visible, formal and compensated fairly. 

One other aspect the panelists highlighted was the need to bring in uniformity in the terminology and definitions across states, so everyone starts using the same language, and it has to be clearly defined in the EPR guidelines as well. This gap, panelists agreed, must be addressed for true circularity.

What must change now?

To conclude, each panelist offered one essential improvement for India’s EPR system. Sharma stressed on effective portal implementation and proper data collection, while Dandekar said blockchain has potential “but full traceability has to be ensured – otherwise the exercise is futile.” Saurabh highlighted the need for “a more responsive system – agile, clear and efficient,” and Jain focused on the need to improve accountability, traceability and data authenticity.

The discussion made one thing clear: EPR in India is continuously evolving. The framework is in place, the intent is there, and stakeholders are engaged. But the system needs better data, stronger enforcement, clearer definitions, impartial cost structures and stronger integration of the informal waste ecosystem to achieve the goals.