India's Extended Bulk Waste Generator Responsibility (EBWGR) framework offers an opportunity to make large food businesses responsible not just for processing food waste, but also for preventing it through better planning and inventory management.
Encourage businesses to prevent avoidable waste, redistribute surplus food that remains safe for consumption, and compost or convert into biogas only what is left.
Effective enforcement, reporting and incentives will be essential to making this food-waste hierarchy work
Preventing food waste and diverting edible surplus from landfills could also reduce methane emissions, and ease the burden on municipal waste-management systems.
India has long placed value on not wasting food, a sentiment often summed up by the familiar advice to finish what is on your plate. Yet significant amounts of food are wasted further up the supply chain and end up in landfills. Hence, as the country’s waste-management framework evolves, it is worth asking how more food can be kept from becoming waste.
At present packaged food falls within the framework of Extended Producer Responsibility (EPR), whose foundation was laid by the Plastic Waste Management Rules, 2016. The principle acquired teeth in 2022, when EPR guidelines established a system of targets, reporting obligations and a centralised portal for producers, importers and brand owners. These rules make producers responsible for the plastic packaging they introduce into the market, including that used for packaged food.
More recently, the government took a related step. The Solid Waste Management Rules, 2026, notified on January 28 and in force since April 1, introduced Extended Bulk Waste Generator Responsibility (EBWGR). Under the rules, any facility generating 100 kg of waste a day or more, such as a hotel, hospital, mall or institutional campus, must process its wet waste on-site or arrange certified processing. Bulk generators account for nearly 30 per cent of India’s total solid waste, which explains why the rules places particular responsibility on them.
The new rules bring food waste within the broader category of wet waste, with an emphasis on ensuring that it is properly processed—either composted or used for biogas generation. But there is an opportunity to think further upstream.
Some food waste can be prevented through better planning and inventory management; some surplus may still be fit for redistribution. Only the genuine leftover can then be treated as waste and can be composted or used for generating biogas.
There is another less visible benefit. At present, food waste that is not processed on-site becomes the municipality’s problem: it must be collected, transported and dumped by systems already under strain. Making large food businesses responsible for measuring, reducing and managing the waste they generate would bring that responsibility closer to where decisions about forecasting, procurement and portion sizes are made.
This need not become another paperwork exercise. Reporting could draw on inventory data that businesses already maintain; targets could be phased in according to business size; and verification could build on EBWGR's certificate-based system. Nor would financing necessarily involve new fees. The cost of organising food donations could be partly offset by savings on disposal, as businesses redirect surplus food rather than pay to send it to landfill.
Incorporating such a “food waste hierarchy” into EBWGR could be built on the principles India has already recognised. The country’s waste-management framework places prevention, reduction and reuse ahead of recycling, recovery and disposal. The Food Safety and Standards Authority of India (FSSAI) has separately promoted food-waste prevention and the redistribution of safe-surplus food through its “Save Food, Share Food” initiative and regulations governing surplus food.
The US Environmental Protection Agency’s Wasted Food Scale and the EU’s waste hierarchy can offer useful examples of how these principles can be applied specifically to food, placing prevention and redistribution ahead of composting. Bringing these strands together under EBWGR could give large food businesses a clearer sequence: prevent what they can, redistribute what remains fit for consumption, and compost or process for biogas only the genuine leftover.
There are, however, reasons to be cautious. A 2025 review of India's EPR framework for food packaging finds that enforcement remains weak. The country’s packaging recycling rate stands at around 9 per cent, with fragmented oversight and relatively light penalties among the factors cited. A Food Waste Hierarchy layered on top of EBWGR could meet the same fate unless its different tiers carry real weight. If a business can meet its obligations simply by composting more, without receiving any greater credit for preventing waste or donating surplus food, the hierarchy will exist on paper without changing practices. Prevention and redistribution must count for more than processing, rather than merely appear above it in a list.
The case for such an approach extends beyond waste management. India's First Biennial Transparency Report, submitted to the UN Framework Convention on Climate Change (UNFCCC) in 2025, records that the waste sector generated 93.84 million tonnes of CO2-equivalent emissions in 2022—51 per cent more than in 2005. Solid waste disposal alone, including landfills where organic matter such as food decomposes, accounted for close to 29 per cent of these emissions. Methane made up nearly 16 per cent of India's total greenhouse gas emissions that year. The Intergovernmental Panel on Climate Change (IPCC) estimates that methane has roughly 84 times the global-warming potential of CO2 over a 20-year period, making it particularly important to near-term climate action. Since decomposing organic matter is a major source of methane emissions from landfills, preventing food waste and redirecting safe surplus for redistribution can help avert these emissions before they arise.
None of this requires India to adopt another country's model wholesale. It requires the country to build on the framework it has already put in place and apply it to a different question under EBWGR: not simply whether waste was processed, but how far a business went towards preventing it before processing became necessary. The Solid Waste Management Rules, 2026, are still in the early months of implementation. This makes it an opportune moment to introduce such a refinement, while reporting and verification systems are still taking shape.
Views expressed are the author’s own and don’t necessarily reflect those of Down To Earth.