Fighting plastic pollution is a herculean task in itself. However, on top of fighting to save the planet and the people from the impacts of the entire plastic life-cycle, we are confronted with yet another fight. Fighting false solutions to plastic pollution! False solutions are those that do not actually address the problem at hand, but mislead people into believing they do, while also causing additional significant problems. The latest to the list of false solutions for the plastic pollution problem are the âPlastic Creditsâ a.k.a âExtended Producer Responsibility (EPR) certificatesâ in India.Â
What are plastic credits?Â
Plastic credit is a transferable unit that represents one tonne of plastic ârecycledâ (more on this later!) to generate a credit. A company then purchases that credit to offset one tonne of their plastic use. In India, this exchange is facilitated by the Central Pollution Control Board ( CPCB) which provides what are called â Extended Producer Responsibility (EPR) certificatesâ for different categories of plastic. It allows businesses to claim to “balance” or âoffsetâ their plastic footprint by purchasing credits that cover the cost of removing plastic from the environment in proportion to their plastic pollution footprint. The promise is that acquiring credits funds an activity that would not have occurred otherwise. The idea of âPlastic Creditâ draws significant inspiration from the failed âCarbon Creditâ program that emerged from the United Nations Framework Convention on Climate Change (UNFCCC). A Guardian investigation published in 2023 found that more than 90% of rainforest carbon offsets are worthless and could potentially exacerbate global warming. Similarly, the plastic credits system is designed to have loopholes for companies to escape real action on plastic pollution.Â
The myth of recycling our way out of plastic pollution-Â
Many people around the world now believe that we can just keep consuming as we have always done, as long as we properly recycle. Thanks to the strong greenwashing and investment heavy marketing machines of certain corporations. However, the myth peddled by the plastics conglomerate has been busted by several reports (here, here and here) which list the top reasons why recycling is not only ineffective but also destructive. It is because they are extremely difficult to collect, virtually impossible to sort for recycling, environmentally harmful to reprocess, often made of and contaminated by toxic materials, and not economical to recycle. There is more bad news for the advocates of plastic recycling. Numerous studies have stated the presence of toxic chemicals in recycled plastic products. The Canadian Governmentâs 2021 report highlighted the toxicity risks in recycled plastic, which prevents âthe vast majority of plastic products and packaging producedâ from being recycled into food-grade packaging. A study conducted by Toxics link in Delhi found that 87% of toys and 67% of the Food Contact Materials made from recycled plastics had toxic chemicals such as Bisphenol- A/ heavy metals/Chlorinated Paraffins. While India is pushing for plastics recycling at domestic and international platforms, this study indicates that it is not safe and puts the health of millions of people at jeopardy.Â
The Extended Producer Responsibility (EPR) certificates in India-Â
The Plastic Waste Management (PWM) rules released in 2016 to address the plastic pollution problem. But subsequently, it has been amended (read diluted!) eight times, in eight years.The final decimation of the PMW rules came when the Extended Producer Responsibility (EPR) guidelines were issued in 2022. Companies or Producers/Importers/Brand Owners (PIBOs) could purchase category wise EPR certificates for the different plastics that they produced from authorized recyclers. However, this was against the original idea of âminimizing plastic wasteâ.Â
Apples and oranges: Plastic credits or the EPR certificates are not location sensitive. Locations where plastic is difficult to collect and recycle (example- from hilly regions, villages, islands etc) will continue to get polluted because the companies or Producers/Importers/Brand Owners (PIBOs) will be able to offset it by recycling plastic in other locations where it is easier to collect and recycle (example- from metropolitan cities or city corporations).Â
The Modus Operandi of getting fake EPR certificates: Offset markets are not only complicated, scattered, and difficult to regulate but also often lead to fraud. In 2023, a random inspection by the Central Pollution Control Board (CPCB) in Gujarat, Maharashtra and Karnataka found that Producers/Importers/Brand Owners (PIBOs) had purchased fake EPR certificates which claimed to have recycled about 6,93,662 tons of plastic waste. The CPCB levied a fine of 355 crores on the four plastic waste recyclers for violating the norms and selling fake EPR certificates. âJust four companies were able to create fake EPR recycling certificates of about 7 lakh tons of plastic waste. This is just the tip of the iceberg and physical inspection of all the 2355 registered Plastic Waste Recyclers (PWR) by the CPCB will reveal that the scam is several times biggerâ, said a plastic recycler who chose to remain anonymous. Other random inspections in Gujarat and Maharashtra revealed that Plastic Waste Recyclers (PWR) were uploading fake invoices, photographs and videos and overreporting employees to generate fake EPR certificates.Â
No additional recycling: Additionality or âadditional recyclingâ is at the core of all EPR certificates and plastic offsetting. It means that the plastic recycling would not have occurred without revenue from the sale of EPR certificates. If the recycling would have happened anyway â i.e., without any prospect for project owners to sell EPR credits â then they are not additional. âEPR certificates can be generated for as low as 50 paise to 2 rupees per kg and this does not help in additional recycling in any wayâ, says a recycler who engages in the EPR business. The more fundamental issue is the proving of additionality given that research from Berkeley, Oxford, and Carbon Plan found that 85% of offsets sold today are not additional. Furthermore, responsibility of managing the plastic pollution cannot be reduced to mere âadditionalâ recycling.
Burning plastics to generate EPR certificates!Â
According to the National Green Tribunal (NGT), no unregulated open burning of plastic is allowed in the country. However, the EPR certification legalizes the burning of plastics in the guise of âco-processingâ and âwaste to energyâ and even incentivises it. The EPR targets for recycling plastics in the year 2024 is 100% according to the PWM rules. But the euphoria of the rules and it’s impact is short lived and giddiness strikes when we learn that PBIOs are mandated to recycle only 30% of the EPR target and the rest of the 70% of their target can be met by burning plastics in waste-to-energy incineration or cement co-processing plants. Recycling (technically downcycling) is the process of converting post-consumption plastic waste into new materials/products. This is very different from using plastic waste to recover energy by burning it. The Extended Producer âResponsibilityâ rules allows for plastic producers/brand owners to use this glaring loop hole to burn more plastic. As a result, the four waste to energy incineration plants in Delhi were incentivized for burning 7,35,840 tons of plastic âresponsiblyâ in the FY 2022-23. No questions asked about why the most polluted capital in the world burns about 20,00,000 kg of plastic everyday or about one fifth of the plastic waste generated by our country . No questions asked on how burning plastics a.k.a fossil fuel which jeopardizes the health, environment and climate is seen as âresponsibleâ. Despite the National green tribunal imposing hefty fines on these WTE incineration plants which released upto 890% more dioxins and furans, a carcinogen, the Delhi Solid Waste Management Committee has proposed the doubling of WTE incineration capacity and burn double the amount of plastics by 2027. Burning of plastics as a way of waste management is irresponsible. No, it is unacceptable!
The Plastic Waste Management (PWM) rules talks about all the forms of management from recycling to end of life disposal, while clandestinely leaving out the most-preferred option of plastic production and consumption minimisation. Companies should not be able to cheaply âbuyâ their way out of their responsibility to the plastic they make by purchasing plastic credits. The plastic waste management rules need to cover the full life-cycle of plastics by controlling the production of primary plastic polymers, phasing out all single use plastics, deploying reusable and refillable alternatives and controlling the chemicals used in plastics.Â
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