Waste grows, producer responsibility falls short

Fourteen years after introducing the EPR policy, India’s recycling industry still depends on patchy systems, informal networks and changing regulations

Bengaluru: A pan-India soft drink brand reported a sale of Rs 20,008 crore last year and claimed an 88 per cent PET bottle recycling rate. However, in Bengaluru, one of its biggest markets, there is no mechanism in place for collecting or buying back used bottles.

This is not an exception. Across brands in various sectors, packaging material and post-consumer waste are rarely collected unless they have significant monetary value.

To address this accountability gap, the country introduced Extended Producer Responsibility (EPR) in 2011, with an aim to make producers responsible for the scientific collection, recycling and disposal of their products after sale and consumption. However, implementation of this policy is still evolving even after 14 years. 

EPR seeks to formalise recycling by introducing the ‘polluter pays’ principle. Since the cost of procuring, transporting and recycling waste often exceeds the value of the end product, EPR mandates that producers of various appliances, plastic packaging and tyres pay for responsible disposal. 

To achieve this, producers can have direct tie-ups with recyclers for material recovery and documentation of waste produced and recycled. Another way of fulfilling this responsibility is through Producer Responsibility Organisations (PROs) that manage the process end-to-end. Producers can also use digital platforms that offer real-time traceability, recycler verification, and Central Pollution Control Board-compliant documentation. EPR credits are a way to cash in on this value chain, where those who are engaged in the service are rewarded monetarily, and producers use them to prove compliance.

The EPR portal, launched in 2021, initially had loopholes that allowed many vendors from Gujarat, Maharashtra and Karnataka to generate fake certificates. The Central Pollution Control Board (CPCB) has now fixed the problems. Dileep Kumar S, co-founder of Peenya-based 4R Recycling Private Limited, explained that some recyclers pay for the material collected from corporates. As a result, the focus is on materials that can yield high-value metals in the recovery process. 

This also means that recyclers tend to exclude low-value e-waste like electric bulbs, which are particularly challenging to transport and recycle.

“EPR process channelises the materials away from the informal sector,” says Abhishek Agashe, chief executive officer of Elima. This Hyderabad-based firm acts as both an e-waste recycler and a producer responsibility organisation for battery waste, tyres, and plastic waste.

“The quality of materials we produce from e-waste is higher, so is the cost. Formal recyclers incur higher costs due to mandatory certifications, processing infrastructure, audit mechanisms, labour welfare etc,” explained Abhishek. 

The informal sector avoids these costs, making the products cheaper but less accountable. “The EPR framework covers the cost gap between the formal and informal sectors,” he explained.

Recykal, a cleantech startup in Hyderabad, runs a digital platform that enables digital audit with supporting documentation such as weighbridge slips, e-way bills and geo-tagged photos. “Brands can select the model that best aligns with their operational scale and compliance maturity, while ensuring traceability and audit readiness,” said Ekta Narain, co-founder, Recykal. Abhishek says the EPR’s objectives are sound, but its implementation is inconsistent and ineffective. 

Implementation is also dependent on state pollution control boards. A company like Elima, which collects e-waste from across the country, must comply with the rules set by various state boards, which may not be uniform. For instance, some states insist on recycling by local operators, whereas central rules allow transboundary movement of waste for processing.

“If implementation is standardised across the states, it would help EPR businesses achieve better compliance,” said Abhishek.

While CPCB has launched dedicated EPR portals for various categories, inconsistencies persist. Varying interpretations of rules by state pollution control boards, delays in approvals or registration renewals and poor digital coordination between CPCB and SPCBs on verification and field-level enforcement are some key challenges.

“Confusion surrounding the distinction between authorised credits and unverified documentation, as well as consumer waste collection obligations, hinder EPR’s effective implementation,” said Ekta.

Are producers meeting their targets honestly, or are loopholes being exploited? Ekta says there is a growing push for transparency, especially with the mandatory EPR portal reporting and the Environmental Compensation (EC) clause that specifies the monetary penalty imposed on producers, importers, or brand owners (PIBOs) who fail to meet their EPR obligations within a specified time.

While many leading brands are actively working towards achieving full compliance, there are still challenges in ground-level verification, and there have been instances where non-compliant recyclers were given duplicate credits.

“Fulfillments are sometimes done through unverified channels, and some smaller producers rely on proxy documentation without traceable material movement,” she said.

Abhishek believes that there needs to be better compliance within the industry as well, and the culture of shortcuts must cease.

Frequent policy changes

EPR frameworks are evolving consistently. “In 2012, there were very few categories in e-waste. Now there are over 100,” says Dileep Kumar. However, frequent policy changes create uncertainty.

The amendments in 2024 to India’s e-waste rules under the E-Waste (Management) Rules, 2022, fixed a floor price of 22 per kg for general e-waste that producers must pay to recyclers to obtain EPR certificates. 

Electronic majors, such as Samsung, LG and others, have challenged this in court, saying it inflates the costs. They argued that the government should allow the market to decide the price.

The case is pending in court, and the outcome will determine the course of e-waste EPR. “This has led to a funding gap in the market. The uncertainty has made recycling businesses freeze investments,” said Abhishek.

“Frequent changes in the policy pose challenges in implementation. We need to have fixed frameworks for 4-5 years before changing, it helps the businesses invest in collection, transportation and processing systems,” Abhishek pointed out.

CPCB’s reported plan to privatise and auction EPR credits has also drawn criticism. “The lowest bidder gets the most amount of business. But EPR needs compliance. How do you build compliance into this auctioneering model?” Abhishek asks, suggesting that market-driven recycling could be a step back from the existing system.

India’s textile industry will need EPR as the country's fast fashion boom is generating large quantities of textile waste, said Abhishek. Currently, cloth is often reused or upcycled, being handed down or given away to other people.

“How do you build a supply chain for this? How to incorporate all these processes into EPR? The material is not homogeneous. There is no technology to process them at scale. Developing a supply chain and a market for the end products is critical at this stage,” observes Abhishek.

EPR credits for households

In a 2022 compliance audit report, the CAG directed the CPCB and state PCBs to identify and register all PIBOs operating under their jurisdiction, to comply with the provisions of the EPR.

Kerala became one of the first states to implement EPR, while taking a step further by integrating households into the EPR chain. The state generates approximately 2.5 million tonnes of waste annually.

In 2024, the state launched door-to-door collection of e-waste and other solid waste, providing EPR credits to households. So far, Rs 8.84 lakh has been given to households through the Harita Karma Sena volunteers. 

Clean Kerala Company works as the nodal agency for e-waste collection. Kerala State Pollution Control Board has been engaged in the process of registering all entities mandated under EPR and ensuring the compliance aspects of waste management. 

Local self-government institutions are responsible for collecting and segregating waste at the ground level, while designated agencies are entrusted with recycling tasks.

The Kerala local self-government department brought out the Extended Producer Responsibility policy in July 2025. The key objectives are to give incentives to producers to reduce waste and to invest in recycling initiatives. 

The state is yet to initiate aggressive enforcement, industry sources said. Activists in the field say that, due to a lack of effective monitoring systems, the PCB relies heavily on the data provided by the producers and PROs.

Ram Prasad V, a Bengaluru-based waste management consultant, says EPR credits should be given to households in Bengaluru as well. Bangalore Solid Waste Management Limited (BSWML), which collects the user fee, can award a portion of EPR credits to households in the form of a fee discount. 

In fact, BSWML officials were also keen on this, but sources say registration on the CPCB portal took a backseat for reasons unknown. The fact that the garbage fee-collecting authority is the corporation and not the BSWML has only complicated the situation.

Karnataka Power Corporation Limited (KPCL) is in the process of registering as a plastic waste processor through its waste-to-energy plant in Bidadi.  

Rajesh Babu, co-founder of Swachha, a non-profit focused on waste management, views the rise of producer responsibility organisations as a trend that can hinder urban local bodies (ULBs) from acting as PROs and generating revenue from it. “Only the municipality of Indore has been successful in doing this,” he says, adding that there is no political will and intent among ULBs even when there is good potential to earn money and enforce responsibility. 

What needs to be done?

The Securities and Exchange Board of India (SEBI) has mandated environment, social, and governance (ESG) reporting for 1,000 listed companies on the National Stock Exchange. Smitha Venkatesh, an independent ESG consultant, describes this as a progressive step as it involves the supply chains of micro, small and medium-sized industries. 

“However, internal departments in most micro, small and medium enterprises are unaware of EPR guidelines and mandates. There needs to be a lot more awareness,” she said.

Dileep Kumar highlighted an important aspect. “We recyclers do not have a sector. When we go to a bank and ask for loans, we fall under the category of traders, so we are unable to avail ourselves of any schemes and incentives meant for specific sectors. Naturally, we are charged higher interest rates,” he said. He added that categorisation of the recycling industry as a green industry that contributes to the circular economy would help better implementation of EPR.

He added that there is no clarity on who should receive carbon credits for recycling—whether it should be the producer who pays for recycling, or the recycler who actually does it. 

According to Thiruvananthapuram-based environmental activist K N Shibu, the key drawback of EPR implementation is that those associated with framing the policies and setting targets are generally senior bureaucrats of the Union government and corporate representatives. “There should be greater representation of states in the development of guidelines for EPR implementation,” he said.

“We have seen promising traction where regulators are open to collaborating with technology platforms to enable standardised compliance. We believe that collaborative governance, where tech providers, regulators, and stakeholders work in sync, is key to building trust and scalability in India’s EPR landscape,” said Ekta.

(With inputs from S N V Sudhir in Hyderabad and Arjun Raghunath in Thiruvananthapuram)