The Union Ministry of Environment, Forest and Climate Change (MoEF&CC) has released a draft notification proposing Extended Producer Responsibility (EPR) for packaging made from paper, glass, and metal, as well as sanitary products.
The notification arrives a year after Centre for Science and Environment (CSE) released a comprehensive report in December 2023 to address the same concerns.
The CSE publication proposed developing Extended Producer Responsibility (EPR) guidelines for paper waste to reduce dependency on imported wastepaper and increase the use of domestically available raw materials.
Historically, management of waste generated from materials like paper, glass and metal has fallen under the ambit of the Solid Waste Management Rules.
The latest draft EPR guidelines introduce a framework where producers, importers and brand owners (PIBOs) are responsible for collecting and recycling the packaging waste they generate. This system aims to reduce the burden on landfills and promote circularity in resource utilisation.
The current guidelines primarily focus on packaging-grade paper, which, while representing 60 per cent of total paper production, already boasts a relatively high collection rate of around 60 per cent. This indicates that a mature recycling system for this segment is in place.
However, a far more critical segment is writing and printing paper, constituting 30 per cent of production, yet with a lower collection rate of a mere 40 per cent. CSE emphasises the need to include this segment under EPR, given that paper made from virgin fibres can be recycled multiple times (six to seven times) throughout its lifecycle.
So the limited scope fails to capitalise on the full potential of wastepaper circularity and undermines efforts to reduce the reliance on imported wastepaper for writing and printing paper.
Settling for lenient targets of recovery
CSE has proposed ambitious recovery targets for recycled fiber-based (RCF) paper industries:
95 per cent domestic recovery rate by 2028: This aggressive target aims to significantly boost domestic recycling efforts.
Limited international sourcing: Importing wastepaper should be restricted to a mere five per cent of total raw material needs.
Focus on domestic sources: Prioritise the use of recycled or virgin wastepaper sourced entirely within the country.
However, the draft EPR guidelines limit these targets to packaging-grade paper. This exclusion may undermine the broader goal of comprehensive waste management. Targeting a 70 per cent recovery rate by 2026-27 is overly lenient and essentially redundant, as this target has already been almost achieved.
Furthermore, as suggested by CSE, a recovery rate of 95 per cent from 2027-28 onwards is more appropriate, considering the fraction of imported material. However, the draft notification aims for only 85 per cent during that timeframe.
While this draft EPR guidelines represent a positive step towards sustainable waste management, a closer analysis reveals crucial gaps that need to be addressed to create a truly robust and effective framework. The CSE, in its aforementioned report highlighted several recommendations, some of which have been incorporated in the draft, while others remain unaddressed.
A detailed comparison between CSE’s recommendations and the MoEF&CC draft EPR guidelines is presented below, highlighting areas that require further consideration:
| Parameter | CSE?s recommendation | MoEF&CC draft EPR guidelines | Remarks |
| Extended Producer Responsibility (EPR) for wastepaper management | The Government of India should formulate regulations on EPR for paper waste, including guidelines for manufacturers, consumers, CPCB/PCCs/SPCBs, and recyclers with clear responsibilities for each. | Producers, Importers, and Brand Owners who introduce packaging or sanitary products to the market are responsible for collecting these products. | The draft guidelines incorporate EPR but do not mention consumers' responsibility. |
| Stakeholders Covered under EPR | Producers or manufacturers of paper products including kraft paper, duplex board and other wastepaper-based products | Producers (excluding micro and small enterprises), Importers with an annual turnover of Rs. 10 crore and above, and Brand Owners (including online platforms/marketplaces and supermarkets/retail chains, excluding micro and small enterprises) are covered. Waste processors are also covered under EPR obligations. | Inline with CSE. The draft guidelines cover a comprehensive range of stakeholders. |
| E-commerce brands (Amazon, Flipkart, Blinkit, etc.) and other brand owners using any grade of paper in bulk. | It incorporates entities dealing with packaging made of paper including paper board or glass or metal and sanitary waste. | ||
| Registration of stakeholders | stakeholders should be registered through a system similar to the one created by CPCB under EPR notifications which are already in exercise. | Registration of PIBOs (operating in one or two states) and waste processors shall be done by SPCB/PCC through the centralised EPR portal. | Inline with CSE |
| Registration of PIBOs (operating in more than two states) shall be done by CPCB through the centralised EPR portal. | |||
| Integration of the Informal Sector | CSE stresses the need to formally integrate the informal sector (ragpickers and kabadiwallahs) with formal agencies for wastepaper collection, sorting, and recycling. | While the draft mentions collaboration with local bodies for collection infrastructure, it lacks explicit guidelines for integrating the informal sector into the formal recycling system. | This lack of clear integration mechanisms may perpetuate inefficiencies in wastepaper collection and recycling, as well as fail to empower and improve the livelihoods of informal waste workers. |
| EPR Targets for RCF-Based Paper Industries | CSE proposed ambitious recovery targets for RCF-based paper industries, aiming for a 95% recovery rate by 2028 through domestic recycling. | The draft guidelines set EPR targets for PIBOs, with a gradual increase in recycling percentages over time. However, these targets are limited to packaging-grade paper and do not specifically address the ambitious goal of 95% recovery for RCF-based industries by 2028. | The lack of specific and ambitious targets for RCF-based industries may hinder the growth of domestic wastepaper recycling and fail to incentivise achieving higher recovery rates. |
| Quality Standards for Raw Materials | CSE recommends the development of quality standards for raw materials to optimize the blending of virgin and recycled paper and ensure the production of high-quality recycled paper. | The draft guidelines do not specify any quality standards for raw materials. | This absence can hinder the production of high-quality recycled paper, discourage the use of recycled paper, and perpetuate the reliance on virgin fiber. |
| Registration is must | All dealings should be undertaken among the registered stakeholders only. | The registered entities covered under sub-rule (1) shall not deal with any other entity covered under sub-rule (1) but not registered on the online centralised portal. | Inline with CSE |
The draft guidelines clearly demonstrate the government's intent to move towards a circular economy model for managing packaging waste. However, to realise the full potential of EPR and achieve a truly circular system, the MoEF&CC should seriously consider incorporating the missing elements highlighted by the CSE. Addressing these limitations will ensure a more robust, inclusive, and effective EPR framework, ultimately leading to increased domestic wastepaper recovery, reduced reliance on imports, and environmental sustainability.
“This draft is indeed a courageous and positive step that will boost circularity in the pulp and paper sector and further India's mission of self-reliance,” Vijay Kumar, Secretary General of the Indian Newsprint Manufacturers Association (INMA) stated.
However, Parth Kumar, Programme Manager, Industry Programme at the Centre for Science and Environment (CSE), argued, “The proposed guidelines represent a step forward in formalising waste management for certain materials. However, their limited scope raises concerns. Writing and printing paper, which relies heavily on imported wastepaper, has not been considered in the EPR mandate, which is a significant gap in the current draft”.
“CSE emphasises the need for inclusive EPR guidelines that address all paper categories and encourage circularity across the industry,” Kumar added.
By aligning EPR targets with domestic recycling capacities and covering a broader spectrum of materials, the policy could significantly reduce wastepaper imports and improve resource efficiency.
With a few critical revisions, the EPR framework has the potential to not only streamline waste management but also position India as a leader in sustainable recycling practices.