The Plastic Paradox

Plastic is a non-renewable product.  It is simply another form of fossil fuel that is partially responsible for the climate crisis. Every aspect of the life cycle of plastic—extraction, purification, production, distribution, use, processing and disposal—fuels climate change.

For decades, plastic pollution has been misunderstood and underestimated to be a waste mismanagement issue, a marine litter problem, a problem that could be solved through technological intervention. The petroleum and petrochemical industry continue to argue that they are not a part of the problem and most of our national legislations have been drafted accordingly. As a result, all our efforts were directed towards the downstream end of the plastic life cycle. Governments mobilised funds to manage plastic waste while production kept increasing. We have produced more plastic in the last 10 years than in the last century.

India is one of the global leaders in introducing an array of policies for managing plastic waste. Starting from 2016, there have been as many as five amendments till January 2022, which could largely be categorised into (a) banning select single use plastic, (b) imposing polluters pay principle on the plastic producer, importer and brand-owner, collectively known as the “PIBO” to manage plastic waste coming from packaging and (c) mandatory use of recycled plastic in manufacturing new products to reduce consumption of virgin materials. It is noteworthy that multi-layered plastics (MLP) were proposed to be banned under the Plastic Waste Management Rules, 2016. The 2018 amendment introduced new narratives like “energy recovery” and “alternate use”. The amendment notified phase out of MLP that was non-recyclable and non-energy recoverable, making the phase out redundant.

While the Single Use Plastic (SUP) ban notification was promising, it had few grey areas according to India’s own definition brought out on August 12, 2021 notification as “plastic item intended to be used once for the same purpose before being disposed of or recycled”. But it is not a blanket ban on SUP as is the general perception. After a year of enforcement of the ban, the situation does not seem to have changed much on the ground.  There are primarily three reasons for this. Firstly, the banned items are mostly non-branded and in all likelihood most of them are being produced in informal manufacturing units. Secondly, about 60 per cent of Indian plastic waste is sourced from plastic packaging, which, according to our own definition, is SUPs, but not considered for banning. Thirdly,  MLP, which happens to be the most problematic of all plastic waste, was also not considered for ban under the SUP notification.

The Plastic Waste Management Rules, 2016 introduced the concept of Extended Producer Responsibility (EPR) to manage plastics in India but it did not really take off then. A comprehensive EPR policy for plastic waste management was finally notified in January 2022. The Extended Producer Responsibility (EPR) Amendment, 2022 has divided the polluters into three different categories – importers, producers and brand owners.

While the evolution of EPR is still at a nascent stage, the enforcement lacks clarity in the absence of the cost of collecting plastic waste by the brands. It leaves the vulnerable informal network, which, despite not finding a space in policies, as the key player. The other downside of the EPR mandate is to allow co-processing industries to register themselves as plastic waste processors in rigid and flexible category of plastic waste. Overall, the EPR policy is a useful instrument, which would ensure accountability by the polluters and may also result in curbing use of plastic in packaging. Once the recycling target for the PIBOs kicks in from 2024, performance of EPR can be better assessed.

The EPR notification issued by the Ministry of Environment, Forest and Climate Change in 2022 has left out biodegradable plastics from the EPR mandate. It means producers and brand owners placing their products in the market in biodegradable packaging will not have any collection and recycling obligations. Compostable plastics, which had also been left out of the EPR’s scope, have now been included following intervention and advice from civil society organisations. The latter had emphasised on why compostable plastics need to get collected and channelled into industrial composting facilities. There are now collection and recycling targets under EPR for compostable plastics, starting from the fiscal years 2021-22, and 2024-25, respectively.

The petroleum industry is the feeding source for the petrochemical sector, where polymers (plastics) are manufactured. This means that plastic is a petrochemical made from fossil fuels. In 2020-21, over 84 per cent of India’s petroleum (crude oil) demand was met through imports. This crude oil is refined to get naphtha, which is then subjected to a process of cracking to get building blocks (monomers like ethylene, propylene, styrene, etc). These building blocks are processed with intermediate chemicals to make the basic petrochemical, which is then converted into the final product.

This final product can range from plastics to detergents to chemical fertilisers. India’s cumulative production capacity for petrochemicals is 29.10 million metric tonne per annum (MMTPA). In 2020-21, of the 17.93 MMTPA, 12.14 million metric tonne was used to manufacture polymers (plastic). This means that plastics accounted for more than 67 per cent of the total petrochemicals produced. The production of polymers has been constantly increasing over the last decade and a half. The production of polymers in India has gone up by 2.6 times, while the import has witnessed a four-fold rise between 2005 and 2020.

There are enough evidences to conclude that it is time to look at the upstream of plastics in terms of regulating supply and consumption of raw materials in plastic manufacturing facilities. An endeavour to end plastic pollution without taking the upstream into consideration may not become a reality ever.

The period between 2016 and 2020 has been, therefore, extremely eventful considering the way India has positioned itself to deal with the ever increasing plastic pollution. We continued to believe that plastic in India is a downstream waste management problem and kept searching for solutions in technologies.

We defined and re-defined “recycling” to the extent of equating it with co-processing for energy recovery. As a nation, we kept talking about dealing with plastic waste management and associated technological solutions.  What got missed in the whole endeavour is focusing on the upstream of the plastic value chain to control and regulate plastic production in India, especially the problematic fractions like MLP and SUP. Here is why we should look at the plastic issues holistically to plan a roadmap for management. While plastic is a necessity, it is equally important to use it judiciously where the product is designed to be used for years and not days. Some of the key considerations to curb plastic pollution in India are given below:

• Strengthen the inventories, collect credible data: The plastic waste production, consumption and recycling inventory of the country needs to be strengthened. Simultaneously, we need to work on estimating/calculating the country’s plastic recycling capacity, and create an inventory of all the plastic recycling processes used in the country.
• Monitor biodegradable and compostable plastics: A stringent monitoring mechanism is needed for tracking the biodegradable and compostable plastics that are being released into the market. With the Central Pollution Control Board (CPCB) looking at them as potential alternatives, we should not lose sight of the challenges that comes along with this special stream of plastic waste.
• Proactive disclosure policy for PIBOs: A high degree of opacity lies in the systems that are currently in place as far as the use of plastic by PIBOs is concerned. Brands should be mandated to have a proactive disclosure policy to continually report the amount of plastics put out by them in the market each year.
• Ensure credible labelling: Consumers should have the right to access relevant information through robust labelling mechanisms. For instance, use of the recycled symbol even on non-recyclable plastic packaging is equivalent to misleading consumers.
• Recognise informal sector: The informal sector needs to be included in the formal value chain of plastic waste management. It also needs to be protected from the rapid privatisation of plastic waste management services. Traditionally, informal sector has been at the epicentre of collecting and recycling plastic waste into formal recycling facilities.
• Promote refillable/reusable models of packaging: Refillable models for SUP packaging for FMCG products should be promoted by the government and explored by the brand owners. Refillable models promote the concept of reduce and reuse, which takes us in the right direction towards solutions for the plastic problem.
• Rationalise the EPR system: Giant companies have devised a mechanism to involve waste-picker cooperatives to fulfil their (the companies’) EPR liabilities. All this is being done without knowing the actual cost of EPR, which should account for the cost of minimum labour wages, occupational safety and health benefits for the workers actually involved in making realisation of EPR targets a reality for big companies.
• Ban Multi-Layered Plastic (MLP): The agenda of banning/phasing out MLP has time and again eluded lawmakers. We need to institute a systemic change in the way we are consuming. We cannot keep producing materials that cannot be dealt with once their end-of-life is reached.
• Enforce design changes in product packaging: While it is important to focus on the downstream aspects of plastic pollution by promoting better waste management practices, equal importance and thought needs to be given to upstream solutions such as design changes in product packaging. It is a fact that the more composite the packaging, the costlier and more unfeasible is the recycling potential. Using polymers from the same family will increase the recyclability of the plastic packaging. This needs to be the way forward. Simultaneously, we need to move away from composite plastics.
• Encourage R&D on plastic packaging: The central government and the industry should pledge funds for research and development on plastic packaging which will help in transition from the problematic non-recyclable plastics to a market with higher recyclable materials. Recently, a reputed brand in India has developed a mono-material plastic packaging for toothpaste which reportedly increases the recyclability of the otherwise non-recyclable lami-tube used currently for paste or gel-based products.
• Match environmental choices with economic choices: India will need to put its environmental preferences at par with its economic preferences, if not above. Petroleum and petrochemical companies should also be held accountable for the plastic waste that we have to deal with. While the existing legal arrangement gives this a miss, we need to understand that any number of midstream and downstream plastic waste management strategies like design changes, clean-up drives, and bio-remediation are responses to the pollution that we already have to deal with. The ultimate solution is to target the ‘source’ of the problem by regulating the production of polymers, which has witnessed a steep rise lately.
• Introduce DRS systems: Deposit Refund Schemes (DRS) that involve all stakeholders and strengthen existing legal tools like EPR should be introduced. Such schemes will incentivise the consumer while putting the responsibility on the right shoulders in the plastic value chain. This will ensure that bottles are recycled and converted back to bottles, and not to a product. The latter takes the plastic waste generated at the end-of-life out of the plastic waste eco-system and accounting, leading to unaccounted composite/blended plastic waste which is much more difficult to recycle.

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Atin Biswas and Siddharth G Singh serve as Programme Director and Programme Manager in Centre for Science and Environment