How bad is India’s single-use plastic crisis?

On June 5, 2018, to mark the World Environment Day, Prime Minister Narendra Modi announced that India would phase out single-use plastics by 2022. Three years later, on August 12, 2021, a ban on identified single-use plastic items was notified by the Ministry of Environment, Forest and Climate Change (MOEFCC) vide the Plastic Waste Management Amendment Rules, 2021. It came into force on July 1, 2022.

Newspapers claimed that India had banned single-use plastics. The reality, however, was that India had banned 19 selected single-use plastic items while a lot more were in circulation and continue to be. Incidentally, the August notification was also the first time India defined single-use plastic, as a “plastic item intended to be used once for the same purpose before being disposed of or recycled.” This is an oversimplified definition as it does not distinguish between necessary and unnecessary plastics or between recyclable and non-recyclable plastics. Unnecessary and non-recyclable plastics need to be phased out on priority. However, a significant amount of nonrecyclable plastics that are problematic—for instance, multi-layered packaging—have been allowed to still circulate on the basis of the rationale that we do not have alternatives for those plastics.

The identification of single-use plastic items to be phased out was done on the basis of a report by an expert committee on single-use plastics constituted by the Department of Chemicals and Petrochemicals (DCPC) under the direction of the Union Ministry of Chemicals and Fertilizers. The assessment was conducted by DCPC by comparing two pillars—the Utility Index of a specific type of single-use plastic and its Environmental Impact. But some items that are low on Utility Index and high on Environmental Impact as per the scores assigned by the study, have not been considered for phasing out. This leaves big corporations least affected. It is unclear what yardstick was actually considered for the items listed for phasing out.

The annual share of banned single-use plastic items is roughly 0.6 million tonnes per year. The remaining single-use plastic items, comprising mostly packaging products, are covered under the Extended Producer Responsibility (EPR) policy introduced by the Ministry of Environment, Forest and Climate Change (MOEFCC) in 2022. The EPR policy specifies targets collection and recycling, ignoring the fact that some single-use plastics that are not banned (such as multilayered packaging) are non-recyclable.

According to the report Plastic Waste Makers Index 2019, India was the thirteenth-largest investor in single-use plastic polymer production globally. India’s Reliance Industries—producing 3 million tonne of single-use plastic waste—stood eighth in the list of companies producing polymers. India ranked third globally, contributing 5.5 million tonnes of single-use plastic (SUP) waste, and ranked ninety-fourth with per capita single-use plastic waste of 4 kg per year, indicating that the SUP ban in India addresses roughly 11 per cent of the entire gamut of single-use plastic waste.

The United Nations Environment Programme (UNEP)’s country-wise plastic data revealed that India mismanages 85 per cent of its plastic waste. This waste, predominantly single-use in nature, is dumped or even burnt at roadsides, choking drains and flowing into the rivers from where it disperses into the ocean, harming marine life directly or indirectly as it degrades into micro- and nano-sized particles over months, years and decades. Emissions from the production, use and disposal of single-use plastics are significant in their contributions in degrading the country’s environment.

To deal with this issue and phase out single-use plastics, Central Pollution Control Board (CPCB) issued a Comprehensive Action Plan on February 1, 2022 to all the State Pollution Control Boards (SPCBs) and the Pollution Control Committees (PCCs). The Action Plan comprises four parts:

Part A: Supply-side interventions

• Stopping supply of plastic raw materials
• Stopping manufacture of banned SUP items
• Stopping sale of banned SUP items

Part B: Demand-side interventions

• Stopping usage of banned SUP items: CPCB issued directions to 18 plastic raw-material manufacturers, nine sellers of single-use plastics and 30 e-commerce companies for phasing out single-use plastics. Additionally, letters were issued to all SPCBs and PCCs, Chief Secretaries of all the states, and customs authorities (for regulating/stopping import).

Part C: Creating an enabling environment for phasing out single-use plastics

• Promoting alternatives to single-use plastics (SUPs)
• Creating awareness on phasing out SUPs

Part D: Managing SUP legacy waste

• The last part of the Action Plan focused on developing guidance documents for various processing technologies available in the Indian market.
• For effective monitoring of the ban on identified single-use plastic items and plastic waste management in the country, the following online platforms are in operation:
• CPCB monitoring module for compliance on elimination of single-use plastic
• CPCB grievance redressal app

To understand the extent of implementation and enforcement of the ban on single-use plastic items across the country, research team of the Centre for Science and Environment (CSE) conducted three different surveys, with a blend of digital means and interaction with stakeholders such as citizens, retailers and street vendors. The surveys aimed to understand the following:

• The implementation of the SUP ban across the country;
• Perception of citizens; and Practices followed by small and medium businesses The key findings of the survey were:
• The enforcement of the ban on single-use plastics has been poor and needs to be strengthened. Enforcement by SPCBs and local governments alike to ensure closure of units producing or manufacturing banned SUP items has been lax. Retailers and street vendors continue to be levied with Environmental Compensation by officials of urban local bodies while units producing and selling single-use plastic items continue to manufacture them uninterruptedly. The provisions mentioned in the Comprehensive Action Plan, especially the deliverables that were to be implemented on the ground—for instance, structured market survey and structured field inspections—have not been adhered to and there is no update from the responsible authority on the assigned task.
• Awareness campaigns were intensive only during the initial months of the ban, and have nosedived post August 2022. This is reflected in the number of complaints that dropped from an average of more than 700 in September 2022 to less than 100 in March 2023, a fall of 85 per cent.
• There is no data on the number of manufacturers and/or producers who were fined either by the SPCB/PCC or by CPCB. There is also no inventory of which of the fined manufacturers is still operational. Consolidated data for the amount collected and street vendors/retailers fined is available upon request but not readily in the public domain. While the Environmental Compensation issued by the CPCB gives a clear indication in terms of monetary and legal action, no such update has been issued by CPCB with regard to how many producers, stockists/distributors, importers or commercial establishments have been fined or the nature of action taken against violators. During the enforcement campaign, non-compliance with the ban on identified single-use plastics was found in commercial establishments, including small shops in local markets. Action has been taken on the deviations, which include seizure of banned single-use plastic items and levy of penalty. As per available information, the penalty levied during the enforcement campaigns was approximately Rs 5,81,78,001, and 775,577 kg of material was seized. Most of the updates from the authorities revolve around the inspections done in local markets and among street vendors. Enough has not been done—or at least reported—to stop the production of single-use plastics at the source.
• Carry bags (below 120 micron) continue to be the most widely circulated banned single-use plastic item. Almost a third of all banned single-use plastics made available are carry bags. India has failed to choose its position in the fight between becoming single-use-plastic free or promoting plastic to boost its economy. While on one hand India commits to making itself single-use-plastic free, on the other it still wants to see plastic carry bags in its market.
• The market for plastic alternatives is severely underdeveloped and enough is not being done by the Central and state governments to push it.

We should be mindful that the solutions we provide today do not end up creating a fresh stream of waste management issues in the coming years. In that light, CSE suggests these as the ways forward to deal with this issue:

Enforce the laws: Capacity building of government officials, especially those authorised to issue challans, needs to be upgraded with regard to what to look for when they visit a certain type of establishment for a structured field inspection. Inspection teams should also be equipped with instruments such as gauge meters. This has only been done in Delhi in selected locations for very specific periods of time, while officials from other local governments were not even aware that such an instrument exists. Reporting should be facilitated on the scale at which inspections were done in various facilities.

Mandatory public disclosure of environmental compensation levied and units shut/fined every quarter on the SPCB/PCC website: Local governments and states should be mandated by the CPCB and MOEFCC to put out quarterly updates on their websites in the format provided to the Chairmen of all the SPCB/PCCs. CPCB required that states submit a report on enforcement every fortnight. There is no update, however, on the information sought by CPCB, raising concerns about the functionality of the Comprehensive Action Plan.

There should be provision to include the information sought in the Annual Report published by the CPCB as per the Plastic Waste Management Rules, 2016. CPCB will have to start sharing the data that it collects from private players through the EPR and the state authorities through the SUP monitoring module.

Stop the micron business: Carry bags irrespective of thickness should be banned. This has been done successfully in countries that are weaker economies than India such as various East African countries, for example, Tanzania and Rwanda. The Indian state of Himachal Pradesh through its Non-biodegradable Garbage Control Act of 1998 has completely banned the production, distribution, storage and use of carry bags. This is not just a policy on paper but has been implemented at scale in the entire state of Himachal Pradesh.

Plastic carry bags seem relatively cheap. However, this price fails to account for the full cost imposed across the plastic life cycle. As per a 2021 World Wildlife Fund report, Plastics: The Costs to Society, the Environment and the Economy, “The lifetime cost of the plastic produced in 2019 will be at least US $3.7 trillion, which is more than the GDP of India.” The lifetime cost includes the cost for management of waste, cost incurred due to loss of ecosystems, health costs and mitigation measures to fight plastic pollution and climate change.

Invest in the SUP alternative market by creating avenues like subsidies and reduced tax rates for banned SUP item alternatives to compete with banned conventional plastic items: One of the key reasons why we have not been able to shift away from SUP is the lack of alternatives in the market. The market will shift only when similar cost-effective and convenient options are available. Currently, however, substitutes are not widely available in large volumes. A major reason for this is the government’s failure to promote the alternative industry over the past years while continuing to attempt bans at the national and state levels. Moreover, there is no supportive infrastructure or incentives provided that would encourage the production of alternatives in large volumes. Therefore, the plastic-alternatives industry remains a niche business, with the government having no measures to mainstream it.

This was first published in the State of India’s Environment 2024

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