Analysing Plastic Waste Management in India

IIIEE Reports 2001:11
Analysing Plastic Waste Management in India

Case study of Polybags and PET bottles
Priya Narayan
Supervisors
Thomas Lindhqvist
Naoko Tojo
Thesis for the fulfilment of the

Master of Science in Environmental Management and Policy
Lund, Sweden, September 2001
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Acknowledgements
I would like to express my gratitude to my supervisor Thomas Lindhqvist, professor at IIIEE, who
encouraged me to undertake this study and also extended the necessary financial assistance from the
institute. His ability to understand and work with people from diverse backgrounds is really impressive.
Working closely with him has given me the chance to appreciate his sharp intellect as well as his warm and
helpful nature.
I would also like to thank Naoko Tojo, Research Scholar at IIIEE, for her active involvement in my
research work, her enthusiasm in reviewing my drafts, and for giving me valuable insights. Your patience
and support is greatly appreciated.
Thanks are also due to Mr Shisher Kumra, Research Scholar at IIIEE, for providing me with an
opportunity to participate in the seminar held at Nagpur, India.
This study could not have been successful without the valuable input of the various stakeholders in India.
I would like to thank all the industry associations, NGOs, Central Pollution Control Board, and related
agencies, for sparing their valuable time to participate in the interviews. This work was also immensely
benefited through the stimulating discussions with Dr Indrani Chandrashekhar, Mr. O.P. Ratra, Ms.
Nidhijamwal, Mr. Ravi Agarwal, Ms. Bharati Chaturvedi, Dr Basu, Mr Achrekar, Mr. Vijay Merchant, and
Mrs Priya Ubale. They provided me with the necessary information/data and advice, and many thanks are
due for the same.
I would like to appreciate the efforts of Rachel Kellett in providing me with the needed contacts of the
various organisations working in related areas. Your prompt emails and suggestions have been really
helpful.
During the hot days in Delhi, I was fortunate to have my parents with me and their support and
encouragement has been tremendous. Special thanks are due to my father for sharing his thoughts and
also providing me a conducive environment for the study. I am also profoundly grateful to my mother for
the unconditional care and support during my work on this thesis.
A special mention must be made of a good friend Deepak Jain whose constant advice has helped me gain
tremendous self-confidence.
Thanks to Ole, Annette, Uma and Bharath for their timely help throughout the Masters Programme. Last
but not the least I would like to acknowledge my dear friend Sauti Sen who has helped me through my ups
and downs in the 14-month Master programme.
iii
Abstract
The rapid rate of urbanisation in India has led to increasing plastic waste generation. This increase has
resulted in a large amount of plastic waste, particularly plastic bags and PET bottles, being littered on the
landscape of India. In this context, research has been carried out to contribute to the development of
efficient policy approaches on plastic waste in India. Few policies have been enforced by the government
to address the acute problem of littering in the country. These polices on plastic waste have been analysed
with particular reference to Mumbai as a case study. The strengths, weakness and missing links of the
existing policies were identified. The analysis has revealed that the existing policies on plastic waste have
not been able to address the issue of littering, primarily because these have not attempted to provide a
long-term solution to the problem. In the case of PET the lack of legislation to manage the rising
consumption has been identified as the key problem. Based on the analysis a few policy recommendations
have been made that could assist decision-makers in their efforts to develop a comprehensive plan of
action for plastic waste management.
v
Executive Summary
The rapid rate of urbanisation throughout the world has led to the creation of increasing amounts of waste
and this in turn poses greater difficulties for disposal. The problem is more acute in developing countries
such as India, where economic growth as well as urbanisation is quite rapid. Often post consumer waste is
associated with packaging, which in turn finds an association with plastics. Plastics have become a major
threat due to their non-biodegradability and high visibility in the waste stream. Their presence in the waste
stream poses a serious problem when there is lack of efficient end of life management of plastic waste.
Plastic waste has attracted widespread attention in India, particularly in the last five years, due to the
widespread littering of plastics on the landscape of India. The environmental issues due to plastic waste
arise predominantly due to the throwaway culture that plastics propagate, and also the lack of an efficient
waste management system. Problems have been identified in the collection, transportation and disposal,
and these primarily arise due to the inefficiency of the municipalities. Municipalities, who are responsible
for collection, have failed in fulfilling their responsibilities in the face of increasing amounts of waste, and
the scarcity of budget for waste management.
In parallel to the formal system, are the wastepickers, who value much plastic waste since it represents a
source of livelihood. However, plastic carry bags and PET do not figure in their priorities, because
collecting them is not profitable. This is primarily because the rewards do not match the efforts required
for collection, and this leads to plastic bags and PET continuing to pose a major threat to the
environment. With the formal and informal sector failing to collect such waste, India’s landscape is littered
with polybags and PET, with polybags dominating the litter. Polybags in particular have been a focus,
because it has contributed to host of problems in India such as choked sewers, animal deaths and clogged
soils.
Besides littering, problems also exist in the plastic recycling industry in India. Plastic recycling presents a
unique scenario in India. The recycling units are dispersed between the formal and the informal sector.
Polybag recycling is carried out predominantly by the informal units, which are characterized by outdated
technologies, unskilled labour, and poor health and safety conditions for workers. Hence the quality of the
recycled products from this sector is very poor.
In this context, a research study was carried out in an urban metropolis in India to contribute to the
development of efficient policy approaches for plastic waste management in India. Existing policies on
plastic waste were analysed, and the strengths and weaknesses of the policies were discussed with
particular reference to Mumbai as a case study. In order to aid a systematic analysis of the existing policies,
a framework was developed based on the characteristics of sustainable policies.
The only comprehensive Rule on plastic waste in India is the Recycled Plastic Manufacture and Usage
Rule. The Rule was passed to reduce the health risk associated with polybags and alleviate the problem of
littering in the country. The Rule attempts to attain these objectives by increasing the thickness of virgin
plastic bags and restricting the use of coloured recycled plastic bags
Detailed analysis of the Rule has revealed that it has not been effective in mitigating littering and its
associated problems, primarily because it has been a reactive solution. Further, the case study of Mumbai
shows, that despite adequate enforcement, littering continues to remain a major problem, which indicates
the inherent lacunae in the design of the policy.
The Rule attempts to address the problem of littering only by encouraging the recycling and reuse of
polybags, while ignoring the goal of reducing plastic waste. Such an approach only serves to further
unnecessary consumerism. Further, the Rule, by increasing the thickness of plastic bags has skirted the real
problem, of reducing plastic waste generated. So the failure to incorporate a long-term solution to the
problem of littering has been the key limitation of existing policies.
vii
Priya Narayan, IIIEE, Lund University
The problem of littering has predominantly arisen due to indiscriminate use and disposal, and the lack of
an efficient waste management system. The policy fails to prevent this indiscriminate use by creating
suitable disincentive towards use of polybags. Further, there are technical and economic weaknesses with
the existing substitutes, and no provisions have been made to improve their performance, and to make
them cost effective to the consumer.
Also, the Rule fails to make provisions for improving the existing waste management system in India. The
Indian waste management system is starved of resources when the demands of increasing urbanisation are
taken into account. There are several bottlenecks that need to be addressed in the existing system, and
these require adequate financial resources, but the policy makes no mention of how such resources can be
mobilised.
In addition to the fact that the policy lacks beneficial elements to minimise littering, it worsens the existing
situation by pushing more virgin plastics into the system. The beneficiaries from this are the virgin plastic
industries, which have no roles and responsibilities defined in the Recycling Manufacture and Usage Rule.
Instead the Rule comes down hard on the recycling industry that is doing a good job for the environment
by recycling. By encouraging recycling we aim to reduce the speed and volume at which we consume our
finite resource. The whole idea of resource conservation has been completely overlooked in the existing
policy on plastic waste.
Since there is no policy on PET waste in India, various issues associated with PET waste and recycling
have been discussed. In the case of PET bottles, the rising consumption is associated with the lack of
clean water supplies in the country. The key problem identified was the limited incentives for the waste
pickers to collect them, since they represent low value in the trade. Information has been available on one
of the PET recycling units in the country that recycles PET waste into polystyrene fibres by importing
PET waste. Given the fact such recycling does not require clean PET waste, the author is unsure as to why
local PET waste has not been attractive to them. Further, the packers and fillers have no incentives to
utilise the 1 litre and 500 ml bottles that contribute extensively to the litter, as they are thin and cannot be
reused. Therefore, the lack of a comprehensive legislation on PET waste to manage the rising
consumption is the cause for the widespread littering.
Considering that a number of marginal and poor segments characterise the waste management system in
India, any policy aimed at strengthening the waste management process, besides being cost-efficient and
beneficial to society, should create income generating opportunities for the poor.
Keeping this in mind, a few recommendations have been made that may assist in formulating future
policies for plastic waste management. Polybags clearly present a problem of downstream consumption.
So it would be useful to consider measures such as environmental tax (termed as a cess in India) that can
minimise consumption and at the same time generate revenues that could be utilised for improving the
plastic waste management system as well for research and development activities.
Reform of the waste management system by decentralising the process and involving the waste pickers
clearly represents a long-term strategy; since it creates benefits for the municipalities, waste generators and
wastepickers. Such a reorganisation would also help to ensure better quality of waste for recycling.
Reorganisation of the recycling sector would help to effectively utilise the waste available through source
separation and thereby improve the quality of recycled products to an extent that they can impinge on the
virgin market.
Incineration coupled with energy recovery, which has received great support from the industry and
Government in India, could minimise the immediate waste disposal problems in India; but this could also
aggravate pollution problems if strict standards are not enforced. Further there are huge costs associated
with incineration, if it has to be profitable and carried out in an environmentally friendly manner. Another
key aspect is composition of municipal solid waste in India. The waste has a very low calorific value that
viii
makes it unsuitable for the production of energy. So additional fuel may be required to carry out
incineration effectively. This would further add to the costs associated with incineration. Another
important implication arsing from introduction of incineration in India, is that it may adversely affect the
recycling industry.
In case of PET, a deposit refund system has been proposed that may bring about effective collection and
recycling. The availability of clean PET waste could also stimulate bottle-to-bottle recycling thereby
minimising virgin PET consumption. However a long-term solution would be to minimise PET
consumption by ensuring clean water supplies to all in the country.
Sustainable products have also attracted attention in the last few years, and there is extensive research
underway to identify products that can fulfil material needs in sustainable ways. In this context, bioplastics
have also been discussed as a possible option. Although there are several factors that impede the adoption
of bioplastics on a large scale today, extensive research may help to ensure that plastics of the future will
be bioplastics.
However, realising all the beneficial policy objectives necessitates an active participation and cooperation
of all the stakeholders at various levels. Wise governance, working in partnership with the industry and
citizens, is key for any transition to a sustainable society. Only such a strong visionary government, with
the support of the stakeholders, can create innovative policy solutions for plastic waste management, and
these in turn will ensure a sustainable use of plastics in the country.
ix
Table of Contents
LIST OF FIGURES ......................................................................................................................................III
LIST OF TABLES.........................................................................................................................................III
ABBREVIATIONS ....................................................................................................................................... IV
1. INTRODUCTION..................................................................................................................................1
1.1 BACKGROUND ...................................................................................................................................................................1
1.2 PURPOSE..............................................................................................................................................................................1
1.3 SCOPE ..................................................................................................................................................................................2
1.4 METHODOLOGY ................................................................................................................................................................2
1.4.1 Study for developing a framework for policy evaluation.................................................................................................3
1.4.2 Study of the plastic waste management system, its problems, stakeholders and existing policies related to plastic
waste .........................................................................................................................................................................3
1.4.3 Interviews with various stakeholders in the plastic chain...............................................................................................4
1.4.4 Analysis of the information gathered in the above two phases .......................................................................................5
1.5 STRUCTURE OF THE THESIS ............................................................................................................................................5
2. EVALUATION FRAMEWORK ............................................................................................................ 7
2.1 OBJECTIVES OF SUSTAINABLE WASTE POLICIES ........................................................................................................7
2.2 CHARACTERISTICS OF SUSTAINABLE ENVIRONMENTAL POLICIES .........................................................................9
2.2.1 Environmental effectiveness ........................................................................................................................................10
2.2.2 Cost efficiency ............................................................................................................................................................10
2.2.3 Equity ......................................................................................................................................................................10
2.2.4 Administrative feasibility ..........................................................................................................................................11
2.2.5 Social and political acceptability ................................................................................................................................12
2.2.6 Incentives for improvements........................................................................................................................................12
2.3 FRAMEWORK FOR POLICY EVALUATION ....................................................................................................................12
3. PLASTIC INDUSTRY IN INDIA ........................................................................................................15
3.1 SECTOR PROFILE .............................................................................................................................................................15
3.2 PLASTIC CONSUMPTION IN INDIA ...............................................................................................................................16
3.3 PLASTIC WASTE MANAGEMENT IN INDIA .................................................................................................................18
3.3.1 Plastic waste generation .............................................................................................................................................19
3.3.2 Plastic waste collection and disposal ...........................................................................................................................20
3.3.3 Plastic waste recovery and recycling.............................................................................................................................21
3.3.4 Agents involved .........................................................................................................................................................21
3.3.5 Plastic Recycling Industry ..........................................................................................................................................24
3.3.6 Environmental Aspects of Recycling...........................................................................................................................25
3.3.7 Quality of Recycled Products......................................................................................................................................25
3.4 STAKEHOLDERS OF THE PLASTIC WASTE MANAGEMENT SYSTEM.......................................................................26
3.5 PROBLEMS RELATED TO PET AND POLYBAG IN INDIA .........................................................................................28
3.5.1 PET : An emerging problem.....................................................................................................................................30
3.5.2 Polybag: A major concern..........................................................................................................................................31
4. STATUES RELATING TO PLASTIC WASTE MANAGEMENT IN INDIA....................................33
4.1 PLASTIC WASTE MANAGEMENT TASK FORCE ..........................................................................................................33
4.1.1 The Guidelines for Plastics Packaging and Packaging Waste in India.......................................................................33
4.1.2 Guidelines for Recycling of Plastics ............................................................................................................................34
4.2 NATIONAL LAW ON POLYBAG......................................................................................................................................34
4.2.1 Recycled Plastic Manufacture and Usage Rule...........................................................................................................34
I
4.2.2 State specific initiatives.............................................................................................................................................. 34

4.3 ECOMARK PROPOSED SCHEME ON LABELLING OF ENVIRONMENT FRIENDLY PRODUCTS –
PLASTICS ........................................................................................................................................................................ 35
5. ANALYSIS OF THE EXISTING POLICIES.......................................................................................37
5.1 POLYBAGS......................................................................................................................................................................... 37
5.1.1 Recycled Plastic Manufacture and Usage Rule........................................................................................................... 37
5.1.2 Mumbai experience with the Recycling Rule .............................................................................................................. 39
5.2 CONCLUSIONS ON THE CASE STUDY .......................................................................................................................... 48
5.3 INDUSTRY INITIATIVES TO PROTECT ITS IMAGE (ICPE-NAGAR-BMC).............................................................. 49
5.4 POLYETHYLENE TEREPHTHALATE (PET) ................................................................................................................. 51
5.5 ECOMARK SCHEME......................................................................................................................................................... 52
5.6 RESULTS OF THE ANALYSIS ........................................................................................................................................... 52
6. PROPOSED POLICIES .......................................................................................................................55
6.1 ENVIRONMENTAL TAX ON PLASTIC BAGS ................................................................................................................ 55
6.2 INCINERATION WITH ENERGY RECOVERY ............................................................................................................... 56
6.3 SOURCE SEPARATION ..................................................................................................................................................... 59
6.3.1 Decentralising the waste management system.............................................................................................................. 60
6.4 REORGANISATION OF THE RECYCLING SECTOR...................................................................................................... 61
6.5 EXTENDED PRODUCER RESPONSIBILITY .................................................................................................................. 62
6.5.1 Deposit refund system................................................................................................................................................ 62
6.5.2 Organisation of the deposit refund system................................................................................................................... 63
6.6 EMERGENCE OF SUBSTITUTES: BIOPLASTICS (?).......................................................................................................65
6.6.1 Composition of bioplastics ......................................................................................................................................... 65
6.6.2 Advantages of bioplastics in waste management......................................................................................................... 66
6.6.3 Status of bioplastics in India ..................................................................................................................................... 66
6.6.4 Challenges ahead....................................................................................................................................................... 67
6.7 CONCLUDING REMARKS ................................................................................................................................................ 68
7. CONCLUSIONS ...................................................................................................................................69
7.1 FUTURE RESEARCH ......................................................................................................................................................... 71
REFERENCES..............................................................................................................................................73
LIST OF INTERVIEWEES ..........................................................................................................................79
II
List of Figures
Figure 2-1 Linkage between waste prevention and waste minimisation ............................................................8
Figure 2-2 Framework for policy evaluation.........................................................................................................14
Figure 3-1 Structure of the Virgin plastic and Recycling Industry. ...................................................................16
Figure 3-2 Plastic waste management in India......................................................................................................19
Figure 3-3 Problems related to plastics in India...................................................................................................29
List of Tables
Table 3-1 Demand scenario for key commodity plastics in India....................................................................17
Table 3-2 Indian PET market (tonnes)- Current and projected.......................................................................18
Table 3-3 Plastic waste generations in India ........................................................................................................20
Table 3-4 Value addition of plastic waste across the informal sector .............................................................24
Table 3-5 Existing partnerships for managing plastic waste.............................................................................28
Table 4-1 State specific initiatives to address the problem of plastic waste ...................................................35
Table 5-1 Impacts of the Recycling Rule on critical issues ...............................................................................48
Table 6-1 Incentives for a deposit refund system in India................................................................................64
III
Abbreviations
Cess =Tax
CETP: Common Effluent Treatment Plant
CPCB: Central Pollution Control Board
DRS: Deposit Refund System
EPR: Extended Producer Responsibility
Existing policy on plastic waste = policies on plastic waste that have been enforced in India
Formal authorities = Municipality
GOI: Government of India
HDPE: High Density Polyethylene
Informal sector = Wastepickers, Itinerant waste buyers, Bulk buyers, Wholesalers, Polybag recycling units
Kabariwala/Raddiwala = Itinerant Waste Buyers (IWBs)
ICPE: Indian Center for Plastics and Environment
LDPE: Low Density Polyethylene
LLDPE: Linear Low Density Polyethylene
MOEF: Ministry of Environment and Forests
NGO: Non-Governmental Organisation
PET: Polyethylene terephthalate
PE: Polyethylene
PHB: Poly (3-hydroxy butyrate)
PLA: Polylactic acid
Polybags = carry bags made of plastic
PVC: Polyvinyl Chloride
Recycled Plastic Manufacture and Usage Rule = Recycling Rule =Rule
SPCB: State Pollution Control Board
Wastepickers = Ragpickers
The Indian currency is Rupees and 1 Rs =100 paise

The Swedish Conversion to Indian Rupees is 1 SEK =Rs 4.50
The US dollar conversion to Indian Rupees is based on 1 USD = Rs 47
Crore and Lakh are the Indian words for units of 10 million and 100 thousand
100,000 = 1 lakh
10,000,000 =1 crore
IV
1. Introduction
1.1 Background
Increasing amounts of plastic waste are being generated following the rapid rate of urbanisation in
India. Today, there is a staggering demand for plastic products with the rising affluence and public
embracement of western consumerism. However, this expansion of plastic production and
consumption is having a significant impact both visibly and invisibly on the environment and society in
India.
The problems with plastic waste may seem surprising in a country where traditional materials fulfilling
the current role of plastics have existed. The winning factor for plastics is its functional superiority
(convenience) and cost effectiveness. By sheer economies of scale, plastics have eroded the traditional
industries in India and have slowly perpetuated the throwaway culture in the Indian society. The
bottled water, fast food and Pepsi Coke culture in the country contributes to the increasing plastic
waste generation in India. The problem becomes very visible when there is no effective end of life
management to take care of the litter, and this creates an environmental and social problem.
The widespread use of plastics as a packaging medium has resulted in the landscapes of India being
littered with non-biodegradable plastic bags and PET bottles, with plastic bags dominating the litter.
Much plastic waste has a value, and is consequently taken care of by the informal recycling sector.
Market forces guide the informal sector, and they contribute to the waste system immensely by
collecting waste material that has a value, thereby taking over a part of the burden on the municipalities.
Despite the attempts from the formal and the informal sector, significant quantities of the plastic waste
remain uncollected.
Waste management is also constrained by the lack of public awareness and low municipal budgets in
the country. Most municipalities are starved of budgets and this impairs the system of waste collection
and disposal in many cities in India. Even when budgets are adequate for collection, safe disposal
remains a major problem. In essence, inefficient waste management leads to a number of
environmental problems. The situation is more acute in countries such as India where economic
growth as well as urbanisation is quite rapid. In view of the limited resources and availability of land for
disposal, especially in the metropolitan cities, there is a need for a concerted effort to develop cost-
effective and feasible policy options for tackling the waste management problems.
1.2 Purpose
The purpose of the research was to contribute to the development of efficient policy approaches for
plastic waste management in India. In order to do so, it was imperative to understand the issues
relating to plastic waste collection, recycling and disposal in India. It was also imperative to study the
key problems and deficiencies in the policy mechanisms (relating to infrastructure, regulations,
incentives, promotional and technological development aspects) pertaining to waste management of
polybags and PET bottles in India.
Keeping in the mind the primary objective, the research focussed on understanding the following
aspects
• What are the environmental issues of plastic waste and recycling in India?
• What are the existing policies initiatives to address these issues?
1
• What are the strengths and shortcomings of the existing initiatives?
• What policy options can be considered to ameliorate the existing problems?
The research was not intended to prescribe a policy solution, but instead made an attempt to identify
the strengths and weaknesses as well as the missing links in the existing policy mechanism. A few policy
recommendations have also been made based on the analysis. The research findings are expected to
assist decision-makers in the efforts to develop a comprehensive plan of action for plastic waste
management.
1.3 Scope
The scope of the research is limited to the study of plastics as a packaging material, with special
emphasis on polybags and PET bottles. Polybags and PET bottles have been chosen since they
contribute extensively to littering, and pose a serious problem of disposal, especially in metropolitan
cities in India. Other plastics such as PVC and polypropylene that are also used in packaging have not
been considered for the study.
Post consumer plastic waste includes municipal waste, automotive wastes, agricultural wastes and
construction debris, etc. The focus of this study is limited to municipal waste only.
India is a huge country with 26 States (Provinces), and the time frame in which this research was
conducted was too short to study the effectiveness of the existing policies in the entire country.
Considering this, the study focussed on the enforcement of legislation and the initiatives taken by the
NGOs, plastic industry, and the municipality in the city of Mumbai. The city of Mumbai was chosen
for the following reasons:
• Mumbai, is among the largest metropolises in the country, and provides a useful example of
growth driven urban centres in the country faced with increasing urban waste, inadequate
municipal services and scarce resources.
• The city is facing a huge problem of clogged drains during monsoons due to plastic bags.
• The Mumbai Municipality has been proactive in its efforts to address littering problems.
• The Mumbai Municipal Corporation has undertaken measures in association with the industry
and NGOs to address the plastic waste management problems.
The problem of littering has been an issue in all states of India, though the magnitude and size of the
problem varies quite substantially among them. Hence information on the enforcement of the rule in
certain states where the problem of littering has been severe, for instance in tourist states like Goa,
Kashmir and Shimla, efforts of the proactive NGOs in these states as reported by various agencies has
been utilised with the aim of assisting the author in generalising the recommendations. Hence, the
recommendations made in the study can be applied to all states, with suitable modifications based on
the socio-economic, cultural and educational status prevailing in the particular state in India. In
addition, it also provides the other states an opportunity to learn from good practices adopted in
Mumbai.
1.4 Methodology
The research was carried out in four phases.
2
1. Review of literature to develop suitable criteria for analysing the existing policy framework.
2. Review of literature to understand the plastic sector in India, existing plastic waste
management, related problems, stakeholders and existing policies on plastic waste.
3. Confirm the understanding of the existing situation; obtain viewpoints on the problems and
plausible solutions as perceived by the various stakeholders in the plastic chain, through
interviews and face-to-face dialogue.
4. Analysis of the information gathered in the above phases.
1.4.1 Study for developing a framework for policy evaluation

Many developed countries have recognised the need for evolving polices to handle the problem of
packaging waste in a comprehensive manner. Policies relating to plastic packaging waste conform to
this broader framework evolved. However, this is not the case with most developing countries like
India, which are yet to evolve a comprehensive packaging waste policy. Therefore, in evaluating the
existing policy initiatives, it is important to take into account the overall objective of sustainable waste
packaging policies. This will help in analysing the objectives of the existing policy on plastic waste,
while keeping in mind the broader framework of sustainable waste policies.
In order to evaluate the current policy measures on plastic waste, it is also necessary to identify criteria
that are essential features of successful policies. While selecting the criteria for evaluating polices, it is
important to understand the characteristics of a sustainable environmental policy. Though criteria for
evaluating environmental policies in general are well established, applying them to the specific policy
issues pertaining to plastic waste requires prioritisation. The selection of criteria for evaluation is based
on a literature survey of the commonly employed criteria for evaluating environmental policies as
discussed by various authors. Suitable criteria were selected depending on the feasibility of adopting
them for the existing study. Such a framework can help to identify the strengths and weaknesses of the
existing policy measures for sustainable plastic waste management in India.
1.4.2 Study of the plastic waste management system, its problems,

stakeholders and existing policies related to plastic waste
Polybags and PET have been a focus of interest due to the littering problems. Therefore, information
was reviewed to gain an understanding of the following aspects: the plastic chain with emphasis on the
existing plastic waste management practices of polybags and PET, and also the relevant stakeholders
and the partnerships that exist between them for the management of plastic waste. In addition,
emphasis was placed on studying the recycling sector and their constraints in handling polybags and
PET. This provided the author with an understanding of the problems associated with polybag and
PET management.
As the focus of the study is on policies addressing the problem of littering, existing regulations on
plastic waste were studied with the aim of understanding the drivers for the policy, objective of the
policy, scope of the legislation, and the provision of instruments used to achieve the objectives. In
addition, information was gathered on the effectiveness of the legislation as documented by various
stakeholders in the relevant states, and also the problems that are being encountered during the
enforcement of the legislation. This literature survey provided an understanding on the problems
associated with littering, and the measures taken to address the problem in selected states in India.
3
Further, a literature survey was also carried out to identify the specific policy initiatives taken by other
countries relating to plastic waste management. This gave an insight into the policy options that are
available for possible adoption in India based on international experiences.
1.4.3 Interviews with various stakeholders in the plastic chain

In order to confirm the understanding of the problem, the effect of legislation on the various
stakeholders and their viewpoints, an in depth study was conducted for one month in India. Interviews
were carried out with various representatives in the plastic chain consisting of the virgin resin
manufacturers, plastic processors, packers/fillers, consumers, formal waste management authorities
and the informal network from the ragpickers to the recyclers. Additionally, policy makers, NGOs and
research and development agencies were also interviewed. A semi-structured questionnaire facilitated
an interactive dialogue during the interviews, and while providing a general script, also allowed for a
free-flowing discussion. The questionnaires were designed so as to get the relevant data, viewpoints of
various stakeholders on the problem areas, and the feasible recommendation that could help in
mitigating the problem.
The plastic industry has formed associations, which include representatives from the virgin and
processing industry. Heads of the associations were interviewed to get a comprehensive viewpoint on
the industry. The industry is a key stakeholder in the plastic chain, and in recent times, has been in
constant scrutiny by the media and the NGOs, particularly with regard to actions taken to address the
problem of littering. Hence, it is crucial to understand industry initiatives to alleviate the plastic waste
management problem in India.
The recycling sector in India is dispersed between the formal1 and the informal sector2. The PET
recycling units are part of the formal sector, and the polybag recycling units are a part of the informal
sector. Interviews were therefore carried out with recycling units in both sectors. A site visit was also
undertaken to a polybag-recycling unit to understand the procurement of raw materials for recycling,
processing techniques, and also the quality of finished products.
Mumbai was chosen as a case study for this research. Municipalities are responsible for waste collection
and disposal in India. Therefore, officials in the Municipality of Mumbai were interviewed so as to
understand the issues relating to the management of plastic waste, and also the problems encountered
in their proper collection and disposal. As the municipality is charged with the responsibility of
enforcing plastic waste policies, the initiatives taken by them to generate public awareness, and in
implementing the legislation at various levels were studied. Discussions were also held with the State
Pollution Control Board on the problems relating to the enforcement of the legislation, with particular
reference to the plastic recycling industry. As part of the case study, the role of the retailers and
consumers were also considered and representatives of these groups were interviewed to understand
the efficacy of implementation of the existing policies.
Since there is an existing informal network that collects and recycles plastic waste, in parallel to the
formal system, personal discussions were carried about by the author with these individuals, to
understand their concerns and difficulties in collecting PET and polybags. This was essential, as the
informal sector has been responsible for the collection of plastic waste in the country, and this presents
a source of livelihood to a considerable group of people. For the purpose of understanding the
1 Formal recycling units are registered, pay taxes and the municipality has an account of them and they employ labour
formally.
2 Informal units are characterized as those who are not registered with the municipality and who do not pay tax. In addition,
the recycling units employ labourers informally and do not conform to the labour laws prevailing in the country.
4
economic and social factors involved in this trade, a field study was carried out in Dharavi (the largest
plastic trade market in Mumbai) with the various actors in the informal sector.
Interviews with the Central and State Environmental Ministries were also carried out to clarify the
issues relating to the coordination between state and central agencies in enforcing the legislation, and
also to understand the priorities of the Government relating to plastic waste management. The
loopholes in the existing policies, and the active involvement of the informal and private sector in
improving the plastic waste management system, were also taken up with the relevant authorities.
Since the problem of littering is partially due to the lack of public awareness on waste management
aspects, NGOs often play a major role in sensitising the public. They often act as intermediaries in
monitoring and evaluating the initiatives taken by the government and industry to address the problem.
Since their role is vital, their perspective was also taken into consideration.
The technological issues addressed by the research and development organisations are of crucial
importance in evolving policies. New emerging technologies like biodegradable polymers could alter
the scenario of plastic waste management. Further, the recycling industry could also be made to
improve the quality of recycled products through technology improvement programmes. Hence R&D
institutions were also considered in this study.
1.4.4 Analysis of the information gathered in the above two phases

Analysis of the information3 gathered was done using the framework that was formulated. The
interviews helped the author to understand the complexity of the problem, that is the economic, social,
cultural, and technological issues associated with plastic waste management in India. Experiences from
other countries were also studied and these aided in the analysis. The framework provided the basis for
a systematic analysis and aided in highlighting the deficiencies and implications that have been
overlooked in the existing polices. The analysis brought to focus some of the priority areas that need
immediate attention.
1.5 Structure of the Thesis

The paper comprises of seven sections inclusive of the introductory chapter. Chapter 2 describes the
framework that has been developed for the evaluation of the plastic waste policies. Following this, the
status of the plastic industry, the recycling sector, plastic waste management, and the problems
associated with PET and Polybags in India have been presented in Chapter 3. In Chapter 4, the existing
policies on plastic waste as formulated by the Central and State government have been discussed. In
Chapter 5, the existing policies have been analysed based on the framework developed in Chapter 2.
Based on the findings from the analysis, a few recommendations have been made in Chapter 6, and
these could be considered in formulating future policies on PET and polybags in India. Conclusions
from the research have been presented in Chapter 7.
3 Although levels of waste generation, collection and disposal are available, they are not accurate figures as is the case with all
solid waste management data. These problems are even more acute in developing countries.
5
6
2. Evaluation Framework
Environmental policies typically combine the identification of a goal (either general or specific) with
some means to achieve that goal. The objective of a policy in addressing an issue is very important,
since targeting the right objective is crucial in alleviating the problem. To evaluate the policy or
program as to its effects on sustainable development and resource use, it is necessary to review the
objectives of the policy (IIISD, 1995). Further, it is also important that the objectives of the policy are
sustainable in the long- term. A policy objective should not only aim to address immediate concerns,
but also provide a long-term solution to the problems. Since the focus of this research is on packaging
waste, it is important to understand the objectives policy makers have in mind while framing
sustainable waste management policies. This would help to analyse whether the objectives of the
existing policies on plastic waste management in India contribute to sustainable waste management.
2.1 Objectives of Sustainable Waste Policies

Managing waste from packaging has become increasingly difficult in developed and developing
countries. As a result of the growing amounts of packaging in the municipal waste stream, an increasing
number of developed countries are in the process of identifying policy options that can reduce the
presence of packaging in the waste stream.
As a major component of municipal waste, packaging waste contributes to various environmental

problems such as resource use (raw material extraction and processing), littering, and waste disposal
impacts related to landfills and incineration.
Sustainable waste policy starts from the base line objective that the generation of waste should be
optimally prevented. The following reflects the main principles for sustainable waste management
(OECD, 1993):
1. Prevention of waste generation at source as the first priority
2. Waste minimisation
3. Reuse and recycling should be practised to the extent possible
4. Treatment of waste prior to disposal
5. Disposal is the least preferred option.
Source reduction is often adopted as a key element of a waste management strategy aiming for resource
efficiency, and ultimately, sustainable development. Source reduction in the context of packaging could
mean prevention of waste generation by reducing the use of packaging, or by shifting from one
packaging to another, less voluminous or lighter one; which will encourage producers to generate less
waste and use fewer resources. Waste prevention can produce environmental benefits throughout
product life cycles. Most directly, preventing the generation of waste reduces the need for further
investments and energy use to collect, store, process and dispose of what would have been waste
(OECD, 1999).
While communities and companies can save money via waste prevention, the benefits to be gained
from waste prevention will also often be manifested upstream. For example, the reuse of PET bottles
not only reduces their discard into the municipal waste stream; it also reduces plastic consumption, and
therefore the need for plastic distribution, and ultimately plastic production and oil extraction.
Therefore, externalities associated with each link in the plastic chain are also lowered. This may be
7
generalised as a cascading relationship: waste prevention can lead to modified consumption, and this to
modified production, and further reduced pollution and waste generation throughout product life
cycles (OECD, 1999).
Waste prevention stands apart from the other options in the waste hierarchy because it principally
addresses the causes rather than the outcomes of waste generation. Clearly, the less waste that is
produced the less waste there is to dispose of. Moreover, reducing waste either from the production
process or in the shape of post-consumer waste helps to conserve scarce resources, and reduces the
potential environmental problems associated with waste disposal. Waste prevention is therefore the
single most important initiative towards achieving sustainable waste management.
Waste Minimisation according to the OECD countries is a broader term than waste prevention in that
it includes recycling and if, considered appropriate, incineration with energy recovery (OECD, 1999).
Waste Minimisation includes all those activities that eventually contribute to less waste.
Waste prevention in the context of Waste Minimisation (OECD, 1999)
Strict Avoidance
Waste
Reduction at Source Prevention
Waste
Product Reuse
Minimisation
Recycling
Incineration with Energy Recovery
Figure 2-1 Linkage between waste prevention and waste minimisation
It seems particularly relevant to emphasise the distinction between prevention and recycling. Recycling,
unlike waste prevention, is a production process, requiring material transport, energy use, and
ultimately disposal of the residues left over from the activity (OECD, 1999). Clearly, although recycling
is environmentally preferable to disposal, it is not without its own environmental implications.
While recycling will continue to play a significant role in mitigating the waste burden in countries like
India, it is imperative to bear in mind that recycling is not equivalent to prevention. Policies that target
to encourage recycling cannot clearly produce the same benefits as waste prevention. Waste prevention
will tend to engender significantly higher environmental benefits.
Another option that is often practised in developed economies is incineration with energy recovery. In
this, waste is burnt, thereby significantly reducing the volume of waste requiring disposal. Incineration
with energy recovery is not an action specific to the packaging waste, but is relevant to municipal waste
at large. If the overall goal of the waste management system is to minimise the disposal to landfills4,
incineration can complement the recycling systems. Incineration with energy recovery is a feasible
option in countries where material recycling is low and waste has a high calorific value. In the case of
4 From the financial point of view it seems that landfills look like the way to go, but traditional financial analysis omits the
fact that the landfills are permanent facilities that need to be maintained and monitored. In contrast, material recycling
systems and incinerators are temporary structures, and after their useful life, can be decommissioned, and the land could be
sold or put to other beneficial uses.
8
India, incineration with energy recovery may not be a feasible option, considering the fact that material
recycling of plastics is as high as 60%. This may not leave waste with much calorific value, thus making
incineration with energy recovery a non-viable option.
Encouraging reuse and recycling alone will not be enough to counteract the overall increase in waste
outflow. Waste prevention will generally produce superior environmental results to recycling, and the
combination of prevention and recycling will generally produce superior results as compared to the
application of either activity in isolation (OECD, 1999). Thus, waste management policies may
generally incorporate several provisions to attain the objective of sustainable waste management.
Clearly, moving up in the waste management hierarchy may render policies more in line with
sustainable development. It also means that the policies in the sphere of waste management could aim
at the achievement of the following objectives:
• Waste prevention and reduction
• Product reuse
• Increased use of recycled materials
• Reduced natural resource consumption
The single most important reason contributing to the waste challenge is the fact that producers and
consumers have not been required to pay the full social and environmental costs of the wastes they are
responsible for creating, and as a consequence of their consumption patterns.
Internalisation of environmental costs can lead to proper pricing of goods. Plastics are cheaper since
they do not take account the ecological cost. So, an appropriate pricing of plastics could make
renewable and traditional materials5 that existed in India prior to the arrival of plastic seem attractive
from a cost perspective. Therefore, it is important that products are appropriately priced so that this
can lead to the consumer making the right choices.
This discussion gave us an idea on the objectives, waste management polices should ideally target to be in
line with sustainable development. Further, it is also important that the objectives are achieved in a
sustainable manner. Therefore, it becomes imperative to understand the characteristics of sustainable
policies, and this has been discussed in the next section. This will provide information on the criteria
available for evaluating the sustainability of policies.
2.2 Characteristics of Sustainable Environmental Policies

There are many different types of environmental policies. Each type anticipates that administrators and
polluters will respond to it in a particular way. Each of them has some specific characteristics that make
it more likely to succeed in certain circumstances, and not in others. In evaluating the effectiveness and
appropriateness of the policy for addressing a given environmental problem, it is important to have
clearly in mind a set of policy evaluation criteria (Field, 1999). Considering these different criteria
provides a basis for evaluating the strengths and weaknesses of different types of policies.
Field (1999) has suggested some key criteria that could aid in the evaluation of policies. The criteria
include effectiveness, cost efficiency, fairness, enforceability, social and political acceptability and the
5 The clay kulhads would be much cheaper than the polystyrene plastic cup. Kulhad is the mud cup, which was used as a
teacup. The earthen Kulhad can be used once and when disposed, creates no problems.
9
incentives the policy offers to search for better solutions. Most environmental polices broadly cover
the three Es: environmental effectiveness, economic efficiency and equity (O'Connor, 1996). Apart
from the three Es there are also issues pertaining to political acceptability, transparency, administrative
feasibility, industry response, monitoring, and enforcement, legal and institutional requirements that
have been utilised. A brief discussion on some of the essential criteria follows.
2.2.1 Environmental effectiveness

A policy is said to be effective when it is able to achieve the environmental goal that is desired.
Environmental effectiveness is indicative of the extent to which the policy succeeds in reducing
environmental impacts in general, in relation to the policy targets set. (OECD, 1999). In the context of
packaging, ideally the policy should be able to mitigate the pollution and resource usage impacts
associated with packaging. Policies vary in their capacity to achieve the objective in different situations
(IISD, 1995). Hence environmental effectiveness is an essential criterion in evaluating environmental
policies. It is also important how the goal is achieved which leads us to the next criterion of cost
efficiency.
2.2.2 Cost efficiency

A policy is cost efficient if it can produce the maximum environmental benefit for the resources being
expended, or it achieves a given amount of environmental improvement at the least possible cost
(Field, 1999). A policy should economise on resources, in terms of capital, labour, materials and energy
(OECD, 1993).
Costs are important, since the resources devoted to environmental improvements should be spent in
ways that will have the greatest impact. This is especially important in less developed economies, where
people have fewer resources to invest in environmental programmes and cannot afford policies that are
not cost efficient (Field, 1999). It is highly desirable that costs borne are minimal in achieving the
objective desired.
2.2.3 Equity
Any policy affecting change will have distributional impacts. The cost of taking action could be shared
quite differently among the various stakeholders according to the design of the policy. Equity involves
an assessment of the extent to which provisions are made for the involvement of all the stakeholders in
bringing a change (IISD, 1995). The impact of the policy should not be clearly regressive, that is it
should not confer a disproportionate burden on those who are least well-to-do in society (Turner et al,
1994). Equity6 is also a concern for policy effectiveness, because policies may not be supported
enthusiastically, if they are found to be inequitable (Field, 1999).
Equity or distributional effects relates to the way in which the responsibilities to bring about a change
are allocated. What are the costs of adjustment for the various stakeholders by the adoption of a policy?
Although ideally regulation should be fair to ensure that all the stakeholders contribute towards a
change, in reality, there are few who have to bear more costs than the others because of a policy
intervention. Policies are clearly better if they do not place an unfair burden on any member of the
6 It is an open question on how much emphasis should be placed on the distributional impacts of the environmental policy
compared to other characteristics. On one hand, the argument is that environmental degradation is so pervasive that we
should focus on policies that are primarily efficient, that give us the most for the resources spent. On the other hand is the
position that we should avoid polices, even efficient ones, that may cause a regressive impact. In countries like India, there
clearly needs to be a design of policies that are efficient and equitable for the reason that it is also important to achieve
environmental protection without putting a large segment of the population at stake.
10
society. Equity considerations loom large in the making of environmental policies in countries like
India, where it is necessary to promote income generation activities.
2.2.4 Administrative feasibility

The administrative feasibility of policy implementation depends to a large extent on the design of the
policy, and the effectiveness of the administrative authority charged with enforcing environmental
protection measures. The reason for this is that polices differ in terms of how easy it is to enforce
them. Some may require technical measures to get reasonable enforcement; others may be enforceable
at lower cost. In many developing countries, the administrative agencies are not technically trained to
enforce the legislation, and can be hoodwinked. However the training of the administrators also entails
costs. If adequate funds cannot be provided to train and equip officials then it seems meaningless to
make legislation (Faure, 2001). In addition, many public agencies have budget limitations, but have
responsibilities that are large and growing. Therefore, the costs of enforcement become critical to the
success of policies. There is no sense in creating a policy that is essentially impossible to enforce. (Field,
1999)
Success of enforcement also depends on the awareness of the public on the contents of the legislation
and the risks of non-compliance. This depends on the probability of detection, and size of the sanction
imposed (Faure, 2001). There are two main steps in enforcement: which are the following:
• Monitoring:
Monitoring refers to measuring the performance of the polluter in comparison to what requirements
are set out in the relevant law. The objective of enforcement is to get the people to comply with the
law. Without adequate resources for monitoring (e.g., equipment and testing facilities and trained
personnel), regulatory effectiveness is diminished. In the Philippines for instance, half of the fourteen
regional environmental offices have no established laboratories capable of even basic testing (OECD,
1992). So if the enforcing authorities lack adequate resources and facilities to effectively monitor and
enforce, polluters who stand to lose money if the legislation is completely enforced, may find ways and
means of hood winking the monitoring authorities.
• Sanctioning:
Sanctioning refers to the task of bringing to justice those whom monitoring has shown to be in
violation of the law. Even when sanctions are stringent, they may lack the deterrent effect if the
probability of detection is low. Potential polluters always tend to underestimate the probability7 of
being caught. Therefore, it is not only important to have sanctions that are sufficiently high, but also
assure a high probability of monitoring and punishment (Faure, 2001).
There is a paradox built into the sanctioning process. Higher fines and imprisonments may help the law
to deter violators. On the other hand, the higher the penalties, the more reluctant the courts may be to
apply them. The threat of stiff financial penalties can in turn threaten the livelihood of large numbers
of people. Courts may be reluctant to throw a large number of people out of work and may adopt less
drastic penalties than stated in the law (Field, 1999).
Therefore policies should have both low administrative complexity and compliance costs, that is, the
practical difficulty of calibration, collection, monitoring and control should be minimised.
7 This phenomenon will of course increase if they can even decrease the probability of a prosecution or conviction by bribing
the administrators or the public prosecutor in countries where the level of corruption is high.
11
2.2.5 Social and political acceptability

Political acceptability8 refers to the extent to which the policy fits in with the government’s wider
priorities – which are, of course, greatly influenced by pressures emanating from a wide range of
interest and pressure groups, as well as the mass media and the general public. It is very important to
know the extent to which concerned groups in society are ready to accept the new policy (OECD,
1993).
It has been observed that the effectiveness of a policy in practise has often been low because of the
lack of political will to enforce the regulation made. The problem is that environmental protection is
often limited to political statements that lack adequate enforcement9 (Faure, 2001). In such cases the
legislation remains dormant and is never enforced, and hence never achieves the goal. Consequently it
is important that there is a consensus among different stakeholders on the policy so that it can be
effective.
2.2.6 Incentives for improvements

In studying environmental policies we have to remember that it is the private parties, firms and
consumers whose decisions actually determine the range and extent of environmental impacts; and
hence the incentives facing these private parties determine how and when these impacts will be
reduced. Thus an important criterion that should be used to evaluate an environmental policy is
whether the policy provides a strong incentive for individuals and groups to find new innovative ways
of reducing their impact on the environment (Field, 1999).
The introduction of policy principles like Extended Producer Responsibility (EPR) for packaging in
Germany have led to a systematic search for product innovation in order to minimise the fee paid to
producer responsibility organisations (Lindhqvist, 2000). This has reduced the amount of packaging
used. If EPR was not a part of the legislation then such innovation in the packaging market may be
difficult to achieve.
Although sustainable policies may have the aforementioned characteristics, they also have to be
designed taking into consideration the social, cultural and economic conditions prevailing in the
country. This fact is being stressed here because policies may fail when have not been designed in tune
with the local conditions prevailing in the country. So, all the above-mentioned factors should be taken
into account when designing policies suitable for addressing a particular problem.
2.3 Framework for Policy evaluation

The aforementioned facts present the key criteria that policies need to abide by, in order to be
sustainable. In this research, the following criteria have been chosen for evaluating the merits and
demerits of the existing policies: Environmental effectiveness, cost efficiency, equity, administrative
feasibility, social and political acceptability, and incentives the policy offers to search for better
solutions. The rationale behind selecting the following criteria is predominantly their relevance in
evaluating the existing policies on plastic waste management. It is crucial to understand if the existing
policies on plastic waste have been able to achieve their objectives, and if the objectives have been
achieved in a cost efficient manner. Considering that developing countries like India have limited
8 Policy formulation is a constant struggle where ambitious politicians attempting to accumulate power, lobbying groups
representing particular interests and administrative agencies with their own agendas all come together in a process of
conflict and strife.
9 There is often a lack of political will to enforce the regulation made. There is no manpower made available to control the
compliance with the environmental regulations and if there is sufficient manpower they often lack technical knowledge or
equipment.
12
budgets for waste management, it is important that policies are cost efficient. Further, it is also
necessary that the costs for bringing a change in the system be fairly distributed among the various
stakeholders, and this brings in the criteria of equity. Often laws in India do not achieve their goals due
to enforcement problems. This makes it very important to design policies that are enforceable. So,
feasibility of administration is also critical to the success of the policy. In order to enforce a policy and
ensure that it is a success, a key factor is the political will and social acceptance of the policy. If this is
not ensured, then policies are bound to be unsuccessful. Finally, a policy should also give incentives for
the appropriate stakeholder so as to stimulate continuous improvement. In the context of waste
management a policy aiming to solve the littering problems could give appropriate incentives to
prevent waste generation in the long term. Therefore, incentives for improvement have also been
selected as one of few criteria.
The criteria selected above are pertinent and essential for evaluating the existing policies on plastic
waste, since the evaluation could bring to focus the key problem areas in the existing polices on plastic
waste.
Many of the waste policies vary exceedingly in their design, objectives and in the number of policy
instruments used. The principles outlined in the Section 2.1 indicate the various objectives policy-
makers target when designing sustainable waste policies. It is also important to evaluate if the various
objectives have been achieved in a sustainable manner. In order to guide the study, an evaluation
framework (Figure 2-2) has been developed that will provide the author to analyse the objectives of the
existing plastic waste polices and also assess if the existing policies on plastic waste in India meet the
criteria of the sustainable policies.
Reviewing the objectives of the existing policies forms the first step in the evaluation. It is possible that
the objectives of the policy or the programme may not be sustainable and should be reconsidered. The
existing plastic waste policy has an explicit aim of curbing littering through encouraging reuse and
recycling. In order to evaluate if littering has been minimised through the objectives of recycling and
reuse, the objectives of the existing policy is scrutinized with respect to general objectives of a
sustainable waste policy10.
The next step in the evaluation is to identify if the policy targets have been achieved in a sustainable
way or not. The criteria for evaluation have been identified in Section 2.2 and the existing policy will be
appraised by comparing its consistency with these criteria. The evaluation criteria used in this research
are derived from the broader concerns of efficiency, effectiveness and equity.
The purpose of this framework is to take advantage of the information available and provide a
systematic assessment of the policy. Such a systematic approach is capable of singling out strengths,
weaknesses and ignored consequences of the existing policies on plastic waste management in India.
While policies may or may not promote sustainable waste management, the author, through the use of
the evaluative framework, hopes to provide the information necessary to suggest desirable
modifications, which may help to render the existing policies more in line with sustainable
development.
10 A waste management policy may not have an explicit aim of minimizing littering, however this has been shown as
separate aim in the framework in view of its significance in the disposal of PET and polybag
13
Existing policy for evaluation
Analysing the objective of the

existing policy
• Strict Avoidance
• Source Reduction
Broader goals of a Sustainable
Waste Management policy • Reuse
• Recycling
• Minimise Littering
• Effective Disposal
Policy evaluation based on the criteria of

sustainable policies
• Effectiveness
• Efficiency
Criteria for evaluating • Equity

Environmental Policies
• Enforcement
• Acceptability
• Incentives for Improvement
Figure 2-2 Framework for policy evaluation.
14
3. Plastic Industry in India

This chapter provides information on the plastic industry in India, the current consumption levels of
plastics, the existing plastic waste management system and its key stakeholders, the recycling industry
and its associated issues, and the problems related to PET and polybags in India.
3.1 Sector Profile

The plastic industry in India started with imported machines, raw materials, and processing technology
in the late 1940’s. The industry gained momentum in 1960, when a small naphtha cracker plant for
production of ethylene was set-up. With the availability of ethylene, production facilities for HDPE and
PVC were established. The pace of growth was slowed with successive crisis faced by the polymer
industry in the 1970s. The major global oil crisis in 1973 resulted in major increase in feedstock prices
for the petrochemical industry in India.
In the late 1980’s, as a part of the seventh five-year national plan (1986-1990), the Government
sanctioned a number of petrochemical complexes with the proposed investment of Rs 30,000 crores
(US $ 6.4 billion). The main aim behind the promotions was that India was seeking to be self-sufficient
in commodity plastics. The impetus was once again halted in the early 1990s, as India suffered a serious
balance of payment crisis. This was worsened by the Gulf war, which saw the prices of polymers
doubling. Since India was importing oil feedstock, it could not cater to the demands of the domestic
market and hence processors in the country had to reduce production levels to around 50% of their
capacity (Edwards, Kellet, 1999). In 1991, the government came out with a comprehensive scheme
involving exchange rate adjustments and structural reforms in trade and policy that aimed to balance
out the problem.
The promotion aimed in the seventh five-year plan helped companies like Reliance, India’s largest
private sector company, to make the leap forward. In India, they are two companies that dominate the
polymer raw material industry: Reliance Industries limited (RIL) 11 and Indian petrochemicals
corporation Limited (IPCL). This is soon becoming one with Reliance occupying more than 56% of
the plastic market in India (Edwards, Kellet, 1999). Besides Reliance, the other main players in the
market are government owned IPCL, Chemplast Sanmar, NOCIL and Finolex.
In addition to the raw material manufacturers like Reliance and IPCL, there are also the processors in
the plastic industry, who convert the virgin material, into consumer goods. As the end product has
finished its expected life, it becomes plastic waste, which is collected by the informal sector for
recycling. The structure of the plastic industry is depicted in Figure 3-1. The dotted line indicates the
separation between the virgin plastic industry and the recycling industry. The virgin and recycling
industry operate in parallel with individual niche markets for their finished products.
The polymer industry in India has moved a long way and has diversified to serve key sectors like
agriculture, telecom, transport and packaging. As the per capita consumption of plastics (4kg) in India
is very low as compared to the world average of 18 kg consumption, India is still a scarcely tapped
11 Reliance is India’s biggest private sector industrial company. It owns a massive refinery in Jamnagar (Gujarat), which is the
largest oil refinery in Asia. This refinery is expected to refine 15 million tonnes of oil annually and the total investment in
the site is estimated at about US$4.3billion. Reliance strategy has been very bold. Instead of catering to the demand,
Reliance set up huge capacities, thereby creating a market for its products, lowering costs and pre-empting others from
expanding into the market. Therefore building overcapacity has helped it squash domestic competition. Despite the huge
production capacity Reliance has never focused on export of raw materials. Its interest has always been in the domestic
market. With the increasing demand for commodity plastic and the huge infrastructure reliance has setup to cater to the
needs, the rise in plastic consumption is bound to occur.
15
market and the number of potential consumers is enormous. So the industry believes that the demand
for plastic products can be vastly increased in India (GOI, 1997). Further, liberalisation of the Indian
economy, and petrochemical industry being a high priority area for the Government, there is bound to
be an increase in plastic production and consumption in the years to come.
Virgin granules
Virgin Raw material industry Polymers
Plastic
Processing Additives
Industry
Consumer (Finished products) Processors of the virgin

granules
Post Consumer Waste

Plastic Recycled
Reprocessor
Recycling Granulator products
Industry
Reprocessed
Granules
Figure 3-1 Structure of the Virgin plastic and Recycling Industry.
3.2 Plastic Consumption in India

The growth of the Indian plastic industry has been phenomenal - the growth rate (17%) is higher than
for the plastic industry elsewhere in the world (GOI, 1997). India has a population of over 1 billion and
a plastic consumption of 4 million tonnes. One third of the population is destitute and may not have
the disposable income to consume much in the way of plastics or other goods. The virgin industry
does not target this population to expand its markets. However, one third of the population is the
middle class whose aspirations could be moulded to increase consumption. Plastic manufacturers
create needs for this segment of population. The rising needs of the middle class, and abilities of
plastics to satisfy them at a cheaper price as compared to other materials like glass and metal, has
contributed to an increase in the consumption of plastics in the last few years. The consumption trends
for key commodity plastics are presented below in Table 3-1.
16
Table 3-1 Demand scenario for key commodity plastics in India
Polymer 1995-1996 2001-2002 2006-2007

Polyethylene (PE) 823 1835 3267
Polypropylene (PP) 340 885 1790
Polyvinyl chloride (PVC) 489 867 1287
Polyethyleneterephthalate (PET) 34 140 289
Others 203 647 1415
Total 1889 4374 8054
Plastics in Packaging 976 2272 4037
% of Plastics in Packaging 52% 52% 50%
Source: National Plastic Waste Management task force report (1997). The above figure presents the total predicted
increase in consumption of resins. (Figures in thousand tonnes)
Table 3-1 shows that there is an expected increase in all commodity plastics consumed in the country.
Of the total consumption of plastics, commodity plastics account for 85% with engineering and other
plastics accounting for the balance (CDC, 2001).
Packaging presents a major growth area where there has been a spiralling demand for plastics. 52% of
the plastics produced in India are utilised for packaging12 (Refer Table 3-1). Among the commodity
plastics, polyethylene and PET are predominantly used in packaging. LDPE13 is used in the
manufacture of carry bags and PET is used in packaging beverages like soft drink and mineral water
and PET in particular presents a major growth area in the years to come.
The rise in PET is mainly associated with the non-availability of clean water in the country. Lack of
clean drinking water results in frequent water borne infection due to which residents and travellers
consume bottled water packed in PET. The Indian PET consumption has grown at an annual rate of
30% and the current PET consumption is estimated to be around 45,000 tonnes per annum. PET is
maintaining a growth of at least 25% per annum and with this projected growth the Indian PET
consumption will double in the next three years (Economic Times, 2000). Some of the key drivers for
this growth are the complete adoption of PET packaging by the mineral water industry, entry of many
MNCs14 in this market segment and widespread application areas for PET (in packaging edible oil,
liquor etc).
The PET bottle production in India was around 840 million bottles in 2000, and is likely to grow to 1.3
billion bottles by 2002 (Economic Times, 2000). The mineral water and carbonated soft drink market
12 This trend is expected to continue. In fact, the packaging industry is one of the single largest markets for the plastic industry
in India. According to industry estimates plastics has captured 40% of the total US$ 6.3 billion packaging market in India.
The increasing presence of multinational companies in India has boosted the packaging sector and thereby the plastic
packaging sector as well (Toxic Link, 2001)
13 The LDPE consumption for the year (2001-2002) is 303,000 tonnes and is expected to increase to 534, 000 tonnes in the
year (2006-2007). (CDC, 2001)
14 MNCs refer to Multinational Corporation. Bottled water has been a monopoly of Bisleri a 31year old brand in India, but
now multinationals such as Pepsi Foods with Aquafina, and Coco-Cola Limited with Kinley are in the market giving Bisleri
a tough competition. A few years ago the value of the organised bottled water market in India was pegged around Rs 1.5
billion and today it has gone up to Rs 5 billion. (Indian infoline,2000)
17
will form the two major markets for these bottles in India. Table 3-2 presents the current and projected
market segment for PET in India.
Table 3-2 Indian PET market (tonnes)- Current and projected
Market Segment 2000 2003

Carbonated soft Drink 10,000 25,000
Mineral water 10,000 25,000
Country liquor 5,000 8,000
Edible oil 3,000 5,000
Jars (Tea, confectionery) 6000 8000
Small bottles (pharmaceuticals) 4000 6000
Others 7000 13,000
Total 45,000 90,000
Source: The Economic Times. (2000) 15
There are no accurate figures available on the polybag consumption in the country. The industry
estimates reveal that virgin LDPE consumption for carry bags is 31,000 tonnes (CDC, 2001) The
consumption of recycled polybags is hard to estimate primarily because polybag recycling units are
located in the informal sector, which are scattered throughout the country as small units.
3.3 Plastic Waste Management in India

Plastic goods after completion of their useful life find their way into waste. The phenomenal growth of
plastics and their consumption in terms of products of short and intermediate life spans have resulted
in significant generation of waste.
The predominant sources of post consumer plastic waste are:
• Municipal sources that include residential households, markets, small commercial

establishments, hotels and hospitals,
• Distribution and industry sector like food and chemical industries, packing films, etc
• Other sources include automotive wastes, agricultural wastes, industrial waste and construction
debris.
Process of collection, transportation and disposal of waste is not systematically structured in any Indian
city. Garbage makes its way to neighbourhood dumps. These are usually open vats where the garbage
festers and spills out to the street. The waste could lie there for days together with cows and stray dogs
foraging through it. Some of it gets transported to landfill sites (open dumping grounds) in municipal
trucks. Figure 3-2 indicates the system of plastic waste management and the movement of plastic waste
through the various actors in the informal sector.
15 The installed PET resin capacity in the country is 158,000 tonnes and the conversion capacity available in the country is
80,000 tonnes and the expected increase in consumption is 90,000 tonnes.
18
Virgin resin manufacturers and plastic processors

Production
Post Consumer Waste

End user/ Household Hospital Hotels Shops
Consumer
Ragpickers Dealers/Wholesalers
Collection Trade
Waste plastics Uncollected waste

that have a value allowed to litter and
are picked from eventually carried
Municipal solid the street dumps along with the
waste (Formal biodegradable waste
and the Informal to open dumping
Sector) Street Waste, Dumpyards grounds
! Sorting and cleaning

! Grinding , cleaning and drying
! Granulation and packaging
Reprocessing
cycle
Reprocessor
Reprocessor
Consumer
Figure 3-2 Plastic waste management in India
3.3.1 Plastic waste generation

Waste generation rates are often affected by socio-economic development, degree of industrialisation,
and climatic conditions. Generally, the greater the economic prosperity and the higher percentage of
urban population, the greater the amount of solid waste produced. Urbanisation and rising incomes,
which lead to more use of resources and therefore more waste, are the two most important trends that
factor into rising waste generation rates and this is exactly the case with India’s urban population
(World Bank, 1999).
Down to Earth (2000) reports that a total of 36.5 million tonnes/year (36.5 kg/individual16) of
municipal solid waste is generated in the country. The plastic content in MSW as reported by various
organisations has been highly incongruous. The plastic content in the MSW depends on the
consumption pattern, which varies from zone to zone, and level of urbanisation. The plastic content is
16 The figure of 36.5 kg/individual has been found to be low. Considering the fact that the plastic consumption in the country
is 4 million tonnes and 52% of the plastics is used for packaging, then we could estimate that the plastic waste generated is
at least 2 million tonnes and not more than 4 million tonnes. Since plastics constitute only between 1-4% of the waste, and
then the total waste generated should be between 50million tonnes – 400million tonnes /year that constitute 50-400
kg/individual, which is higher than the reported figures.
19
reported to be in the range of 1-4% (0.37kg/individual – 1.5kg/individual) (GOI, 1997). Table 3-3
indicates the total amount of post consumer waste available for reprocessing. Process waste that is
clean is directly utilised in the industry but the post consumer waste if not properly disposed poses a
grave problem. 60% of the post consumer waste is collected for recycling and the remaining 40% waste
is uncollected and left to litter (GOI, 1997). Considering the post consumer waste available for current
year, then 800,000 tonnes of waste remains as litter, posing a huge problem, or finds its way to open
dumping grounds.
Table 3-3 Plastic waste generations in India
1995-1996 2001-2002 2006-2007

Total polymers 1889 4374 8054
Process Waste (2%) 38 87 161
Post consumer Waste17 870 (46%) 1966(45%) 3624(45%)
Source: National Plastic Waste Management Task Force. (1997) Figures in thousands tonnes
3.3.2 Plastic waste collection and disposal

Low calorific value, high moisture content, and high quantity of non-combustibles characterise the
Indian municipal waste. Waste is the responsibility of the municipal18 authorities in India, but since the
non-biodegradable garbage presents a value for the poor who eke out a living from the waste, it is often
taken care of by the informal sector. The biodegradable waste along with the uncollected non-
biodegradable garbage is taken care of by the municipal authority. The level of service for waste
collection is also very poor. In most industrialised countries services have expanded to the extent that
over 90 per cent of the population (and 100 per cent of the urban population) have access to waste
collection (Buekering et al., 1999b). This is not the case with many developing countries like India
where municipal services are limited. The failure to provide adequate collection services poses a serious
threat to human health in India19 (WHO, 1992). Yet, it should be noted limited finances20 and ever
increasing demand on urban services handicap municipal services in India. In fact, it is the poor who
derive their living from waste who demonstrate better efficiency in collecting waste and perform the
important task of segregating waste that can be recycled from biodegradable waste.
Open dumping is the most commonly accepted way of disposing waste in India. Waste is collected and
transported outside city limits and deposited along highways or low-lying areas. Dumping is also carried
out illegally on private farmlands located in the city vicinity. One reason for this is the lack of landfill
space in the cities (Buekering et al, 1999b). These pits of rotting waste generate methane, which cannot
be tapped or used without regular soil cover. During monsoons, rain dissolves the toxins present in the
waste that permeates the soil and pollutes groundwater (Down to Earth, 2001).
17 Post consumer waste includes reprocess able mixed plastic waste

18 In most Indian cities, the municipal service for the collection and transportation of urban solid wastes comprises three
separate functions: (a) sweeping and kerbside collection; (b) transportation by hand-carts to large or road collection points,
which may be open dumps, vats (masonry enclosures) or storage chambers; and (c) transportation by vehicles to the
disposal sites. (Buekering et. al., 1999a)
19 Improper waste collection and disposal leads to health problems such as tuberculosis, asthma, bronchitis and lung infection
among the waste pickers as well as the local population.
20 Budgets for waste management is a problem in many developing countries. In Malaysia, about 70 percent of the MSW
budget is spent on the waste collection. Typically, 90 percent of Indonesian solid waste management budgets are allocated
for activities related to collection: street sweeping, transportation, vehicle operation and maintenance. (World Bank, 1999)
20
3.3.3 Plastic waste recovery and recycling

An important feature of waste recovery and recycling in India is the involvement of the informal
sector. This sector is mainly engaged in the recovery and re-sale of most of the recyclables and is highly
labour intensive. They form the core for plastic waste management in India but their role in waste
management is yet to be recognised. The informal sector constitutes a chain of actors who are involved
in the trade of plastic waste and recycling.
3.3.4 Agents involved
3.3.4.1 Formal (municipal) sector

In large Indian cities, the municipal body21 is the main group involved in the urban solid waste
management. The municipalities are responsible for the collection of waste disposed in bins by the
households, hotels and commercial establishments and they remove the garbage by motorised vehicles
and dump it on open grounds.
The municipality derives its funds for waste management either through funds designated by the
Central Government and funds derived from property taxes. These funds seem inadequate for most
municipalities, considering the increasing demands of urbanisation. Due to budgetary constraints,
inadequate equipment and poor planning, house-to-house collection is very rare in India, particularly in
low-income areas where waste is not collected at all (Baud, Schenk, 1994). It is estimated that up to 30
per cent of disposed solid waste (public dustbins and street garbage) is left uncollected (Buekering et al,
1999a).
In the city of Mumbai, the budget for solid waste management has increased from Rs 2.5 billions to 4
billion in the last six years. A major portion of this budget goes for collection and transportation, and
only a very small portion for disposal. Disposal is generally open dumping and this accounts for the
low expenditure. Further, the solid waste management department of the municipality has 35,000
regular employees22 all of them with an average salary of Rs 7000 (approximately $149) per month.
With more than 70% (Rs 2.94 billion) of the budget being dispensed to employees, the inadequacy of
the budget for appropriate transportation and disposal seems justified. Therefore despite the increasing
budgets for waste management, many areas or suburbs of Mumbai are badly served. These areas are
faced with clogged sewers and littered waste, creating serious health problems for the resident
population (Interview, Deputy Municipal commissioner, Mumbai).
The economics of waste management services are gaining importance in India. Because of the widening
gap, resulting from the increased municipal costs of provision and limited finances, the emphasis is on
improving efficiency. However, the municipal authorities are constrained by the fact that historically
service prices in India have been extremely low and do not adequately reflect the costs incurred in
providing them (Buekering et al, 1999a).
21 The 74th Constitutional Amendment Act (1993) provides for three types of urban local bodies. They are the nagar
panchayats for transititional areas, Municipal councils for small urban areas and City Municipal corporations for larger
urban areas (Buekering et al,1999b).
22 It is believed that the municipality sweepers employed in the solid waste management department hire others for a meager
amount to fulfill their tasks. The importance of government job lies in the fringe benefit of subsidized housing, free health
care and provident funds. However this does not mean that the quality of the municipal service in this regard cannot be
guaranteed.
21
3.3.4.2 Informal sector

As in most developing countries there is an informal network of plastic waste management processors
in Indian cities. This is parallel to the formal waste management system, and is largely a self-organised
activity. This activity is a sheer economically driven activity and plastic waste gets value added as it
passes through each actor in the informal sector.
Wastepickers
Recycling in India takes the shape of a flat-topped pyramid. The wastepickers form the bottom layer of
the waste collection/recycling pyramid (CPCB, 1997). They form the backbone of plastic recycling in
India. Rag picking is born out of abject poverty and a desperate need to survive in an overcrowded
country. The numbers of people involved in the collection are hard to quantify. It is estimated that
over one million wastepickers are engaged in management of plastic waste in India. In Mumbai alone
there are about 200,000 wastepickers from different parts of India (Interview, Indian Centre for
Plastics and Environment, Mumbai) The earning of the wastepickers varies from Rs 30 - Rs 200 per
day23 depending on the locality they squat on. Their earnings are also dependent on seasonal variations.
Since most bins are open, the garbage becomes wet in the monsoon, and this considerably lowers their
income24. The wastepickers collect all waste that has a value in the market.
The wastepickers carry out scavenging with bare hands that make them susceptible to a wide range of
infections, cuts and wounds. Research on occupational exposure has revealed that the wastepickers
were found to commonly suffer from body pain, respiratory diseases and various serious skin
infections. Since they endanger themselves physically by entering disposal sites and garbage bins
without protection for their feet or body, they are exposed to injury by iron and glass pieces. In
addition to the physical hazard, they are also subjected to harassment by the local authorities and
police. Further, the other actors in the informal network often exploit them by underpaying them for
their goods and creating debt traps for them (CPCB, 1997).
A study carried out by the New Delhi based NGO “Chintan” reveals the beneficial work of the
wastepickers from the environmental and financial point of view. The Municipal Corporation of Delhi
spends about Rs 620 to collect and transport one tonne of waste. It is estimated that the waste pickers
feed into the recycling chain between 12 and 15% of the total waste generated. Of the approximately
6000 tonnes of garbage produced each day in Delhi they collect between 720 –900 tonnes. Applying
the municipality rates, it would be safe to say that the wastepickers save the municipality of Rs
558,000/day (Chaturvedi, 1999). The picture that emerges is that of an unacknowledged service being
provided by the wastepickers, which apart from benefiting the waste producer (consumers) also
benefits the waste owners (municipality).
The waste collected by the wastepickers is sold to the waste buyers. They form the next layer in the
pyramid.
Kabariwala/Raddiwala (Itinerant waste buyers)
Kabariwala move about often in the localities to collect newspapers and scrap articles. He is mobile and
instead of picking waste from bins or dumpsites, goes from door to door to buy the waste from the
households. Since his materials have not been mixed with the disposable waste, the quality of plastics is
much higher than that gathered by the wastepickers. The raddiwala remain stationary in one shop and
carry out their business from a fixed location. The raddiwala collects only clean scrap from the
23 It should be noted that the earnings of Rs 30 –Rs 200 of the waste pickers is not only from plastics but also from metals,
paper, etc
24 Personal interview with the informal sector, Dharavi, Mumbai
22
wastepickers, and is not exposed to occupational hazards like the wastepickers. They deal with a variety
of scrap materials like metal and glass, in addition to plastics. In order to have a constant supply of
waste, they develop a relationship of patronage and exploitation with the wastepickers. They buy the
materials from the wastepickers and sell to the next person in the chain that is the scrap dealers.
Scrap Dealers
A scrap dealer gets waste from the stationary raddiwala and the mobile kabariwala. Scrap dealers
generally collect one type of scrap (for instance plastics only). This trade is still an informal activity
because the traded materials are unregistered and the labourers sorting out the waste belong to the
non-wage employment. The dealer sorts the waste, bundles it, and sells it to the bulk buyers.
Bulk Buyers
They are the traders and collect material until it is sufficient to be sent to the recycling plant. Often the
bulk buyers can also be the granulators, and they operate in shanties to convert the plastic waste into
granules. Since the investment is very low, and the quantities of waste are very high, some of the bulk
buyers are also the granulators. They feed the granules into the recycling sector. However, the bulk
buyers have wealth and assets in sharp contrast to those lower down in the chain. It is often difficult to
estimate earnings because of the clandestine and informal nature of their operations.
It has been observed that packaging materials form the major part of the scrap. The quality of scrap
depends on the number of times the material has been processed, the colour, and the general purity
(judged by appearance). It has also been observed that white or transparent plastics are preferred
because they can be coloured accordingly during reprocessing (NPC, 1994). As the plastic waste
reaches the top of the pyramid, it has acquired a fairly high value after passing through the various
actors in the informal sector.
23
Table 3-4 Value addition of plastic waste across the informal sector25
Wastepickers
Roadside bins, open spaces, dumpsites
Rs 2/Kg –Rs 15/Kg (depending on the type and quality)
Kabariwala/Raddiwala
Rs 5/Kg –Rs 22 Kg (Manual sorting)
Scrap Dealers
Rs 6/Kg –Rs 45/Kg
Bulk Buyers
Rs 11/Kg –Rs 52/Kg
Recyclers
The plastic acquires a fairly high value before it is fed into the recycling chain. Although the statistics
are not very recent they are valid even today with minor differences. The table provides only an
approximate idea of the money involved in the trade. Chaturvedi (1999) reports that even without any
reprocessing, the value of the plastic waste within the trade increases by a minimum of 750%.
3.3.5 Plastic Recycling Industry

India is primarily a low cost economy characterised by the low purchasing power of the consumer.
Hence recovery, reuse and recycling are effectively practised and the levels are much higher in India for
all plastic wastes. In fact, the material recycling of plastics is estimated to be 60% in India. (GOI, 1997)
Two reasons have been attributed to this. One is that the throwaway culture is yet to completely
penetrate Indian society. Traditionally materials including plastics are used over and over again. So-
called “plastic mechanics” visit various residential localities on weekdays and offer their services to
repair broken plastics by simple fusion. The other reason is the wide scale informal sector that values
plastic waste (Edwards, Kellet, 1999)
Recycling is an economically driven activity in India providing meaningful employment to a number of

people. The recycling industry in India falls under the small sector since their investments are much
below the stipulated Rs 600,000 (NPC, 1994). India has high rates of recycling, but recycling does not
employ state-of-the-art technologies. The whole process of recycling, starting from sorting to the final
reprocessing of plastic waste, is done by experience. The sorting of plastic scrap is done on the basis of
colour, transparency, hardness, density and opacity. The sorted waste is sent to the granulators. The
recycling technology employed is a mechanical process with the traditional grinding and extrusion to
obtain granules.
The reprocessing sector can be divided into the granulators and the converters. The granulators make
granules from the plastic scrap and sell granules only. The converters make plastic products out of
granules. Majority of the units in the informal sector are the granulators, who utilise their storage shed
25 Central Pollution Control Board, 1996
24
in the houses to carry out the grinding. Such units are often located in slums, and function with stolen
power and single machine extruding units. Scrap storage is done in the backyards, and washing is done
in open drums, and also the workers do not use any protective clothing. Their activities are often
termed as backyard recycling.
Granules produced are now sold to the converters. Conversion units are small industrial units that
process the granules into finished products. The technologies in these industries are also very old and
produced locally. In addition, the sector does not employ highly skilled labour, which also justifies the
poor quality of recycled products.
The recycling industry has emerged parallel to the virgin plastic industry. There are more than 2500
recycling units26 with an average output of 350 tonnes per annum. These 2500 recycling units recycle
60% of the plastic waste generated in the country. The turn over of the recycling industry is estimated
to be 26 billion up to the granulation stage. The post granulation turnover of the industry is estimated
to be 39 billion. This industry provides gainful employment to about 250,000 people (ICPE, 2000).
3.3.6 Environmental Aspects of Recycling

The major source of generation of effluents is the washing and cleaning process. Wastewater is
generated during the recycling process when the plastic scrap is cleaned to remove the dirt and foreign
matter adhering to it. Quantity and characteristics of wastewater generated cannot be generalised, and
depends to a large extent on the contents of the plastic scrap. Soap solution is used to clean the scrap,
and it is reused several times before it is finally disposed of into open drains. The wastewater has high
pollution load in terms of BOD, COD, and TSS depending on the material that was packed. This water
needs treatment before proper disposal into the drains. As of today recycling units in the country
release the wastewater into open drains without prior treatment.
Although PE and PET are less toxic than PVC, the incomplete combustion of PE releases carbon
monoxide. The hygienic conditions of most reprocessing units in the informal sector are poor. Since
toxic dyes and chemicals are used as additives during the recycling, the workers are constantly exposed
to them and the exposure levels may be very high given the fact that most of the units are poorly
ventilated. Since polybag recycling is carried out in shanties, this problem is compounded due to poor
ventilation, as workers find themselves inhaling contaminated air (Chaturvedi, 2000) Although polybag
recycling does not release harmful emissions, the problems of contaminated air arise predominantly
due to poor ventilation.
3.3.7 Quality of Recycled Products

Most of the recycling is done in the informal sector where state-of-art technologies are not employed,
which makes the quality of recycled products, questionable. The recycled polybags27 available in the
market are made from LDPE and HDPE. One of the problems in reprocessing is that the source of
plastic waste cannot be traced, and it is very likely that these may include bottles and packaging from
pesticides etc. In such cases, it may lead to major health and environmental problems. Plastics are not
sorted according to the contamination they have acquired during the first life span. The recycled
plastics are then made into cheap products for storing food and beverages. The contaminants remain
due to physical penetration of the toxic molecules into the plastics and can easily leach out into the
26 The exact number of recycling units is hard to estimate given the fact they are a part of the informal sector. The figures as
reported by various authors are highly incongruous. In order to provide the readers an idea industry figures have been
utilized.
27 For manufacturing a strong carry bag, 25kg of LDPE is mixed with 10kg of HDPE. (Srishti, 1998)
25
food when substances such as water or fat are stored. (Edwards, Kellet, 1999) Attention is not paid to
the quality of the product made, which does not conform to any quality standards in India.
In India plastic recycling is a lucrative business, and its sustainability is maintained by the price
difference between virgin and reprocessed granules. Recycled granules are 60% cheaper than the virgin
granules (Srishti, 1998). Much of this price difference is owing to the poor wages paid in this sector and
pilferage of electricity in the informal sector. As long as there is an ever-growing demand for cheap
plastic items in the country by the poor people, plastic recycling in this low grade manner (using poor
quality plastic waste in low grade melters and extruders most of which do not have temperature control
mechanisms) with toxic additives and colours will continue. The range of end products produced from
recycling is seemingly endless, and suffices the demand of a population living below the poverty line,
which accepts products of lower quality.
Therefore the structure of the plastic recycling industry indicates that there are several issues of
concern that need immediate attention. Some of the issues pertain to the health and hygiene of the
workers involved in the reprocessing trade, upgrading of processing equipments used in the recycling
of plastics, quality of the effluent from the recycling plants, and finally, the quality of the products from
recycled plastics waste.
3.4 Stakeholders of the Plastic Waste Management System

Clearly there are several inter-sectoral partnerships for managing plastic waste in India. The
interdependencies reveal a complex network involving a number of actors and institutions engaged in
collection, disposal, and recycling of plastic waste.
The relationships in the system are illustrated in Table 3-5. Relationships exist between formal agents,
formal and informal agents and among the informal agents. The nature of the relationship varies.
Among the formal actors the collaboration is driven by regulatory mechanisms. The relationship varies
from formalised patterns to more voluntary networking and cooperation. The partnership between the
formal and the informal sector is guided by profit and in some cases developmental concerns where the
objective is to uplift the ragpickers. Among the informal sector, the relationships are primarily
commercial and driven by subsistence and profit.
The nature of relationship existing among the various actors could be classified as follows:
• Regulatory (formalised relationship guided by the government policies and interventions),
• Conditional (commercial relationship based on the principle of reciprocity—Supply of plastic

waste for a price),
• Voluntary (cooperative and developmental relationship due to peoples perception).
Besides the regulatory relationship, the industry has also come up with voluntary initiatives of
awareness generation in the view to protect the image of the plastic industry. The Indian Centre for
Plastics and Environment (ICPE) has been set up as a result of the recommendations made in the
plastic waste management task force28. The ICPE has representatives from the plastic industry,
regulatory community, and research organisations. Since the plastic industry has been in constant
scrutiny with the littering problem, the industry is working on raising public awareness among the
28 Plastic waste management task force was set up to look into the issues of plastic waste management in India. One of the
recommendations of the task force was to establish the Indian Center for Plastics and Environment. (Details Refer: Chapter
4.1)
26
public on the appropriate disposal of plastics. It also publishes a quarterly newsletter to communicate
its achievements to ensure a sustainable image of the plastic industry amongst the consumers.
The NGOs29 are involved in the enhancement of the informal sector, and are instrumental in
mobilising pilot projects to integrate the activities of the formal and informal sector. Some of the
NGOs are involved in improving the skills of the wastepickers so as to seek alternative employment.
Keeping the city clean is a responsibility of the municipality, however, they cannot carry out this
activity alone. The plastic waste management process has various dimensions, which require the
involvement of the formal authorities, the non-government organisations, the informal sector and the
industry. This necessitates co-operation and co-ordination among the various sectors, rather than an
isolated approach for better management of plastic waste. Table 3-5 identifies these interdependencies
that exist for managing plastic waste in India (Buekering et al, 1999b).
29 Delhi based NGO Chintan has initiated a pilot project involving the municipality and ragpickers of the locality. The
wastepickers with the assistance of the NGO will separate the organic and inorganic waste. The organic waste will be sent
to the composting plant owned by the municipality. The inorganic waste will be handled by the wastepickers and fed into
the recycling chain. (Personal interview with the NGO Chintan)
27
Table 3-5 Existing partnerships for managing plastic waste
Partnership Agents involved Activities Relationship Incentives
Government-- Municipality – Collection of waste and Formalised --

Government State Government keeping the cities clean and
enforcement of the legislation
Industry-- ICPE--- Awareness raising on proper Voluntary -
Public Consumers disposal of plastic products
Government - Municipality-- Trying to uplift the informal Cooperative Better
Public NGOs sector by providing them Commercial collection and
proper conditions for proper disposal
collection of the waste
Governement - Wastepickers- External involvement of the Weak -
Informal Municipality informal network and relationship,
complementing the activities (Parallel
of the municipality existence)
Government – Government – Working towards introduction Formalised Government
Research Research and of biodegradable plastics in policy
Development the country
organisations
Informal- Scavengers/Junk Conduit for waste plastic Commercial Subsistence
Informal dealers or buyers - recovery from source –first and profit
--wholesalers step in recycling
Informal- Buyers or junk Conduit for waste plastic Commercial Profit
Formal dealers and recovery from middlemen to
wholesalers --- the recyclers
recycling units
Informal- Scavengers /junk Recognising waste pickers Developmental Service
Public dealers contribution and developing Motivation
/wholesalers--- their skills.
NGOs
Consumers- Households— Collection of plastics for Commercial Profit
informal Scavengers /junk recycling
dealers
/wholesalers
3.5 Problems Related to PET and Polybag in India

Figure 3-3 presents the various environmental and social problems related to plastics in India. The two
commodity plastics, extensivley used in packaging have significantly contributed to the litter problem in
the country.The problem with both these products is that there is a limited incentive for the ragpickers
to collect them.
28
Polyethylene
bags and PET
Users of Polyethylene bags and bottles
PET
Households Distribution Transport

Packaging
Travellers and Waste

miscellaneous Littering since waste pickers
have limited incentive to collect
the PET bottles and plastic
Public dustbins or bags
Hotels, commercial
garbage dumps
establishments
Waste Polybags: Death of cows, clogged

collected drains, loss of soil fertility, health
Occupational hazards and air pollution
hazards due to bare Waste pickers
hand scavenging
Waste during sorting

Scrap Dealers
Bulk Buyers
Granulators Poor infrastructure for granulation,

Backyard smelters
air pollution, water pollution
Converters
Air pollution, outdated recycling technologies,

downcycling of plastics
Figure 3-3 Problems related to plastics in India
29
3.5.1 PET : An emerging problem

Increasing consumption of PET
PET has become an ideal food packaging material. Its low weight helps to reduce transportation costs
and its covenience has gained it higher consumer acceptance than glass. As a result PET is substituting
glass in packaging all over the world as well as in India. The estimated increase in consumption is about
45,000 tonnes. With the rising use of PET in a variety of applications like edible oil, soft drinks ,mineral
water etc, there is a need to manage the large amount of PET waste that would be generated. Although
the current per capita consumption is 0.04kg as compared to the 3.5 kg average of developed countries,
PET littering has become pronounced in India (The Economic Times,2000).This situation is likely to
deteriorate given the fact that there is a dearth of clean water supplies in the country.
Poor collection of PET waste
Although the informal network is quite active in collecting plastics, PET bottles do not figure in their
list during the collection. The wastepickers30 reveal that there is no demand for the PET bottle waste in
the informal chain predominantly because the wholesalers have no outlets to sell the waste. Since the
PET bottle cap is made of a HDPE, that carries a value in the informal sector, they are collected by the
wastepickers.
Limited Recycling facilities available
Recycling of PET is primarily in the formal sector and is undertaken by few units in Chennai, Mumbai,
Gujarat, and Kanpur in India. These units find it uneconomical to collect local waste for reasons that
are not clearly known to the author. There is not much information available on PET recycling units in
country and therefore the exact reasons for poor collection have not been identified. The Plastic Waste
Management Task force reports that existing recycling capacity available in the county is in excess than
the plastic PET consumption in the country thereby necessitating imports (GOI, 1997). Some of the
units31 suffice the capacity by importing PET waste from other countries like Germany, USA and in
this unit PET waste is converted to polystyrene fibres (Leonard, 1994).
Existing market for recyled PET
Recycling of PET leads to thermal degradation due to tendency of the molecular weight to decrease
and it is the molecular weight that determines the usefulness of recycled PET. However, PET bottle
waste is valuable, and is recycled to polystyrene fibres in India and finds use in a variety of garments
from sweaters to sleeping bags and pillows. Therefore the secondary market for recycled PET is well
developed. Some polystyrene fibre manufacturers are already using recycled PET for fibre production.
In fact there are packers /fillers32 that are also contemplating to set up bottle to bottle recycling plants
so as to minimise the PET consumption.
30 Interview with the wastepickers at Dharavi, Mumbai.

31 Futura Polymer is one of the PET recycling units in the country that imports waste from other countries. It clearly specifies
the nature of waste that needs to be exported from other countries to India. Here PET is recycled to polystyrene fibers.
Converting PET waste to fibers does not require very clean PET waste. (Manfred, 7 September 2001) Since local waste can
be utilized for these processes it is not clear why the local waste (which may not be as clean as imported waste) has not been
attractive for these PET recyclers.
However, bottle-to-bottle recycling of PET requires clean PET waste (Manfred, 7 September 2001) and hence it is
comprehendible that such recycling units may need uncontaminated PET waste that may not be readily available in India.
32 Interview with Bisleri, New Delhi.
30
Changing lifestyles in urban India, higher disposable incomes , growth of Indian middle class as well as
increasing concerns about personal hygiene, will propel the PET consumption. Alongside the problems
of litter , disposal and recycling will increase given the fact that there is no comprehensive legislation on
PET waste. As it is for other post consumer plastic waste, the consumer recycling of PET waste hinges
on four incentives: Volume of waste, economy, practicality of reclamation, and the existence of the
secondary market. The first two criteria could be the main reasons for the lack of collection of PET
waste in India. Either the waste available is too low since there is not enough awarenss among the
ragpickers and the informal network or these units don’t find it economical to collect local PET waste
which is very unlikley.
3.5.2 Polybag: A major concern

For most Indian citizens the environmental problems of plastics have focused on the visible non-
biodegradable plastic bag. As shown in Figure 3-3 polybags are another major component of the litter
in the country. Although there are no figures that could indicate the size of the vexing problem, the
impacts caused by the bags indicate that they are a product of concern for India.
Some of the main issues that have been associated with polybags in this respect are as follows:
Choked soil
Polybags are non-biodegradable, which means that they do not dissolve or disintegrate into the soil.
Besides, they are non-porous, and do not allow the free flow of water and air, thereby choking plants.
In India, when open dumping grounds are filled, they are levelled out and converted into parks. If the
waste has non-biodegradable garbage like plastic bags, there is a risk of loss of biodiversity. In the City
of Mumbai, there has been a loss of 140 trees in an environmental park, which was previously a
dumping ground. Since the soil was full of non-biodegradable material, predominantly plastic bags, the
tress could not anchor themselves firmly into the ground. When high velocity winds blow over the city
during the monsoon season, the trees get uprooted, thus destroying flora (Times of India, 2001).
Choked drains
Choked drains are a serious hazard caused by the polybags. Since they are light, and in cities like
Mumbai, where monsoons are heavy, polybags have choked the drains, thereby causing water logging
and inconvenience to the citizens. Further, infection and disease also become rampant as a result of the
water stagnation.
Animal deaths
Since cows are allowed freely to graze close to the bins in India, they ingest the plastics along with
organic waste in it. Accounts from across the country tell of post-mortems that reveal how bales of
accumulated plastic bags have killed cows. Polybags kill animals by obstructing their intestine. If the
blocking is complete, the animal is unable to eat and dies.
In addition to the cows, the coastal creatures like turtles are also affected as they mistake the multi
coloured polybags for jellyfishes. As they ingest them, their intestines are blocked and metabolism is
impaired.
The root cause of the litter is that polybags are not collected. Polybags have a commercial value, but it
is not very remunerative for the wastepickers to collect. Added to this, the households dispose their
garbage in these polybags, which makes it unhygienic to collect bags. Since the dirty bags are
uneconomical to collect, they are left to litter. A clean polybag fetches between Rs 5- Rs 10/kg but it
takes 200 to 350 polybags to make a kilogram. Wastepickers are not willing to undergo this back
31
breaking exercise to collect the thin polybag. Instead they prefer to collect materials that can fetch them
a higher price and are easier to collect, for instance: milk pouches.
Since plastic bags are cheap, the vendor or retailer hands them out generously to the consumers. Since
these carry bags can be reused only once or twice, they soon end up in the garbage bins. The short life
span of the carry bag as well as improper collection and disposal, leads to the compounding problems
mentioned above.
Food hazard
In addition to contributing to litter, polybags, particularly recycled polybags pose a major health hazard.
The main hazards are associated with the chemicals used to colour plastic bags. Small amounts of lead
and cadmium are added during the manufacture, and these could permeate into food products stored
in the bags. The recycler may sell polybags for use only as a carry bag, but the vendors are unaware of
the risks of packing food products in coloured plastics.
In essence PET and polybags are a nuisance since they are not collected. Polybags remain an
unattractive economic proposition for the wastepickers, and in the case of PET, there is limited value
for the waste in the informal sector. In towns, cities and tourist centres, plastic bags and PET have
become a plague, and attempts to prevent this have come forth from the State, Central Government
and NGOs. The next section describes the attempts of the State and the Central Government to
alleviate the problem.
32
4. Statues Relating to Plastic Waste Management In India

Responsibility to protect the environment and enforcing the existing regulation lies within the Ministry
of Environment and Forests (MOEF) in India. The Central Pollution Control Board33 (CPCB)
reporting to MOEF is an autonomous body, with no bona fide powers to enforce laws, with its major
function to provide advice and technical assistance. In addition, every state has a State Pollution
Control Boards (SPCB), which is an autonomous body under the State Government that enforces rules
and regulations. An increasing number of environmental legislation requires the SPCB and CPCB to
work together in implementing rules and regulations.
4.1 Plastic Waste Management Task Force

The increasing media pressure to address the problem of plastic litter and the need to regulate the
existing plastic waste management led to the formation of the Plastic Waste Management Task Force in
1996. Prior to 1996, there had been no definite policy and legislation framed in respect to plastic waste
in India. However the state of Himachal Pradesh, in view of the acute plastic litter problem, introduced
the HP Non–Biodegradable Garbage Control Act in 1995.
The objectives of the Plastic Waste Management Task Force were to:
• Formulate a strategy and prepare an action programme for managing plastic waste.
• Propose incentives and penalties to check the growth of plastic packaging waste.
• Prepare guidelines for the use of plastic packaging in the country. (GOI, 1997)
The Task Force came up with a 14-point action programme. Although all of these 14-point
recommendations are yet to be implemented, the Guidelines on Plastic Packaging and Guidelines for
Recycling of Plastics were formulated by the Ministry of Environment and Forest and the Bureau of
Indian Standards. These guidelines were a useful measure given the fact that no formal management
system existed previously.
4.1.1 The Guidelines for Plastics Packaging and Packaging Waste in

India
The guideline aims at a first priority, to prevent the production of packaging waste, encourage reuse of
packaging, recycling and other forms of recovering packaging waste thereby reducing the final disposal
of such waste. Therefore, the aim of source reduction has been incorporated in these guidelines. The
guidelines cover all plastic packaging placed in the market today. They emphasise the need to think of
recycling not when the product waste accumulates, but at the start of the development process. Thus,
they place the onus for source reduction in packaging not only on the packer, but also on the resin
manufacturers and processors.
The guidelines call for establishing an organised system of return, collection and recovery of plastic
waste and, in order to encourage recycling, reuse and recovery appropriate incentives and penalties
have been proposed.
33 The CPCB also coordinates the activities with the State Pollution Control Boards for implementing the respective
legislation.
33
The Ministry of Environment and Forests has been given the responsibility to notify these guidelines
to the plastic industry, packers, users of plastic packaging and the general public
4.1.2 Guidelines for Recycling of Plastics

The Guidelines for Recycling of Plastics were published with a view to bringing discipline to the
recycling practices in the country. They prescribe standards for the segregation and processing of
plastic waste, and also instruct the manufacturer of plastic products to use marking on the finished
product. Such a marking would facilitate the identification of the basic raw material. In respect to
recycled plastic products, it is necessary to indicate the percentage of recycled content in the product.
It should be noted that the guidelines by themselves are not statutory, and need not be followed, unless
specified under any policy.
4.2 National Law on Polybag
4.2.1 Recycled Plastic Manufacture and Usage Rule

This is the first Central Government Rule on plastic waste, formulated to address the plastic bag
problem. The rules have been formulated based on the recommendations made by the Task Force. The
Ministry of Environment and Forests have notified it, and the Rule has the following specifications.
• The Rule prohibits the usage of carry bags and containers made of recycled plastic bags for
storing, carrying and dispensing or packaging of foodstuffs. Mandates the use of only virgin
bags of 20 microns of natural colour without any dyes and pigments for packaging foodstuffs.
• The Rule specifies minimum thickness of the carry bags for virgin to be 20 microns and
recycled to 25 microns and calls for the producer of the plastic product to mark the product as
stated in the Guidelines for Recycling of plastics. It also allows the use of recycled polybags of
a minimum thickness of 25 microns for non-food applications provided the dyes and pigments
used conform to the specification in the Food Adulteration Act.
• The Rule calls for recycling of plastics to be carried out according to the Guidelines for
Recycling of Plastics.
The State Pollution Control boards are responsible for the enforcement in the states and the Pollution
Control committees in the union territories.
4.2.2 State specific initiatives

Few states in India have instituted state laws to minimise plastic waste. Some of the states have adopted
the central legislation or have formulated their own State rules. States (provinces) in India have been
empowered under the Environmental Protection Act to take their own measures independently or in
consultation with the Central Government to protect the environment.
Himachal Pradesh was the first state that formulated a state rule to protect the state from the rapidly
increasing non-biodegradable garbage. The States of Goa, and Jammu & Kashmir have also taken steps
to control the plastic menace prior to the Central Government Rule, particularly since the menace was
affecting their tourism industry, which is a major source of revenue in these states. Similar initiatives
are being contemplated by other states to minimise the problem of littering. Table 4-1 provides the
initiatives taken by selected states in India.
34
States Date Action Taken
Himachal Pradesh July 1996 A ban was placed on plastic littering. The act also provides
(Shimla)34 provision for imposing deterrent penalties.
Ban on the use of plastic bags. They have been replaced by

Jammu and Kashmir November 1998 bags of alternative material such as jute and paper.
March 1999 Ban on thin plastic bags but failure of the rule due to poor
enforcement.
Maharashtra
(Mumbai) State law was passed upholding national law prohibiting

manufacture of polybags less than 20 microns thick and
15 August 2000 also mandated names and addresses of manufacturers to be
printed on all bags. It also stated that licences would be
revoked for all who disobey the rule
The Mumbai Municipal Corporation has appointed a team
of 97 detectors who monitor the compliance and fine the
defaulters. Harsh measures like a fine of Rs 2000 (USD 42)
for any shopkeepers using the bags and Rs 500 (USD 10) to
the user have been imposed. In fact the anti plastic drive
had led to the collection of Rs 100,000 (USD 2127) in fines.
January 1998 Goa Non-Biodegradable Garbage Disposal Act
15 August 2000 Goa State Government announced a total ban on the use of
recycled plastic bags less than 20 microns.
Goa
Eighty day clean up drive to remove plastic bags from
October 2000
drains, beaches and roads of the city.
Table 4-1 State specific initiatives to address the problem of plastic waste
4.3 Ecomark Proposed Scheme on Labelling of Environment

Friendly Products – Plastics
To increase consumer awareness, the Government of India launched the eco-labelling scheme known
as Ecomark in 1991 for easy identification of environment-friendly products. The Ecomark is the eco-
labelling scheme in India. The Ecomark label is awarded to consumer goods, which meet the specified
environmental criteria, and the quality requirements of Indian Standards. Under the Ecomark scheme,
the requirements for plastic products are that material for packaging should be recyclable or
biodegradable.
34 The Himachal Pradesh Non-Biodegradable Act. (MOEF, 1997)
35
The scheme states that plastic packaging used for packaging food, pharmaceuticals, cosmetics and
drinking water shall comply with the relevant Indian standards and packaging of non-food, non-
pharmaceutical and non- drinking applications shall be from recycled plastics, which shall, apart from
fillers and reinforcing agents, be a minimum of 30% by weight of compatible plastic wastes.
In the case of PET there is no comprehensive legislation in India but there have been discussions in
the National Plastic Waste Management Task Force on the possibility of introducing a take back
scheme for PET waste in India. The discussions and the outcome of the meetings will be discussed in
Chapter 5.
36
5. Analysis of the Existing Policies

The existing policies related to PET and polybags will be discussed separately in individual subsections.
The policies on polybags will be analysed using the framework, which has been described in Chapter 2.
This analysis will include, the objectives of the policy, the specifications in the policy and also a case
study of Mumbai, which will serve to illustrate the implementation of the rule. Given the absence of
any formal legislation on PET waste, the existing situation will be described, and the discussions on
take back will be analysed.
5.1 Polybags
5.1.1 Recycled Plastic Manufacture and Usage Rule

The only comprehensive Rule on polybags and plastic waste is the Recycled Plastic Manufacture and
Usage Rule of 1999 mentioned in 4.2.1. The Rule was passed mainly to control the packaging of food
products in recycled plastics, as well as to control the littering problem in the country.
The objective of the Recycling Rule is analysed in the first subsection as to understand if the objectives
of the policy contribute to sustainable waste management. Following this, three main specifications in
the Rule are discussed, so as to understand, the rationale behind formulating these specifications, and
how these specifications could contribute to attaining the objective of the Rule. Further the experiences
of Mumbai in implementing the specifications of the policy in practice are analysed.
5.1.1.1 Objective of the Recycling Plastic Manufacture and Usage Rule

The objective of the Recycling Rule35 was to:
• Protect human health from the risk of coloured plastic bags on human health. (Caused mainly
due to leaching of dyes and pigments added during the manufacturing stage)
• Minimise the littering problem by encouraging reuse and recycling of polybags.
When the objective of the Recycling Rule is scrutinized with respect to objectives of sustainable waste
management policy, the objective of the existing policy has been extremely myopic. The existing policy
aims to address the littering problem by encouraging reuse and recycling. The problem of littering
arises primarily due to increased consumption, indiscriminate use and disposal, and inefficient waste
management system. Assuming that an increase in thickness can lead to an increase in the price of
plastic bag and dissuade the consumer from using plastic bags, the level of thickness of a carry bag that
can affect consumption needs to be more than the stipulated 20-micron limit. Therefore the problem
of over consumption has not been explicitly targeted by the policy. Since plastics are not appropriately
priced they are too cheap for the consumer and this leads to an indiscriminate use and disposal by
them.
The policy should have ideally aimed to minimise the polybag waste generated given the fact that
problems with the product are compounding. Targeting “Waste prevention” as a policy objective
would have resulted in lowering waste management costs, and minimised human and ecological health
risks associated with the disposal of non-biodegradable plastic bag.
35 The Recycled Plastic Manufacture and Usage Rule will be referred to as the Recycling Rule/Rule throughout the analysis
and conclusion, since it is the only Rule/Policy on Plastic waste in India.
37
However, targeting over-consumption has also proved to be very difficult; in Italy for example, a tax of
100 lire (approx US$ 0.08) had been imposed on every plastic bag, but despite this, the consumption of
plastic bags did not show a decreasing trend (Fung, 2000).
5.1.1.2 Specifications of the Recycled Plastic Manufacture and Usage Rule

There are three main specifications in the Rule, which aim to achieve the objective of minimised
littering and protecting the health of citizens. Each specification in the Rule will be discussed in brief.
Discouraging coloured Recycled Plastic bags for Packaging Food Items
Recycled polybags are mostly manufactured in the informal sector where environmental standards and
quality standards are lax. There is a risk that pigments and dyes36 added during the manufacturing
process could leach out into the food products. Hence the use of coloured recycled and virgin polybags
for food products has been prohibited. The Rule also specifies that food products need to be packed
only in virgin material of natural colour with out any pigments and dyes. This was done to reduce the
health risk faced by the citizens. Therefore the Rule may help to control the health impact of toxic dyes
leaching into food.
However, enforcing this specification is an arduous task given the fact that the informal sector is widely
scattered and difficult to regulate. This may need mammoth policing efforts and monitoring on a large
scale. Since coloured virgin and recycled bags are allowed for non-food application, it may be very
difficult to ensure that the vendor does not pack food products in these bags. Here, the awareness and
cooperation of the public, as well as strict enforcement is needed to prevent the vendors and the
consumers from using coloured virgin and recycled bags for packaging food items
Recycled and Virgin Coloured Bags Allowed for Non-food Applications
The Rule allows the use of coloured virgin and recycled bags for non-food applications provided the
dyes or pigments used in the manufacture of polybags are non-toxic, and should conform to the
specifications in the Food Adulterations Act. The rational behind this is that a complete ban on
recycled bags would affect the recycling industry. In order not to adversely affect the recycling sector
recycled bags have been permitted for non-food application.
The specification that pigments and dyes have to conform to the food adulteration act is also very
difficult to ensure, given the fact that the carrybag recycling units are widely dispersed and operate in
shanties. Hence it may be impossible for the enforcing authorities to single out every recycler to abide
to this specification and ensure that the dyes and pigments used by the recycling unit conform to the
Act.
Ban on carry bags less than 20 microns
This specification mainly intended to curb the littering problem in the country. Prior to this, carry bags
ranging from 5-10 microns were used, and were creating a nuisance. The wastepickers would not pick
them and hence was contributing to the problems mentioned in section 3.5.2. Therefore, the rational
behind the increase in the thickness was that wastepickers would have an incentive to collect thicker
bags of higher value; and since thicker bags meant higher price for retailers, they would charge the
consumers, and this may initiate a tendency of reuse among the consumer.
36 Dyes containing cadmium and lead are added during the manufacturing process to obtain various colours of plastic bags.
38
The logic behind the 20-micron limit has been a debatable issue. Representatives from the industry and
ministry reveal that 20 microns37 was a consensus number (Personal Interview). The idea was to move
from the existing 5-10 micron bags, and 20 micron was the limit where there was an agreement among
all the stakeholders.
Whether this specification can alleviate the littering problem is to be analysed in the next section as
enforcement also varies from state to state. Since the difference in thickness between 10 microns and
20 microns is not visible, the enforcement authorities need to be well equipped technically, and have to
be trained to identify bags less than 20 microns. This may involve an additional cost to the enforcing
authorities. Further, since vendors are mobile, monitoring them is not an easy task. Facing a low risk of
prosecution these vendors may continue to use bags less than 20 microns.
Recycling to be carried out according to Guidelines
This specification in the Rule is aimed at assisting the recycling industry, and improving the quality of
recycled plastic products. It clearly states that recycling needs to be carried out as per the Guidelines for
Recycling of plastics. This is a good effort since the recycling sector is in dire need to improve its
recycling practices. However the Rule does not mention as to how these guidelines need to be
implemented. Further, abiding to the guidelines would lead to increased costs for the recyclers. As
stated earlier in section 3.3, the recycling sectors are small-scale investments and may not be ready to
invest in technological upgrades. Instead, they may continue the operations illegally. The recycling
sector being partly in the informal sector is not accountable, and is highly scattered. Hence this
specification also may be difficult to enforce (given the limited resources and manpower of State
Pollution Control Boards), since this involves a dual task of first identifying these illegal recycling units,
and then ensuring that they comply with these guidelines.
Having discussed the specifications theoretically, the next step is to analyse the experiences of Mumbai
in achieving the objectives, and implementing the specifications of the policy
5.1.2 Mumbai experience with the Recycling Rule

Mumbai (Bombay) is the capital of the State of Maharashtra. It is the industrial, financial and
commercial capital of India. These financial and commercial institutions provide considerable
employment opportunities that encourage large-scale migration to this city from different parts of
India. High migration has led to unplanned development and has resulted in unprecedented crowding,
due to which certain areas have very high population densities. This situation is further aggravated on
account of the fact that 60% of the population (estimated population of Mumbai is 12.5 million) lives
in slums. Due to this enormous unplanned development, civic amenities and services are strained.
Waste management has been a serious concern for the municipality of Mumbai. The waste generated is
about 6000 tonnes/day and is expected to increase to about 14,000 tonnes/day by 2011 (BMC, 2001).
With increasing quantities of waste and limited landfill capacity, Mumbai is a facing a major disposal
problem. All the landfill sites are in the midst of dense inhabitation and there are complaints of
environmental pollution caused due to groundwater contamination, odour etc. Besides, the existing
landfill sites are expected to last only for 8-10 years and there are no new sites available for disposal.
37 Interviews with recyclers reveals that carry bags are made from a combination of HDPE and LDPE. LDPE provides
strength to the carry bag and is more expensive than HDPE. It is also possible to have a 5-micron bag just made from
LDPE, but keeping the cost economics in the recycling sector, which utilizes a mix of HDPE and LDPE, 20 micros
seemed to be a good number. From the virgin industry point of view, they did not prefer a thickness that can necessitate
reuse to a large extent since this would obviously lower the demand. Hence, keeping all the perspectives in mind, the
government agreed for 20 microns as the limit. (Interview with MOEF)
39
Rising amounts of waste, the inefficiencies of the municipality to collect waste, and the non-availability
of disposal sites contribute to littering. Plastics bags, a major component of the litter are seen clogging
the underground drainage system during monsoons that hit Mumbai in June and July. The magnitude
of the problem is very high in Mumbai where clogging of drains hampers the commuting of Mumbai
residents.
When the problem of clogged drains became severe, the Municipality of Mumbai passed a resolution
seeking a complete ban on plastic carry bags. However, this was not achieved due to political reasons38.
Subsequently in March 1999, the Mumbai Government passed a law banning thin plastic bags but the
law was completely unsuccessful39.
Problems were encountered during the implementation, as the municipalities were not well equipped
for enforcing the law40. Learning from past experiences, the Mumbai Government decided to start
fresh and accepted the Central Government Rule, that is the Recycled Plastic Manufacture and Usage
Rule passed in September 1999, but with well-prepared administrative machinery.
So in August 2000, Mumbai adopted the Central Government Rule to ban plastic bags less than 20
microns and recycled plastics for food products. The Municipality carried out a series of awareness
drives prior to the enforcement of the Rule in August 2000.
The following table presents a few highlights on the course of actions that occurred during the anti-
plastic drive in Mumbai, and the efforts taken by the Mumbai Municipality to implement the Recycling
Rule.
15 August 2000
Decision of the Mumbai Municipality to ban plastic bags less than 20 microns.
17 August 2000
Fines were mainly collected from shopkeepers, users and vendors who violated the law. The ban on
thin plastic bags came into effect with the nuisance detector squads seizing over 8,000 kg of plastic.
The anti-plastic campaign kicked off with a bang, with the Municipal Corporation recovering over
Rs 100,000 in fines on just the second day of the ban.
18 August 2000
The fear of being caught with coloured and thin plastic bags had seized the city. Citizens and
shopkeepers had consequently stopped using plastics, out of fear of being fined Rs 2,000 if caught
with a plastic bag. Inspectors from the licence department, shop and establishment department and
nuisance detectors were conducting random inspections in the city shops. Advertisements were
appearing in newspapers about the availability of 20-micron bags, which the people can buy for
their use. After the advertisements started appearing on the availability of 20-micron bag,
shopkeepers started handing out plastic bags to their customers.
30 August 2000
In a bid to garner support from academic institutions like school etc to ban thin plastic bags, the
38 Interview with the Deputy Municipal Commissioner, Mumbai
Mumabi Municipal Corporation (BMC) and the sherif's office organised a seminar at several
39 schools.
Even afterThe entire
the ban exercise
on thin plasticwas
bagsaccompanied
the vendors werebyselling
a highbagsprofile mediaThe
of 8 microns. campaign.
main problem with implementation
was the large number of illegal plastic manufacturing units rolling out thin plastic bags into the city everyday and the
potential unemployment of this illegal plastic labour force. These considerations, along with political bickering (the
Following the ban there is a follow up to ensure compliance. The nuisance detectors carry out
pollution control boards blaming the Municipality and vice versa') had made it extremely difficult to effect any change on
random checks
the presence toplastic
of thin ensure that
carry bag.shopkeepers and
(Edward, Kellet, users do not use coloured bags and ensure that bags
1999)
40
are of 20-micron thickness. The revenue generated in the form of penalties during the anti-plastic
Interview with the State Ministry of Environment, Mumbai.
drive has risen to Rs. 12, 39,950 (from August 2000 to July 2001).
40
In order to evaluate if the objectives of the Recycling Rule have been achieved in a sustainable manner,
the criteria developed in framework will be utilised for the evaluation.
5.1.2.1 Sustainability of the Recycling Plastic Manufacture and Usage Rule
Effectiveness
A policy is said to be effective if it achieves the goal(s) set forth in the policy. Here, the aim of the
policy was to minimise littering, and reduce the negative impact of coloured plastic bags on human
health. In Mumbai, the Rule has been partially effective since some of the specifications in the Rule
have been enforced effectively.
Coloured plastics bags out of the market
Mumbai has been successful in removing coloured plastic bags out of the street. It has ensured that the
food products are packed in virgin plastic bags of natural shade41. In addition, it has also ensured that
coloured bags are not used for non-food applications. Therefore, the objective of reducing the risk of
dyes and pigments on human health has been achieved to a large extent.
Thicker bags are not collected
The second objective of reduced littering has not been successful to a large extent. The assumption
that increasing the thickness of plastic bags could minimise littering has failed. The primary reason
being that increased thickness has not initiated reuse and increased recycling. However, the ban on
plastic bags less than 20 microns has minimised the fluttering42 of plastic bags in parks, beaches and
trees. Since the bags are heavier, they remain on the ground and continue to litter. The problem of
choked drains has also not been alleviated since thicker bags are also not collected to a large extent, and
hence continues to clog sewers.
Although the increase in thickness is an incentive for the wastepickers to collect bags (they would get
more money for few bags collected as compared to thin bags), the problem remains that they are still
of marginal value for the wastepickers. The main reasons for wastepickers not collecting carry bags are
the manner of disposal by the consumers, and also that it is not highly remunerative. In India it is a
common practice to dispose household garbage in plastic bags (more so in carry bags). This makes it
extremely difficult for the ragpicker to collect the carry bags43. They find carry bags highly unprofitable
if they are dirty, since dirty carry bags are uneconomical for recycling, and also fetch a lower price
Hence, they prefer to collect other plastics that fetch higher prices, like milk bags.
Another reason for the continuing problem is that the increase in thickness has not initiated a tendency
of reuse. Consumers are so used to the convenience of disposable plastic bags, that it is very difficult to
initiate a practice of reuse. In addition, the common perception is that a carry bag symbolises the use
and throw culture, people never care to reuse a carry bag, but rather prefer to dispose their garbage
41 During the authors visit to Mumbai a random survey of the shopkeepers revealed that they only use virgin plastic bags of
natural shade and avoid using coloured bags due to fear of cancellation of licenses. The author has not observed coloured
plastic bag usage either by the consumer, shopkeepers or in the garbage bins
42 Prior to the enforcement of the Rule, multi coloured plastic bags were seen flying around in parks and beaches. (Interview
with Mumbai Municipality)
43 A clean carry bag fetches him a higher price. If the bags are dirty they have to be washed - a labour intensive and time
consuming job prior to being sold for recycling
41
after their first use. Further people never pay for even the thicker bags44. Therefore, a bag that is not
paid for is obviously not valued by the consumer. The shopkeepers, despite the increased thickness,
find it reasonable to hand out free bags as a part of their service. In essence, the thickness of 20
microns has been unable to initiate reuse.
Increasing the thickness of polybags has failed to initiate a tendency of reuse among consumers, and
also become an attractive proposition for the wastepickers to collect them for recycling. Therefore the
assumptions made during the drafting of the Rule have failed and the problem of littering continues.
Increase in virgin plastic consumption
While the increase in thickness has not increased reuse and recycling, a direct implication from the Rule
has been an increase in virgin plastic consumption. The policy calls for a complete ban on packaging
food stuffs in recycled plastic bags. Therefore, there is a rise in virgin polybag consumption in the
food-packaging sector. In addition, since there is a ban on thin bags, there will be a substantial increase
in virgin plastic to manufacture bags of 20 microns from the previously existing 5-10 microns. The
throughput of virgin plastic will increase because more plastic will be required to make thicker bags. So
the Rule encourages the use of virgin plastic instead of recycled plastic. Consequently, the idea of
resource conservation has been lost in the Rule. By using recycled products we aim to slow down the
speed and volume at which we consume our finite resource. This fact has been overlooked in the
Recycling Rule.
Thickening of plastic bags has proven to be a means of increasing plastic consumption in the country.
The beneficiaries from this are the virgin plastic industry, and polybags manufacturers. It is not in the
best interests of the virgin plastic industry to promote recycled products since this would be to the
detriment of their own market. Economic necessity calls for an increase in the sale of virgin plastic to
pay back investments in petrochemical plants and processing operations.
Wastepickers: Need for Upliftment
The rationale behind increasing the thickness of plastic bags, so that it becomes lucrative for the
wastepickers to collect them for recycling has also failed. The concern that the wastepickers have a
better livelihood is justified, but this cannot be achieved by thickening plastic bags alone. One tends to
wonder whether the concern was a means to increase the virgin plastic use in the country. There are no
provisions in the policy that contribute to their empowerment, or lessen their vulnerability to
occupational hazards. (Chaturvedi, 1999) In fact, the government has yet to realise the unrecognised
financial contribution of wastepickers to the waste management system. There is a need for rethinking
the position of wastepickers; not to see them as undesirable migrants, but as useful members of society
whose services can be better utilised and focussed. Hence, the government should move from
providing a piecemeal solution of thickening plastics, to improve the livelihood of wastepickers, to
taking concrete measures to best utilise their services, and integrate them into the waste management
system.
Cost efficiency
Costs associated with policy have been discussed quantitatively. Due to unavailability of data on the
estimates of benefits associated with the policy, this aspect has been discussed qualitatively only. The
44 However the cost of the polybags is transferred indirectly by the shopkeeper to the user. The shopkeeper incurs a cost of
Rs 30 (US$ 0.6) for 100 virgin plastic carrybags purchased. A number of products sold by the shopkeepers give them the
possibility to recover these costs from the consumer. Assuming that ordinary household consumes an average of 3 virgin
carry bags daily, the cost for a month comes to Rs 30 which is a negligible amount for the households.
42
benefits associated with the Rule are: the benefits from reduced risk of contamination of food by
leaching of dyes and pigments and benefits from improved aesthetic beauty of the city.
Costs45 associated with the Rule include predominantly the enforcement costs and promotional costs.
• Extra costs associated with an increased thickness of the plastic bags,
• Costs associated with the salary of 97 nuisance detectors (an average salary of Rs
6000/month),46
• Cost of the equipment (a micrometer costs Rs 2000 and 26 micrometers have been purchased
by the Mumbai Municipality),
• Costs to carry out awareness drive and campaigns.
Considering the costs47 that are available, it could be said that the costs associated with the enforcement
of the policy are relatively small. Careful analysis would be required for determining whether benefits
outweigh the costs in this policy. In view, of the limited possibilities to acquire the relevant estimates of
the benefits and the relatively small costs associated with the policy, no further analysis has been made.
Equity
The increase in thickness in virgin plastic bags has not resulted in a significant increase in costs for the
rich and the middle class in India. A brief calculation of costs associated with the increase in thickness
of polybags to 20 microns is presented below:
Assuming that 100 virgin polybags of 20 microns cost Rs 30, and a middle class household with an
average salary of Rs 10,000/month consumes an average of 3 bags /day, then the costs incurred by
them would be Rs 27/month, which is a small proportion of the income. Next let us consider an
affluent household with an average salary of Rs 50,000/month, and consuming an average of 7
bags/day; the cost to them would be Rs 63/month, which is an insignificant amount.
Consequently, the costs associated with an increase in the thickness of polybags are considered
relatively small for the middle class as well as the affluent in India. Since the total costs are relatively
insignificant a discussion on the distribution of costs among citizens has not been considered
necessary.
Also given the fact that there is a correlation between the quantity of goods purchased, and the number
of plastic bags used, and the fact that the retailers can recover the costs associated with the polybags
through increased sales of goods, we can assume that the costs are being distributed fairly.
Consequently, the fact that the costs associated with an increase in thickness of polybags are pretty
small and that the costs for the polybags are correlated with the amount of goods purchased, leads us
45 Information obtained through email correspondence with the Chief Engineer, Mumbai Municipal Corporation.
46 The municipality officials confirm that no external manpower was utilized for the enforcement of the ban and all the
nuisance detectors are regular municipal employees.
47 Let us assume that the cost of awareness raising activities to be Rs. 10 million/year (a rough estimate based on the author’s
various contacts and impressions from Mumbai). It is known that the total investment in micrometers was Rs. 52000, and
the salary of nuisance detectors is Rs. 7 million per year. Thus, if we calculate the total annual costs, it comes out to be in
the order of Rs.17, 000,000. Given that Mumbai has a population of 12 million, the annual cost per inhabitant is considered
as small.
43
to conclude that these costs are fairly distributed and need not be further analysed from the equity
point of view.
However it is interesting to analyse the other aspect of equity, which is the sharing of responsibilities
among the different stakeholders to bring about a change. Handling the littering problem is a joint
responsibility. The consumers, recyclers, virgin plastic producers, end users are all responsible for the
problem. A close study of the Rule reveals that it has predominantly targeted only the recyclers. It
could be agreed that the recycling sector needs improvement, but this Rule has come down heavily on
the recyclers. Since there is ban on recycled bags for the packing foodstuffs, virgin polybags have
substituted this sector. Added to this, shopkeepers, to avoid the risk of being fined, prefer to use virgin
material instead of recycled. The Recyclers Traders Association confirm that the business of polybags
has suffered due to the enforcement of the Rule (Personal Interview).
The government blames the recycled bags for the problem of littering, since it is perceived that thin
plastic bags that contribute to a host of problems are rolled into the system only by the illegal recycling
units. This is true, but only in a limited sense, since the problems with polybags are associated with
both virgin and recycled material. The causative is the product by itself, and the problems of clogged
sewers, choked animals etc. can be associated with both recycled and virgin plastic bags.
Therefore the policy ideally should have ensured that all the stakeholders be involved in alleviating the
problem of littering. The virgin plastic industry, which is financially and technologically better placed
than the recycling industry, has no roles and obligations according to the rule. Instead, it contributes to
the problem equally, and ironically, benefits from the policy aimed at solving the problem.
Feasibility of enforcement
This Rule has been enforced to a large extent in Mumbai. The municipality has been proactive to
ensure strong administrative machinery in place prior to the enforcement of the rule. It had chalked out
a four-point programme to ensure the successful enforcement. As per the four -point programme, the
Maharashtra Pollution Control Board was responsible for taking action against manufacturers of
polybags. The civil corporations were in charge of raiding and levying fines on the distributors and
suppliers of these goods, the octroi (municipality tax) department checked the entry of bags in
concerned areas, and lastly, the civil administration was charged with the responsibility of running
awareness campaigns (Down to Earth, 2000).
Prior to the enforcement of the Rule the Municipal Corporation had given wide publicity to the
Government Rule for ban on plastic below 20 microns published in the year 1999. Following this,
caution notice was given to the public in newspapers, public places, cinema theatre etc. After proper
announcement and publicity, vendors, users, shopkeepers and manufacturers of plastic bags have been
raided for confiscating the banned plastic, and fined heavily for using coloured plastic bags .48
Municipalities credit this success to the wide publicity and the stringent penalties that have been
enforced on the user and shopkeepers. In addition, the Maharashtra Pollution Control Board made an
effort to take action against the polybag manufacturers who violated the law in Mumbai. Proper co-
operation by the licensing department, pollution control board, citizens and the NGOs, have
contributed to the partial success of the anti-plastic drive. Further, a follow- up for compliance done
every fortnight to shops by the nuisance detectors helps ensure that the vendors do not use coloured
plastic bags; this has helped Mumbai to move away from coloured plastic bags.
48 Email correspondence with Chief engineer, Solid Waste Management Department, Mumbai Municipal Corporation
44
The ban on the bags (less than 20 microns) was not very satisfactory in Mumbai, since it was an
arduous task for the detectors to measure the thickness of the bags used by all the shopkeepers and the
vendors. However, a sizable control has been exercised due to efforts of the nuisance detectors, who
often make surprise visits to shops, and keep track of the vendor’s activities in this regard.
The specification on disciplining the recycling practices is yet to be enforced in Mumbai. The State
Pollution Control Board49 reveals that enforcement in the informal sector is very tardy given the fact
that these units are scattered.
Disciplining recycling practices is a difficult task
The Pollution Control Board is still in the process of identifying the recycling units in the informal
sector, and the ministry perceives that severe penalties cannot be imposed on this sector due to the
high risk of unemployment.50 The Rule does not mention how the guidelines for recycling need to be
adopted. As of now, the recyclers face no incentives to adopt best practices since there is an existing
market for low quality products produced by this sector. Consequently, the recyclers continue to run
their business as usual in the illegal shanties, with stolen electricity and with outdated recycling
technologies. Encouraging these informal recycling units to adopt good practices requires polices that
provide appropriate incentives.
Feedback from tourist states in India on the enforcement51 of the Rule revealed that several difficulties
were encountered in the implementation of the law. In most cases, the administrative agencies were not
technically trained to enforce the legislation, and could be hoodwinked very easily. In the tourist state
of Goa, the authorities were not well equipped to measure the thickness of the bags less than 20
microns. However, after the pressure from the NGOs, the pollution control boards purchased
measuring instruments. Now the manufacturers of plastic bags have found ways of deceiving the
enforcement authorities by making bags with bubbled or corrugated surfaces. The idea behind this is to
cause the micrometer to show the thickness as greater than 20 microns (Noronha, 2001). The lack of
political will, and coordination among the enforcing agencies, has resulted in poor enforcement.
However, one could attribute the partial success of the Rule in Mumbai to an effective planning by the
municipal authorities, assistance rendered by NGOs in running the awareness drives to educate the
public to keep away from coloured bags, high penalties enforced on the user and the shopkeepers and
the frequent monitoring by the authorities.
Social and political acceptability

The fact that littering is a problem has been realised by the public at large in metropolis like Mumbai.
Hence this state has been seeking effective policy measures to handle the issues. The policy has found
acceptance at all levels. NGOs in Mumbai have assisted in sensitising the public to the problems,
thereby compelling the government to initiate quick and effective action. Further, citizens including the
users and traders have responded positively to the successful implementation of the policy. Further, the
political will of the Mumbai Government to support the Municipality in the enforcement of the rule,
has made it a success in this respect.
49 Interview with the Waste Management Department, State Pollution Control Board, Mumbai
50 Recycling sectors are small-scale investments and harsh measures on this sector may lead to unemployment thereby
increasing the crime rate in society. Hence, the sector has to be given incentives to adopt good recycling practices and
command and control mechanisms may be largely ineffective
51 Personal interview with Central Pollution Control Board
45
This policy has also found favour with the politicians and bureaucrats since it does not adversely affect
the petrochemical sector, which is a powerful lobby in the country. The momentum that has been built
up to handle this issue has to be sustained in order to preserve the social and political acceptance on a
continuing basis.
Incentives for improvement

The Rule provides no incentives that lead to an improvement in the existing situation. The Rule has no
provisions that encourages the following:
Incentives for usage of alternatives to plastic bags
The Rule offers no incentives for the consumer to move away from the use of plastics. Although the
Rule has several specifications to improve collection of polybags, it fails to encourage substitutes.
Although polybags are part of the contemporary lifestyle, the common man would consider moving to
using substitutes if they are made cost effective and user-friendly. The government has made no
mention of encouraging substitutes to replace the use of polybags in the Recycling Rule. Substitutes
available in the market that could replace polybags are paper, cloth and jute bags.
Status of substitutes in India
Paper is the most commonly proposed substitute for plastics in India. Recycled or hand made paper is
by and large the most expensive substitute for polybags. However paper bags from used paper is a
possibility. Manufacturing these paper bags is a small cottage industry that has shrunk due to the
introduction of polybags (Chaturvedi, 1999). The demand for such paper bags has considerably
reduced in the last few years, and it has become increasingly expensive to produce them. However
demand creation may help to make them cost effective.
Old paper bags are possible substitutes for polybags, but they need to be bailed out from the demand
slump they are facing (Chaturvedi, 1999). Here, the government could play a role in helping them out
of the slump, and creating a demand for them; this would be a step to move away from polybags. Even
if paper bags are bailed out from the slump they are facing, they are not convenient for packing wet
products that are widely used in Indian cuisine.
Cloth bags include bags from nylon and cotton. Cotton bags made from new cotton cloth are an
inappropriate use of the expensive material. It could rather be more profitable to use this for the
garment industry. So the only possibility is to use bags from old clothes. However, cloth bags do not
provide similar convenience as plastic bags. It is not economical for the shopkeeper to also hand out
cloth bags for every purchase. In addition, it is not convenient for women/consumers to shop after
work. These practical difficulties make the cloth bag an unattractive substitute for polybags.
Jute52 bags have been touted by the NGOs as the most preferred alternative for polybags. In terms of
an appropriate material itself, jute is a fine multiple use alternative. However, there are many structural
changes required in the material for it to prove to be a viable alternative to polybags. The Indian jute
industry is in dire need of modernisation at a technology level too. Only the economics of a jute bag
will determine whether it can replace polybags. 50% of the 60 jute mills that operate in India are already
financially weak. There is no capital available for product innovation (Edwards, Kellet, 1999).
52 Jute is a 100% natural and renewable fiber that is fully compatible with the environment and maintains an
ecological balance. Jute is a very important industry for India. Jute is rotated with food crops, which improves
soil fertility and reduces incidences of plant disease. It is cultivated without irrigation and few pesticides are
used. Jute is one of the most labour intensive industries in India
46
Therefore, given the existing situation of the jute industry, it is very unlikely that a jute bag can be made
as cheap as a polybag, or even suitable for a one-time use (Chaturvedi, 1999).
Hence as a material, jute is a good alternative, but its chances to replace polybags, and compete with
polybags in terms of price and convenience appears to be bleak. Even if the government considers
promoting this industry on a large scale, jute bags will continue to be more expensive than polybags in
the next few years.
The aforementioned substitutes have their own set of limitations that evades them from the
possibilities of substituting polybags. However it could also be argued that prior to the introduction of
carry bags, people used traditional materials like cloth bags. But to move consumers back to using a
cloth bag needs a huge attitudinal change. Assuming that consumers are willing to change, and
welcome the decision to move away from polybags, then the government has to consider measures to
improve the performance of the substitutes and make them cost- effective to replace polybags.
Incentives for the recycling industry to upgrade its recycling practices
The recycling sector is in dire need of upgrading its technologies. Although the government requires
the recycling industries to adopt good recycling technologies as per the third specification in the rule,
there are no incentives for the recyclers to adopt them The government has not made an initial attempt
to register (formalise) all the units after which can technology enhancement programmes be envisaged
in this sector. There is need for appropriate incentives to attract these recycling units to adopt good
practices. Such an enhancement in recycling practices can only result in recycled products of better
quality. These goods in turn can compete with virgin products in the market.
Incentives for research and development
Bio-plastics are promising technologies of the future that can change the scenario of plastic waste
management. The Government has not made any provisions in the Rule that could speed up the
commercialisation of these technologies in India. Although research is carried out in these areas, the
commercialisation process is still at a low key in India.
In order to clearly understand the results of the Recycling Rule of 1999, the table below presents the
effectiveness of the Rule in handling key issues of concern of polybags. Table 5-1 reveals that key
issues continue not to be addressed despite the effective enforcement in Mumbai. In other states of
India, where enforcement has been a major problem, the Rule may not have affected the existing
situation at all.
47
Table 5-1 Impacts of the Recycling Rule on critical issues
Critical Issues Has the Union legislation managed to

address the following problems
Choked Drains No
Choked Soil No
Dying Animals No
Decreased health risk to the citizens by dyes and Yes
pigments
Improve collection and disposal of polybags No
Improve recycling practices No

Encouraging substitutes to polybags No
Increase awareness of the citizens Yes to a limited extent to move from coloured
plastic bags to colourless plastic bags
Increased reuse of the polybags by the citizens No

Source: Chaturvedi, B. (1999).
5.2 Conclusions on the Case Study

Analysis of the case study reveals several issues that have not been considered by the government while
framing policies. The Recycling Rule of 1999 adopted by Mumbai Government to handle the problem
of littering, has proved to be a reactive solution.
A quick analysis of the specifications theoretically revealed that all of them were difficult to enforce
given the existing regulatory capacity53 in India. Another major drawback of the Recycling Rule is that it
calls for sufficient technical capabilities on the part of those charged with its implementation. Some
proactive municipalities like Mumbai have been able to partially enforce the Rule with deterrent
penalties. Since the penalties have been high enough, they have been able to produce the deterrent
effect. In addition to imposing penalties, Mumbai has also ensured a high probability of detection (with
micrometers). These factors have contributed to the partial success of the Rule.
The specification that aims to discipline recycling practices in the Rule has remained completely
dormant in the state of Mumbai and is yet to be enforced by the State Pollution Control Board.
However, one could agree that enforcing rules and regulations on the recycling sector is difficult, given
the clandestine nature of operations in this sector.
53 Most of the SPCBs in the country do not have adequate knowledge and infrastructure to carry out the regular monitoring
and enforcement A recent study on the performance of pollution control boards, undertaken by the Programme Evaluation
Organization on the instance of the Planning Commission reveals that out of a total of 197 members in 17 boards, 129
including 94 bureaucrats are from non-technical background and 68 possess technical knowledge. That means 65 percent of
the members are technically incompetent to do a job that requires high technical skills. No credence could be given to the
justification that SPCBs function poorly because they do not have adequate staff. Instead, more than half of the staff is
technically incompetent to carry out any monitoring. (Down To Earth, 2001)
48
Enforcing the Rule has not alleviated the littering problem, but this is largely due to the inherent
weakness of the policy in addressing the issue. Due credit has to be given to the municipality of
Mumbai, which has taken efforts to make sure that coloured plastic bags are out of the system, and has
exercised sizable control to ensure that bags less than 20 microns are not sold by the shopkeepers.
Partial success of the Rule in Mumbai demonstrates that highly prepared administrative machinery with
clear division of responsibilities and strong support of the citizens can go a long way in enforcing rules
and regulations.
However, as a result of the enforcement of the rule, there has been an increase in the usage of virgin
plastic bags in the city of Mumbai. In order to avoid the risk of penalties, the shopkeepers in Mumbai
prefer to have virgin plastic bags of natural shade. The plastic industry functions like a double-edged
sword; on the one hand it benefits from the increased consumption of plastic by the citizens, but on
the other hand it continues to shrug off its responsibility in taking care of the product at its end of life.
The question that arises is whether moving from 5 microns to 20 microns has alleviated the problem of
littering in Mumbai? The experience in Mumbai demonstrates clearly that the problem of littering
cannot be addressed by making bags thicker, and promoting virgin plastic bags. Hence, even a
proactive administration and cooperative citizens cannot also cover the inherent flaws of Recycling
Rule.
5.3 Industry Initiatives to Protect Its Image (ICPE-Nagar-BMC)

In the city of Mumbai, the industry association (Indian Centre for Plastic and Environment)54 has
initiated a pilot project to encourage the citizens of Mumbai to carry out source separation.
This effort has been initiated by NAGARs Clean Mumbai Foundation in the Cuff Parade, Colaba and
Church Gate areas of South Mumbai. There are several partners in this pilot project, the key one being
the industry association (ICPE), which has provided the funds necessary for operations in the pilot
project. Beside the Industry, there are several NGOs55, and the Mumbai Municipal Corporation, which
are involved in the pilot project.
Participants of the pilot project
The project was initiated at the Cuff Parade area of Mumbai. This area consists of 52 high-rise
buildings, averaging 20 storeys and with a total of approximately 3600 apartments and a population of
16,000 people. 38-40 buildings in this area participate in this programme and segregate their dry and
wet waste. Several buildings beyond Cuff Parade have also been included into the project due to wide
spread publicity of the project by the NGOs.
Working of the pilot project
The residents of this area separate the dry and wet waste, and the wet waste is taken care of by the
Mumbai Municipal Corporation in the usual manner. The dry waste is collected from each of these
buildings in a tempo (motor vehicle, assigned for this purpose by the municipality - this service has not
yet proven to be financially viable for the municipality), by 5 lady wastepickers (provided by the NGO
54 The Indian Center for Plastics and Environment is the industry association set up to address environmental problems of
plastic waste in India. The main objectives of the centre are to project a responsible image of the plastic industry by creating
awareness on the proper use of plastics and sponsoring pilot projects to demonstrate to the government the measures they
could take to establish a proper system and also ensure that the government does not take any harsh measures against the
industry due to pressure from NGOs.
55 The NGOs involved include the NAGAR (NGO Alliance for Governance and Renewal), Clean Mumbai Foundation,
Association of Youth for a Better India, Cuff Parade residents Association, Stree Mukti Sanghatana,
49
Stree Mukti), between 7 and 12 in the morning .The dry waste is then brought to a small shed allocated
by the Municipality, where the wastepickers sort the waste and store it. Once in a week/fortnight,
depending on the volume of waste collected, an industry (ICPE) appointed recycler collects the waste
by paying a fair price for it to the wastepickers. Since the price given by the recycler is fair, the
wastepickers earn an average of Rs90-Rs 105/ day. Further, to supervise the activities of the
wastepickers, and record the details on waste collected and sold, on going supervision is carried out by
two people from an NGO (Stree Mukti Sanghatana).
Results of the pilot project
The industry and NGOs reveal that the project has been a success, and attribute the success to the
awareness programmes conducted by the Association of Youth for a better India, the efforts of the
Cuff Parade Residents Association to educate their residents on the project, and the industry’s ongoing
financial support to sustain the project. The residents of Cuff Parade have observed a visible change as
a result of the pilot project56. The success has also encouraged the neighbouring areas of Cuff Parade to
join the pilot project. Despite the success, there are a few bottlenecks; the primary one being that some
of the residents in the area fail to segregate their waste, and the municipality fails to wield the stick
against them. In addition, the recycler appointed by the industry has shown tremendous resistance57 to
accept all the dry waste.
Sustaining the pilot project
The success of the pilot project also raises questions on its sustenance. The primary question that
needs to be addressed is that what would happen if the industry would withdraw its financial support
from the pilot project. The Mumbai Municipality is not finding it financially viable to support the
project. The industry, having demonstrated to the municipality the feasibility of the scheme could
expect the municipality to fund this system in the future. Since this scheme is not self-sustaining, it
needs support from the various stakeholders to operate on a regular basis. If the industry does not
sponsor the continuation of the project, the recycler would also refuse to collect waste, and the
wastepickers would not have any incentives to stay within the system since they would prefer to have
fixed earnings from collecting waste on the street. All the efforts of the NGOs in mobilising the
wastepickers, and garnering support from the residents of the area would turn out to be a futile
exercise. Hence, the sustenance of this project on a long-term basis depends to a great extent on the
industry. The industry could be reluctant to fund this project on a long-term basis, especially
establishing a system and also taking responsibility for the functioning of the system on a permanent
basis
Hence such pilot projects may only help the industry to publicise their efforts and project an
environmentally friendly image of a responsible industry, but may not help to alleviate the problems
related to waste management of plastics.
56 Personal Interview with the coordinator of the project.

57 The resistance by the recycler could be common since he may not be interested in collecting waste he does not recycle.
50
5.4 Polyethylene Terephthalate (PET)

There is no comprehensive legislation on PET waste in India. However during several meetings of the
Plastic Waste Management Task force58 (Refer to Section 4) the possibilities of introducing a take back
system for PET bottles was discussed.
A take back or a deposit refund system is a concept that is not new for India. It has existed for several
years now with glass bottles. The price charged by the retailer for each bottle includes a deposit (usually
Rs 5) refunded when the bottle is returned. Used bottles are collected, cleaned, disinfected, refilled with
the same product and returned to the trading point. It is an effective system, which uses the same
transport system for collection and delivery. The deposit on the bottle ensures that it is valued, and the
size of the deposit is fair enough to induce the consumer to return the bottle; even if the consumer
discards it, it is collected by wastepickers.
Discussions on take back for PET bottles
During several meetings of the Task Force, the Ministry of Environment and the CPCB had asked the
industries to come up with an outline scheme of a take back for PET bottles. The industry
representatives during the meetings suggested a voluntary scheme for the collection of PET bottles
with suitable incentives offered to the consumers. From a mandatory take back, the industry moved the
discussion to a voluntary take back59.
Industry’s efforts to evade responsibility
The industry was clearly not interested in establishing a system for PET bottles. After several meetings
with PET manufacturers, recyclers and users of PET bottles like Bisleri, Coca-Cola, and Pepsi the end
result was that all of them showed no inclination to establish a system. The industry expressed its
inability to set up system in view of the fact that the PET consumption in soft drinks is minimal,
whereas for mineral water and liquor bottle, which are the major consumers, such a system would not
be feasible. Another argument was that a large number of mass consumption beverages were still
packed in glass, and establishing a take back for PET would not be financially viable (Edwards, Kellet,
1999).
Therefore a take back system did not materialise and the heaps of PET bottles lie as litter. Littering is
more acute in tourist states like Goa where a large number of tourists contribute large numbers of PET
mineral water bottles, which join the plastic carry bags that litter beaches and streets in the State.
An attempt of take back in Goa
Early in 1999, vexed with the littering problem, an NGO named Goa Foundation took direct action, by
dumping piles of plastic bottles at the gates of the leading mineral water bottler, Bisleri. The company
then agreed to put a deposit of Rs 1 on some of its plastic water bottles. However the deposit was only
for the 5 litre Bisleri bottles. The take back scheme60 has been working fine for the 5-lit bottles in Goa.
As in the case of glass bottles, even if the user does not return the bottle, the ragpicker collects it and
sells it to the retailer. Further, the 5 litre bottles are thicker and the preforms that are used to make
58 The Plastic Waste Management Task Force held several meetings with various stakeholders predominantly from the
industry to look into the issues of plastic waste and then came up with several recommendations, a few of which have been
implemented.
59 Minutes of the meeting of the National Plastic Waste Management Task force.
60 The success of the scheme was confirmed by Goa foundation via email correspondence to the author. There are no figures
available on the collection rates but one may presume that it is in the interest of Bisleri to collect 5 liter bottles as they are
expensive and can be reused.
51
them are also expensive, providing an incentive for the packer to collect and reuse them. The fact that
5 litre bottles are collected is only a partial solution, but represents a good initiative in the right
direction from the bottlers.
Despite this, there are two crucial points that need to be addressed. The first one being that it is not
enough if one packer takes up responsibility. The bottled water market in India is highly competitive,
and there are new players entering the market within a short span of time. Hence, they have to take up
this responsibility collectively and not in isolation. Secondly, the major problem of littering is associated
with the 1-litre and 500 ml bottles, and a take back scheme has to cover these bottles as well. As of
today, there are no incentive for the packer, to collect 1-litre and 500 ml bottles, since they are thin, and
cannot be reused by the packer. These are also not attractive for the wastepickers, since it finds
no/limited value in the trade due to a few PET recycling units existing in the country.
The industry argument remains that mass beverage consumption is still in glass bottles in India, and the
consumption of PET is still not large enough as compared to the developed world to establish a take
back system. The industry is not ready to accept a take back policy since it would mean an increase in
costs, which it is not ready to incur. Further, it may also fear that accepting a take back for PET would
also mean taking responsibility for other problematic plastics like PVC in the near future (Edwards,
Kellet, 1999).
Although there is a consensus among the policy makers that a take back system has to be established
for PET bottles all over India, there is no clear vision on how such a system could be formulated given
the strong industry resistance to such a scheme.
The idea is still at the conceptual stage and discussions are going on among the various stakeholders.
Although the PET consumption levels are low in India, the increasing trends underscore the need for a
system to manage the heaps of PET waste.
5.5 Ecomark Scheme

The Ecomark scheme, a Government certified green label, is not worn by a single product in the
market. Ecomark was launched by the government in 1991 for the labelling of eco-friendly products,
which incorporates a life cycle perspective (manufacturing, use, packaging, distribution, consumption,
disposal and recycling.)
The Ecomark scheme has been a total failure in India. The industry has no incentives for adopting this
scheme, particularly since Indian products are not exported to a large extent and also the fact that there
is no demand from the Indian consumers. In a low per-capita income country like India, consumers are
more price-conscious and driven by basic necessities, rather than by the virtues of product quality or
environmental concerns. Therefore, the lack of demand from consumers has resulted in industry
resistance to adoption of the scheme.
5.6 Results of the Analysis

Objective of the policy (Recycling Rule)
The objective of the policy to minimise littering has been short-sighted. Minimising littering alone is
not a solution to the problem of plastic waste in India. Littering is just one of the more visible issues of
plastic waste. Assurances that waste problems can be effectively dealt with by reuse and recycling of
polybags only serves to further unnecessary consumerism. Considering the fact that, unlike paper, glass
and metals, plastics can rarely be recycled into the same products, and are invariably down-cycled to
inferior products. Plastics can only be re-melted a limited number of times before the material loses its
52
structural value. Therefore, the possibility of working in a 100% reclamation loop is not practically
feasible. Consequently, encouraging recycling alone can never be a solution to the problem of polybags.
The long-term goal of the policy should be to minimise the use of polybags, and thus prevent the waste
from being generated. By targeting waste prevention of polybags, India could contribute to fostering
environmentally advantageous changes in production and consumption patterns, and less extraction of
natural resource, thus freeing up financial resources for other priorities by lowering waste management
costs.
Further, the policy should have included elements for improving and reorganising the existing waste
management system. This could help in handling the ever-changing lifestyle of consumers, and the
consumption and disposal patterns of society. Reducing waste generation as a clear policy objective,
and the restructuring of the existing waste management system could have clearly helped to minimise
the littering.
Recycling Rule replete with flaws
Analysis of the Recycling Rule has indicated several flaws. The primary flaw is that government has
made a Rule with several assumptions. The assumption that increasing the thickness of polybags could
reduce littering is not valid. Further, the increase in thickness has to be more than the stipulated 20
microns to encourage reuse and recycling. Thus, the assumptions that were made were bound to fail,
since the provisions were very weak.
The Recycling Rule has also been quite difficult to enforce. Each specification in the Rule is linked to
the issue of enforcement. A few states such as Mumbai, due to the efforts of proactive municipalities
have encountered partial success. Accounts from selected states like Goa have revealed problems
encountered during enforcement of the rule. Weak and ineffective implementing agencies have made
the compliance and enforcement of this Rule abysmally poor especially in this state. Therefore, the
Rule has not effectively addressed the monitoring aspects. In fact, in Goa, the failure of the Rule has
led the state government to consider implementing a law, which would ban plastic bags below 100
microns in thickness. Each bag of this thickness would cost 5 to 10 rupees. (US$0.10 to $0.20) So,
people would either re-use these bags or avoid using them (Corporate watch, 2001). But will making
ever thicker plastic bags mandatory be in line with encouraging sustainable plastic waste management?
In developed countries, people have started looking at material efficiency (reducing the virgin material
throughput), and finding ways of saving material, while the Indian policy makers are encouraging
practices in the opposite direction to alleviate problems!
The Rule has ended up promoting the virgin plastic industry that refuses (except for financing pilot
projects) to shoulder any responsibility for the problem. Instead, it blames the consumer for their
littering habits, and the Government for not ensuring a proper waste management system.
Further, it comes down hard on the recycling industry that is doing a good job for the environment by
recycling. Although the recycling sector needs to be disciplined, mandating a few requirements against
them would be a futile exercise. The recycling sector needs improvement, and it is in the best interests
of the Government to upgrade this sector. This would ensure that recycled products could compete
with virgin plastics in terms of quality.
Onus of responsibility (Who will pay?)
The problem lies in the fact that alleviating several pressing issues of plastic waste management requires
adequate finances. The municipal authorities have failed miserably in managing the plastic waste,
primarily because of inadequate budgets. In metropolitan states like Mumbai and Delhi, municipal
budgets for waste management are insufficient for managing the rising amounts of waste. The
53
development of an effective waste management system is costly, and at present the Government
revenues are mainly raised from customs and excise duties when goods enter and exit India. A system
of taxing households for municipal services exists, but the amount raised is certainly not adequate to
deal with collection, transportation and disposal of waste. Taxing the incomes of middle class and the
rich is bedevilled with corruption and avoidance61 (Edwards, Kellet, 1999).
The industry perceives that littering is a problem due to the lack of awareness, and that spreading the
bin culture would help alleviate the problems. So its interest lies only in promoting awareness
programs, sponsoring pilot projects to protect its image, and ensuring that the Government does not
take any harsh measures against the plastic industry .The initiatives of the industry so far have been
only to finance pilot projects and awareness programmes.
So in light of the fact that no one takes responsibility for improving the deteriorating system, claims
and counterclaims continues to exist. The problem of plastic waste is perceived as a problem for the
community (since they are the root cause of the litter) and the government (which is unable to provide
an efficient waste management) rather than the producer.
Priority areas
During the course of this analysis, a few priority areas were identified, and these need to be addressed:
• Controlling the indiscriminate use and disposal of polybags,
• Inadequate municipal services due to paucity of resources,
• Integration of the wastepickers into the waste management system,
• Reorganising the recycling sector, and securing technology enhancement to improve the
quality of recycled products
• Establishing a proper system for handling PET waste.
The existing Rule has failed to address any of these issues, and hence the problem of littering continues
to exist.
61 In India, the total number of income tax assesses constitute less than 1.25% of the Indian population. In order to trace tax
evaders the government has to trace owners of cars, mobile phones on the assumption that if citizens can afford such
luxuries then they are in a position to pay income tax as well. (Edwards, 1999)
54
6. Proposed Policies
It was emphasised that changing consumer behaviour and reducing the polybag waste generated, could
ameliorate the littering problems. Therefore it would be worthwhile considering options that would
discourage the consumers to move from using products of short lifespan and high environmental
impacts.
6.1 Environmental tax on Plastic Bags

A cess could be levied on the plastic industry as a means to generate revenue for waste management.
The difference between a tax and cess is that the tax can be used by the government to meet any
budgeted expenditure, while the cess is collected for a specific purpose and can only be utilised to fulfil
that purpose. This fund cannot be diverted to meet any other expenditure of the Government. In that
sense, cess62 is a special tax to meet specific objectives depending on the sector it is levied on. It is
legally binding to adhere to the stipulated goal and objectives. Any modification or change can be
brought about with the approval of the parliament through legislation only.
The plastic industry in India has also been supportive to the cause of sustainable waste management
and the government levying a cess on its products for generating a development fund for establishing
an effective waste management system. The cess or environmental tax could be intended to encourage
the development of new and alternate products, and also provide revenues for waste management.
A cess could be levied on the plastic products, in this case on plastic bags, as a means to internalise the
external costs associated with the products. Further, the cess should also be able to discourage
consumption, and trigger the consumers to make the right purchases. This would in turn reduce the
amount of polybag waste generated.
An environmental cess on plastic bags either targeted at producers or retailers can have the effect of
suppressing consumer demand for plastic bags, and inducing consumers to use other alternatives.
According to the Irish environmental tax on plastic bags, a levy of EUR 0.04 (IEP 0.03) on every bag
was to be charged to suppliers63. The study found that this would be less effective in suppressing
demand, than forcing retailers to charge customers for using carrier bags, but would be simpler to
administer and would be less of a burden on Ireland's many small food retailers (ENDS, 1999).
However, recent reports64 confirm that a tax of IEP 0.10 that translates to EUR 0.12 will be levied, at
the point of sale starting early 2002 so as to directly influence consumer behaviour, and achieve a
significant reduction in the consumption of plastic shopping bags dispensed at retail outlets; the
revenues generated from the plastic bag levy will be dedicated to a central fund for use in support of
waste minimisation, recycling and other environmental initiatives.
Alternatively, the tax could also be calculated based on the recycled content of the plastic bags, and
consequently stimulate the demand for recycled products, and discourage the use of virgin materials. In
62 In India cess is levied sometimes to mobilize fund for a specific purpose. For example there is an R&D cess levied (5%) on
technology transfer fee paid by any industry for import of technology. This amount is used as a technology venture fund for
promoting indigenous R&D capability.
63 Of the several types of levy systems available either a point of sale or a supply-based approach is possible. Both have merits
and disadvantages. The former (point of sale) approach has the benefit of adhering more tightly to the polluter pays
principle in targeting end- consumption, but may be compromised by administrative complexity. By targeting
manufacturers and wholesalers the supply based levy is administratively simpler. It is likely to be less effective, however, in
reducing plastic bag consumption per unit of levy than a point of sale system (without any exemptions) as it offers the
possibility of suppliers absorbing some of the levy to maintain bag sales. (Irish Environment Ministry, 2000)
64 Email correspondence with Una Mc Dermott, Irish Environmental Ministry.
55
the case of India, the quality of recycled bags needs to be substantially improved to an extent that they
can compete with virgin material in quality, so as to avoid health risks associated with polybags. So, a
tax based on recycled content seems difficult given the current status of the polybag recycling sector.
Despite the merits of an environmental tax, there are several problems affecting their effectiveness. In
Italy an environmental tax of ITL 100 (USD 0.06) was only imposed on non- biodegradable plastic
bags. Due to the unclear definition of biodegradability, there was an increase in the production of
plastic bags declared as biodegradable. As a result, after the first year of introduction, a downward
trend of 9% in consumption of plastic bags was observed but the consumption of plastic bags
increased by 16% in the second year (Fung, 2000).
In the context of India, an environmental cess will have the benefit of generating revenue, which could
be utilised for improving the waste management practices, invested into upgrading the recycling sector,
and development of biodegradable products. However, such an environmental tax is difficult
considering the large number of retailing outlets of polybags in India. So a good enforcing capacity is
crucial for implementing an environmental tax on polybags.
Further, the cess rate has to be set at a level that affects consumption, and forces consumers to move
towards other alternatives. If the demand for plastic bags is highly elastic, and consumers can easily
move towards the usage of substitutes then the tax may be effective. As of today alternatives have to
overcome their technical and economic weaknesses they are facing, to make the tax on polybags
effective.
Differential taxation has been employed in the State of Himachal Pradesh where paper bag
manufacturers have been exempted from taxation thus making plastic bags less competitive. A 30%
sales tax had been imposed on plastic bags. This taxation has proven to be ineffective mainly because
the sales tax was not large enough to affect consumer behaviour65.
If higher taxes are imposed then there may be lack of political acceptability since the tax would be
accused for hampering economic competitiveness of domestic production (OECD, 1996). So, taxes
have to be designed in a manner that they do not severely affect domestic production.
In essence an environmental tax (cess) on polybags may be a good idea but requires a good regulatory
capacity to enforce it. Careful design of the tax is required if it is aimed at minimising consumption,
and at the same time it should not be too high to create political barriers, and encourage industry to
adopt undesirable practices. Further cost effective substitutes need to be encouraged so as to dissuade
the consumers from use of polybags.
If properly enforced, such cess or an environmental tax will have the benefit of generating a
promotional and development fund, which could be utilised for improving the waste management
practices or invested into upgrading the recycling sector as well as development of biodegradable
products. This promotional fund could also be used to generate greater awareness among the users.
6.2 Incineration with Energy Recovery

Incineration with energy recovery is advocated by the MOEF (policy makers), and the plastic industry,
as an ideal option for solving the plastic waste management problems in India. Incineration has been
proposed as a solution for three reasons 1) the lack of availability of lands for open dumping in
65 Assuming that 100 plastic bags cost Rs 29 and a sales tax of 30 % is imposed on each plastic bag the total cost after the
taxation works out to be 38 paise per bag which the shopkeepers would easily recover through the sale of other products
and still find it conducive to hand out plastic bags as part of their service.
56
metropolitan cities in India, 2) The informal sector does not collect plastic waste that is not
remunerative, 3) limits to recycling of plastic waste66 need to be practiced effectively so as to ensure the
quality of recycled products.
Waste to energy does provide a suitable option of disposing waste that cannot be recycled further, as
well as non-recyclables (plastic packaging made of dual material like detergent packing material,
shampoo pouches which are difficult to recycle and hence not collected by the wastepickers in India.),
and greatly reduces the volume of waste that needs to be landfilled (Volume reduction ranges from 80
to 95%), and also generates energy as a useful by-product (Tammemagi. 1999). Several big cities in
India like Mumbai and Chennai have entered into agreements for constructing waste to energy plants.
In Chennai a 14.85 MW waste to energy plant will be set up in the next two years where 6000
tonnes/day of municipal solid waste would be converted to electricity (Waste Technology, 2001).
Incineration despite facing strong resistance is still a common practice in the European countries since
the benefits from this technology are attractive to these countries. In Sweden, 95 per cent of the heat
generated from incineration is used for district central heating, covering roughly 10 per cent of the total
need in Sweden. (RVF, 2000) Incineration is often allowed to be one measure for energy recovering of
packaging materials, notably for plastic packaging so as to avoid the difficulties and expenses in the area
of plastic recycling under the take-back scheme of packaging in France, Belgium and Austria
(Ackerman, 1996).
Despite the possible benefits, there are a few concerns that need to be considered in the Indian
context. Indian waste composition is very different from that of European countries67. Indian waste
contains only 3 to 7% of combustibles paper and plastics by the time the waste reaches the disposal
site. This is principally because most of the combustible material is retrieved by wastepickers from the
waste lying in the streets, dusts bins and dump yards. This calorific value of Indian waste at the dump
yards is found to range from 800 to 1000 kcal/kg, which is very low (Supreme court, 1999).
Consequently, additional fuel may be required during the combustion process, thereby adding to the
operational costs68. In addition to the fact that waste to energy plants are highly expensive69, they also
66 Plastic scrap cannot be recycled endlessly forever as it undergoes degradation due to repeated processing. This limits the
number of times plastic can be recycled. Ultimately this scrap has to be incinerated or disposed off in landfills.
67 A Swedish household contains about 49% food scrap, 18% paper, 8% plastic and 8% disposable nappies. Textiles, glass,
metal and other waste are present at levels of about 1%. Hazardous waste accounts for less than half a percent. (RVF,
2000)
68 Incineration entails huge startup costs and operational costs. The operational costs include the expensive chemicals that are
employed for flue gas cleaning, maintenance costs and salary for the educated staff to control the operation. Further the ash
that is produced from burning is toxic which requires appropriate treatment before they are landfilled. (SYSAV, 2001)
69 In order to get a rough idea of the costs involved in incineration of plastics in India, a calculation of the costs associated
with incineration in Sweden has been carried out. The figures have been obtained from SYSAV, Malmö, Sweden, where a
new incineration plant is currently under construction. The capital costs for the plant are SEK 900 million. If we assume the
interest rate on loans for infrastructure investments is 4%/year and the loan should be paid in 25 years, then the annual cost
will be 6.4% of the initial investment. The annual running costs of the plant are the operational costs (SEK 50 million/year)
plus SEK 57 million (= 6.4% of 900 million) that is SEK 107 million per year. The total capacity of the plant is 200,000
tonnes/year. A few assumptions have been made in order to estimate the costs in India:
Assumption 1: Conditions are identical in Sweden and India, considering the investment costs, interest rates and yearly
operational costs.
Assumption 2: India would subscribe to achieving the same emission standards as Sweden.
Assumption 3: Since incineration is being considered as an option only to solve the problems of plastic waste in India, the
costs for incineration have been completely allocated to plastics in the case of India.
Assumption 4: Economic benefits of waste-to-energy have not been considered., as these in India are considered to be
small, if any, compared to the costs. The reasons for this, is that the low calorific value may entail costs of additional fuel for
incineration and the limited market for heat available in India.
57
cause a lot of air pollution, unless state-of-art technologies for cleaning flue gases are employed. In
Sweden, sophisticated flue gas cleaning technologies have been employed for controlling dust, nitrogen
oxides, sulphur oxides and ammonia in order to meet the high requirements set by the Swedish
authorities. Further good sorting70 is also practiced, to keep pollution loads lower from incineration
plants, since uncontaminated waste burns more evenly and does not cause an unnecessary load on the
flue gas cleaning systems (RVF, 2000).
The MOEF in India has brushed aside the fact that air pollution is a major concern from incineration.
PVC accounts for the highest percent (26%) of the total consumption of plastics71 in India. (GOI,
1997) Plastics like PVC should to be prevented from incineration as far as possible in order to
minimise the creation of hydrochloric acid and the risk of formation of dioxins. Even with the most
advanced flue gas-cleaning facilities, the unsorted waste sent to the incinerator may still result in
emission of substances such as dioxins. This situation could be aggravated if emission standards on
operation of waste incineration plants are not ready in the country (Down to Earth, 2000).
Another concern is that incineration also generates fly ash that is highly toxic, and needs proper
treatment prior to disposal. In India, there are no sanitary landfills, and waste is dumped on open
grounds. If the same practice continues with ash from incinerators, then India’s ground water (which is
already contaminated) would face severe contamination thereby affecting human health. The primary
concern with the incineration is that it would affect the recycling sector. Once the middlemen start
selling waste to incinerators, there will be a decrease in the amount of waste diverted for recycling.
Competition will be sparked off between recycling and incineration. The beneficiaries will be the virgin
plastic industries who could push more plastics into the system in the pretext that there is a good
system in place to handle the waste. The slump in the recycling sector will lead to unemployment
problems, and this will further increase the crime rate in the society. So these cascading effects need to
be considered by the government before advocating this technology.
In the past an overwhelming faith in incineration led the Government of India to bring in a Danish
incinerator model, which lies still unused in Timarpur, Delhi72. This incinerator has cost the
Government several millions of rupees and now the Ministry of Non Conventional Energy Sources
(MNES) is planning to offer huge and attractive subsidies to set up waste to energy plants in India. The
Based on these figures, the cost of incineration/tonne has been calculated to be 535 SEK/tonne. Following the assumption
that the costs should be completely allocated to the plastic contents we get:
Waste in India has 1-4% plastics; considering the higher figure of 4 %, 40 kg of waste is present in 1 tonne, and thus the
costs of incineration in India amounts to approximately 13 SEK/kg, which translates to Rs 58.5/kg. Using a plastic content
of 2% then the cost of incineration will be 27 SEK/kg, which translates to Rs 121/kg. Given that the current price of virgin
granules is Rs 52/kg, when the costs for incineration are added to this price, then the total cost becomes doubled. This
indicates that if incineration of municipal solid waste was considered as the only option for plastic waste management, and
that these costs should be borne by the material plastics, then the cost of virgin granules would be doubled. So, the question
that arises is, who pays for the increased costs associated with incineration? Therefore, the Industry and the Government of
India should consider the fact that bringing in incineration as an option and operating it to the same standards as practiced
in European countries entails huge costs.
70 The very low emissions from today’s Swedish incineration plants are due to several factors. Firstly, there is an endeavour to
keep the levels of emissions of hazardous substances down by ensuring that what is not suitable for incineration is
separated. An example of this is that batteries are sorted out, leading to a reduction in the amount of mercury in the waste
by 70 percent in the last ten years. Secondly, the incineration process is steered and optimized so that as few hazardous
substances as possible are formed. Finally, the pollutants still remaining in the flue gas are trapped so that they are not
emitted. (RVF, 2000)
71 HDPE accounts for 21%, polypropylene 21% LL/DLPE 24% and Polystyrene 8% of the total consumption of plastics in
the country. (MOEF, 1997)
72 The Danish incinerator failed to take off since it had not been designed according to the nature of municipal solid waste
generated in India. Since the waste in India has high organic matter and low calorific value it was not viable to generate
energy.
58
allies in this are several municipalities, which claim that they are running out of landfill space to dispose
waste.
In essence, the current discussion of moving to incineration with energy recovery has to be carefully
reviewed, in the light of prevailing conditions in India. Although most of the incinerator plants in India
will be set up on a built-operate–own basis, the Government needs to place stringent air quality
requirements on these private organisations. Strict emission standards relating to the operation of waste
incineration plants need to be prepared and enforced. Further, the waste also needs to be sorted out to
ensure that non-combustibles are not incinerated, and appropriate use and disposal of fly ash should be
stimulated to protect the health and environment. Incineration with energy recovery provides an
immediate solution to reduce the waste volume, and thereby disposal to landfills, but it may also
adversely affect an economically driven activity (recycling) in India.
6.3 Source Separation

In studying the stakeholders involved, it was concluded that there are several interdependencies that
characterise the plastic waste management system in India. There were some weak links identified and
mentioned in Table 3-5. These links need to be strengthened and waste generating agents also need to
participate actively in improvising the existing waste management system. Source Separation is one
option that can be effectively carried out by involving the waste generating agents and integrating the
formal and informal authorities.
Source Separation has already been mandated in the Municipal Solid Waste Rule of 200073.The rule
calls for organising door-to-door collection of garbage either through community bin collection, house-
to-house collection, collection on regular pre-informed timings and also designates the municipalities to
organise awareness programmes for segregation of waste. This rule is yet to be enforced and hence
nothing can be mentioned on the feasibility of households separating waste and the municipalities
arranging a door-to-door collection.
However, source separation by the households would help to reduce the burden of the wastepickers
and the municipality. The non-biodegradable waste has a value and would be taken care of by the
informal sector and the organic waste that is fairly clean could be composted. This may prevent the
households from disposing garbage in polybags that makes it unhygienic for the wastepickers to collect
them. In order to implement the idea of source separation in practice, a primary requirement is
awareness among the households. Awareness needs to be generated in a broad way to ensure that
source separation is a success. The municipalities charged with the responsibility of running awareness
drives for source separation are already facing huge budget constraints. Further there are households
that may fail to cooperate on flimsy grounds such as lack of time to take up sorting activities.
If the idea of door-to-door collection and source separation is fully implemented throughout India,
then littering can be minimised to a large extent. However, getting the households to separate waste,
and carrying out a door-to-door collection is an arduous task for the municipalities given their current
inefficiencies in collecting waste. However, the municipalities could carry out this task efficiently if they
integrate the wastepickers into the waste collection system. The idea of employing wastepickers for
collection of household waste, and provide them areas of sorting has the following advantages.
• Regular income and employment to the wastepickers
• Reduced quantity of waste collection for the municipal system
73 The Municipal Solid Waste Rule has been passed in 2000 in response to the public litigation in public interest filed at the
Supreme Court. The rule clearly mentions source separation as a means to combat littering.
59
• Possibility of utilising clean biodegradable waste for composting.
6.3.1 Decentralising the waste management system

In terms of interventions for improving waste management in the country, three issues need to be
addressed: First, plans for revamping the formal system should not ignore the social and economic
dimensions of the informal sector in the waste management process (Baud, Schenk, 1994). Second, it is
necessary to bring a change in attitudes, which views waste management as a responsibility of the
municipal body and treats wastepicking as an illegal activity (Venkateswaran, 1994a and 1994b). Third,
it should be remembered that excessive municipal control of waste management does not necessarily
lead to significant economies of scale.
Therefore, it is worth considering the integration of the informal practices with the existing formal
system and look into options of decentralising waste management74 with the involvement of the
wastepickers.
As stated in 3.3, the wastepickers provide an unacknowledged service for the municipalities and despite
this they are exploited in the trade, harassed by the police officials, and treated as undesirable entities in
society.
Some NGOs in India are taking a lot of efforts to improve the plight of impoverished wastepickers.
The efforts have been to formally integrate the wastepickers into the municipality. The municipality is
already over-flooded with employees and, consequently, integrating the wastepickers as proper
municipal employees may be extremely difficult. However, the municipalities could recognise the
efforts of the wastepickers, and integrate them formally into the waste management system by other
innovative means. The voluntary service provided by these wastepickers can be organised so as to
ensure them a better living, and higher dignity of work.
There is a gradually changing view towards the informal sector in India today. The need to involve
wastepickers into the waste collection system in the face of growing consumption and urbanisation has
been articulated very clearly by several NGOs and has been realised by a few municipalities. Sincere
attempts have been made in several parts of India to improve the situation of wastepickers. A few
attempts are mentioned in brief below.
In Pimpri-Chinchwad, Maharashtra wastepickers are trained to carry out door-to-door collection. The
municipality is supplying them with identity cards, but there is no formal agreement between the
Municipality and the other agencies involved. 200 women wastepickers have been incorporated into
this scheme all selected through a union of wastepickers. A total of 15,000 households are covered in
this scheme with each household paying Rs 10 to the wastepickers. The programme has been
continuing now for few years without a formal contract. Such a system holds some clear advantages:
clean and segregated waste for the wastepickers, better working conditions, less antagonism from
various sectors like the police and other municipal employees and a cleaner environment. A formal
agreement would allow the wastepickers to project themselves as legitimate service providers.
However, the idea of door-to-door collection with the waste pickers alone is deemed illegal, given the
obligatory position of the municipality to collect, transport and dispose waste. Therefore there are legal
and structural hurdles that impede such novel partnerships (Chaturvedi, 1998).
74 The suggestion to improve the wastepickers by upgrading them to the level of doorstep waste-collector is only with a view
to improve the quality of life of the ragpickers, relieve them from the dirty work of picking up soiled and contaminated
waste to earn their living, integrate them in the mainstream of society by giving them access to the houses, shops and
establishments to collect recyclable waste from the door step in the same informal manner. The ragpickers should not,
therefore, be given any formal employment on a daily or monthly wage by the local body or even by the NGOs as it may
attract the provisions of labour laws.
60
While there are several schemes that help manage waste in a decentralised way through waste pickers,
ACORD (Asian Centre for Organisation, Research and Development) has moved the focus to overall
capacity building and skill enhancing for wastepickers. Apart from collecting household waste, it has
also identified needs the wastepickers can fulfil after their morning work hours. Some of these include
plumbing, gardening etc. These skills may help the ragpicker to set up a private service enterprise
collectively or individually (Chaturvedi, 1998).
The wastepickers must be seen as an industrial enterprise and schemes and opportunities to improve
this stratum of society are necessary for a clean environment. This can come about only with the
integration and cooperation of the wastepickers, consumers and municipality. Bringing together the
three stakeholders and defining roles and responsibilities can fully help in decentralising waste
management.
The savings that decentralised waste management can bring for the waste producers and waste
generators is tremendous. It is a win-win situation for the municipality, which can save costs associated
with transportation and disposal, since the waste pickers at the local level will handle a bulk of waste.
The non-biodegradable garbage may enter the recycling route, and biodegradable garbage could be used
for composting in the locality.
There are less clear savings for the waste producers who do not pay the true costs for waste
management. The amount collected from taxes is also too little to carry out a door-to-door collection.
The waste producers are obliged to pay a meagre amount to the waste pickers in these decentralised
schemes, and these costs are nothing compared to the real costs they would be burdened with if they
had to undertake the service provided by the waste pickers. Further, it also provides the households
with a means of taking the responsible person to task if the service is not provided, rather than relying
on the government agencies.
The issue of legalising the wastepickers into the formal system, and giving them an uplifted status in
society, requires moves at the level of the waste owners (Municipalities). The ways and means to
achieve this integration has been widely discussed, and innovative partnerships have come about in
several states of India but such schemes need to be widely accepted and spread through the country by
the Government, which is yet to formally recognise the wastepickers as the owner of the waste.
It would be worthwhile considering measures that could involve them in the functioning of
decentralised waste management schemes since it entails monetary benefits for the Government,
wastepickers and the waste generators.
6.4 Reorganisation of the Recycling Sector

The market for recyclable materials is crucial for building a source separation programme, and one of
the main concerns today is the quality of recycled products. The author has stressed the fact several
times during the course of the chapters that the conditions of the recycling units in the informal sector
have to be changed, and these units demand complete reorganisation. The recycling industry has to be
promoted as it presents a source of livelihood to million of people in the country. However the current
practices employed in the recycling sector make it highly unsustainable. Slight efforts by the
government to encourage this sector can really help to improve the quality of recycled products in the
country. As a first step, the government has to formalise these units and make them accountable.
Further, technology upgrades and training could be carried out in these recycling units to improve the
quality of recycling carried out in the sector. Once the quality of recycling improves, then the products
could compete at prices closer to virgin products, and the Government can also consider promoting
recycled products.
61
A planned stepwise approach may help in reorganising this sector. The primary step of formalising the
recyclers is a huge task, since there are no incentives for the recyclers to become formalised in the
existing conditions. Here, appropriate incentives such as reduction in sales tax and excise duties may
help them to come forward and register themselves as formal units. Such a formalisation needs to be
followed by reorganisation of these units in small clusters in one industrial area. This may also help to
control the wastewater effluents from recycling units in an economical manner, by setting up a
common effluent treatment plant (CETP). Further relocating them to one industrial area would also
help in enforcing rules and regulations on this sector. Since technology enhancement issues, training in
the recycling sector and setting up a CETP involves costs, the plastic industry should play a major role
in contributing the necessary finances and technological know-how to improve this sector.
Alternatively, the finances generated through earmarked taxes could also be utilised.
Hence, the government should facilitate a centralised approach to recycling rather than leave it
scattered as small-scale units. This would help to cut out the pollution caused by recycled plastics, and
also improve the quality of recycled plastics that can impinge on the virgin plastic market. As the
quality improves, the Government could assist in promoting good quality recycled products.
6.5 Extended Producer Responsibility

Extended Producer Responsibility is an emerging principle focussing more on products rather than
production facilities. In a broader sense EPR is a strategy that aims to achieve a decreased total
environmental impact from the entire life cycle of the product (Lindhqvist, 2000). This aim could be
achieved by making the producers bear a degree of responsibility for the environmental impacts of
their products throughout the products life cycles, including upstream impacts arising from the choice
of materials, from the manufacturing process and downstream impacts from the use and disposal of
the products (Davis, 1994).
One of the regulatory instruments that embody EPR includes mandatory take-back where a producer
takes back a product at the end of its useful life either directly, or through a third party. The model of
take back is not new to India where refundable deposits on refillable glass bottles for beverages are
common.
The rationale behind a deposit refund for PET in India is to stimulate high levels of collection, reuse
and recycling which thereby could help in alleviating the littering problem.
6.5.1 Deposit refund system

A Deposit Refund System (DRS) imposes an upfront charge, the deposit, so as to encourage efficient
resource use, prevent littering and save disposal costs. It guarantees a return of that charge, the refund
upon assurance that the activity has been undertaken. The purpose of DRS is to induce buyers of the
products in the system to return the empty packaging for some kind of reprocessing, either reuse or
recycling. A DRS directly affects reuse and recycling since it helps to make containers available for such
action.
The approach in the United States has been in the form of state-level bottle bills for beverage
containers. Such a system has helped them to increase return and recycling rates, reuse of refillable
bottles and also reduce litter. In Michigan, for example, the return rate of containers one year after the
program was implemented was 95 percent. In Oregon, littering was reduced and long-run savings in
waste management costs were achieved (OECD, 1996).
In Taiwan a DRS has been in operation for PET since 1988 and has been very effective in practice.
The deposit rate in Taiwan has been set at a level yielding strong incentives for recycling .The wide
62
distribution of collection points, and the development of a sizable salvaging company has contributed
to the success of the scheme. The scheme was introduced when the consumption of PET bottles was
260 million bottles/year. The recycling rate of PET had almost reached 80% during the fourth year of
operation (OECD, 1996).
The concept of DRS has existed in India for several years on refillable glass bottles. This system has
been very effective in India. In case of glass bottles, the packers had good incentives to take them back
as they could reuse and refill the glass bottles.
In the case of PET, a DRS will help to ensure good collection, which may help to reduce littering, and
also help prevent the illegal use of used PET by the informal sector in the mineral water segment75and
increase recycling rates. With these benefits, there are important costs elements connected to DRS,
which include not only capital expenditures and differences in running costs for all actors involved in
the scheme, but also of costs for administration of the scheme. The relevant costs and benefits
associated with establishing a DRS for PET include the following:
• Benefits from reduced waste collection and disposal,
• Benefits from reduced litter,
• Benefits from reduced input in container production,
• Benefits from increased health of the public,
• Costs due to increased storage, handling and processing,
• Inconvenience costs for households.
The costs and benefits of the scheme should be evaluated and can be considered if the outcome is
more favourable than the other alternative schemes. A DRS is also beneficial in the sense that it does
not affect income distribution, since a full refund is possible on every deposit. Lower income groups
might be more inclined to return empty containers than the better off and so the impact of DRS may
be progressive. This is with the assumption that non-redeemed deposits can cover the total costs
entailed by the system.
6.5.2 Organisation of the deposit refund system

In designing deposit refund systems for PET, the key stakeholders that need to be considered include
the packers/fillers, PET manufacturers, retailers, transport firms, PET recyclers and the consumer.
There are no incentives for the PET manufacturers to take back PET bottles, and hence they have and
will demonstrate strong resistance (because their turnover will negatively be affected) to such a system.
The packers/fillers (Coca Cola, Pepsi, Bisleri) have to be the actors where responsibility for setting up a
system could be directed. As of now, the packers and fillers face no incentive to collect the PET
bottles, but transferring the responsibility through legislation to these packers would help them to
effectively reuse the refillable, and pass down the non -refillable to the recycling units in the country.
75 Total bottled water segment has a size of Rs 11-12 billion and around Rs 7 billion is in the hands of the organized sector
and the rest is with the unorganized sector. The organized sector includes brand names like Bisleri and the unorganized
consists of a number of operators who enter the market in summers, reap benefits by packaging tap water as mineral water.
This sector utilizes used PET mineral bottles that are littered, cleans them and packs tap water into them. Poverty and
illiteracy levels allow these players to take full advantage of consumers by selling tap water as mineral water.
63
Generally retailers will be reluctant to accept new deposit-refund schemes, since handling returned
bottles requires extra work. Their decisions will be based on the following: consumer preferences, costs
of storage; sometimes, (e.g. in inner cities, available storage space might be a constraint. more storage
room will reduce room for shelves, thereby reducing retailers assortment), costs of handling that is
collection and administration, opportunities for being compensated for the costs mentioned above.
(OECD, 1993) Consumers may accept the system if they are given a good refund and convenience to
return the containers. In India, even if the consumer discards it, the ragpicker would collect and obtain
the deposit.
Looking at the PET recycling sector in India, there is not much information on the exact number of
players in the market. There are very few recycling units in the country, but they have ample capacity to
handle the current PET consumption. Some of the units suffice their capacity with import of clean
PET waste. Since introduction of a DRS may make clean PET waste available, this may serve as an
incentive for the recycling units to utilise the local PET waste. Clean waste could also encourage bottle-
to-bottle recycling, which could also help to minimise consumption.
The various actors and the incentives they would face to adopt a DRS have been summarised in Table
6-1
Table 6-1 Incentives for a deposit refund system in India
Probable actors involved in DRS Probable incentives actors face to accept a DRS
PET manufacturing units The industry would oppose such a system, as it

would affect their production.
Packers/fillers May find it useful if the costs associated with
establishing such a system are not too high, since
they could reuse the refillable bottles
PET recycling units Could find it economical if clean local PET waste is
available since it could stimulate bottle-to-bottle
recycling.
Retailers May accept since consumer acceptance of PET
bottles is higher than glass
Users Middle class families would return the bottles if
convenience is provided to reclaim the refund
Wastepickers On failure of the consumer to return the bottle the

ragpicker would return to claim the deposit.
Although a detailed study to confirm these incentives is required, the initial survey reveals that such a
system could gain acceptance among the actors concerned for PET bottles in India. Considering that
all the actors come together to establish a system, there are issues concerning the structure of the
instrument, that is, the size of the deposit and the refund and roles and responsibilities of these actors
in such a system.
As discussed in Section 5.4, the major problem of littering is associated with the 1 litre and 500 ml
bottles, legislation mandating a DRS should cover these bottles, besides others in the market. Such
legislation could also give incentives for better design of the 1 liter and 500ml bottles thereby initiating
a tendency of reuse among the packers/fillers.
64
Prior to this the Government may benefit from having a complete status report on the size of the PET
market, the key packers operating in the market, number and size of PET recycling units, amount of
PET waste generated and collected for recycling. With this information one could analyse if a deposit-
refund system yields a higher benefit-to-cost ratio than other alternatives.
The current PET bottle production in India is likely to grow to 1.3 billion bottles by 2002. Hence, it is
crucial that a proper system is formulated to manage the rising consumption, to prevent the problem of
littering from further aggravation. A DRS could be one of the possible options that could be
considered in alleviating the problem However a more longer term solution to the problem of PET is
to ensure access to clean water supplies in the country, and not only to those who can afford bottled
water. PET littering has arisen with the rising use in the mineral water segment. Fresh water supplies
need to be protected from contamination thereby minimising bottled water usage. Making clean water
available may help to reduce PET consumption in the country in the future. Government investment in
providing for certain basic needs can lower the costs for waste management and resource depletion.
Tata Energy Research Institute (TERI) estimates that the annual cost of ensuring that every Indian has
access to clean drinking water is Rs12.2 billion. The provision of adequate sanitation accounts for
around 60% of the abatement costs, investments in providing piped drinking water account for one-
sixth (16%) of the abatement costs; and sewage and effluent treatment account for the remaining one
fourth (24%). While these costs seem high in the aggregate, they are only about Rs 130 per capita per
year. The cost of such public intervention is several times lower than the cost individuals bear when
they buy bottled mineral water or water purifying devices (TERI, 1999).
6.6 Emergence of Substitutes: Bioplastics (?)

Sustainable product development has attracted a lot of attention in the last few years, and there has
been extensive research looking at ways to provide material needs using energy efficient, non-toxic and
renewable sources rather than finite materials. It is increasingly being realised that the use of long-
lasting polymers for short-lived applications is not entirely justified, especially when increased concern
exists about the preservation of finite resources. Conventional plastics are persistent in the
environment, if improperly disposed, they are a significant source of environmental pollution and have
a costly impact on waste management. For these reasons, replacement of non-degradable polymers by
degradable plastics, particularly for single-use disposables and packaging applications, is of major
interest to decision-makers. Further, researchers have been very optimistic on the enormous potential
of replacing oil-based plastics with materials from naturally occurring polymers.
6.6.1 Composition of bioplastics

Bioplastics are made by the building blocks of complex carbohydrates like cellulose or starch and
reconstructing (polymerising) them into plastics either chemically, biologically or thermally using micro-
organisms. The degradation of the polymer may be caused by naturally occurring micro-organisms, the
assistance of UV and heat radiation, sunlight, hydrolysis by water and oxidation by air. There are four
main types of bioplastics available in the market today:
• Thermoplastic starch
• Cellulose acetates
• Polyhydroxy fatty acid (PHA)
• Polyactides
65
Of these, PHAs and thermoplastic starch are acceptable non-hazardous alternatives to petroleum-based
plastics. Not all bioplastics are environmentally sound. Some of them require chemical modifications,
and or metal catalysts in their production process (Edwards, Kellet, 1999).
6.6.2 Advantages of bioplastics in waste management

The current market for bioplastics has been limited for products created to become waste like
packaging. The market for compostable bags is developing very fast and many countries are using these
bags for separate collection of organic waste. Other products include trash bags, food containers,
beverage cups and bottles to name a few.
The overriding advantage of bio-based over petrochemicals, is that they are derived from renewable
and vastly abundant resources. Further their production is safe and manufacture does not generate
toxic hazardous material.
Biodegradable bioplastics clearly have many advantages for single use disposal. The main problem with
polybags is the non-biodegradability, but bioplastics can be safely landfilled with complete
biodegradability.
6.6.3 Status of bioplastics in India

There is a lot of awareness among the research institutions on the potential of bioplastics in India
However, India appears to be investing only in first generation of oil based plastics, that have starch to
impart it with biodegradability. Biodegradation of polymers can be achieved in two ways. One way is to
synthesise polymer like PLA/PHB, which are biodegradable in nature. The other way is to modify the
properties of non-biodegradable plastics by the incorporation of additives that help in breaking the
molecular chain and permit direct metabolisation by microbes when disposed in nature (CDC, 2001).
In India the R&D efforts have focussed more on the second approach of biodegradation. The National
Research Development Corporation of India has developed a biodegradable plastic76 by mixing
plastics/ LDPE and starch made from tapioca and a soluble chemical agent that will soon bring
biodegradable bags in the market. This plastic is found to have adequate mechanical strength, and has
taken only 2 months under soil burial for complete disintegration. The starch component, being
organic, degrades in the soil and once the molecule of the compound breaks, its vulnerability to
bacterial attacks increases, thus resulting in its disintegration. (CDC, 2001).
Currently there are two units in India who have opted for the above-mentioned technology for
production of biodegradable plastic. One of these units located in North India is producing 30-40
tonnes/year of biodegradable plastics in the granular form. Their products have been quality tested in
India’s premiere research institutions (Shriram Institute for Industrial Research). Their focus has been
mainly on the packaging sector (carry bags, shopping bags, woven sack, and disposable containers. etc.
The selling price of the biodegradable plastic is Rs 80-100/kg and the price of a normal plastic product
is Rs 60-70/kg. Further there is an excise duty of 16% on all products. Unfortunately cost constraints
have limited their markets, and thereby production. (CDC, 2001) The company claims its products are
biodegradable when buried or under continued exposure in atmosphere in 4 to 24 weeks thereby
avoiding environmental pollution.
Another unit located in state of Maharashtra has started production since September 2000, and has
developed a process indigenously by importing chemicals (polymers) for degradation, and additives to
enhance strength and capacity. So the production technology is a combination of imported and
76 This work has been done by DR S.K.Nanda at the Central Tuber Crops Research Institute, Kerala.
66
indigenous efforts. Their products have also been tested at the National Chemical Laboratory in Pune.
The claims have been that the biodegradation of the product could take place aerobically and
anaerobically and with/without the presence of light. The end products from this unit include
shopping bags and refuse bags (CDC, 2001). Currently the company is facing difficulties to market
biodegradable plastics because of the cost factor. The cost of biodegradable plastics is Rs 110/kg due
to 67.5% import duty on imported chemicals.
The market size of biodegradable plastics is estimated at present to be 46,000 tonnes in India and is
likely to go up to 96,000 tonnes in 2006-07 based on a 15% penetration level of potential segments.
(CDC, 2001)
Product applications for bioplastics will largely depend on its material properties like its strength,
lifespan, resistance to heat and water and the ability to package food items. Further the successful
introduction of these products also depends on their functional advantage, cost, waste management
attributes (ways of dealing with bio waste), ways of marketing and legislation.
6.6.4 Challenges ahead

There are number of factors that impede the adoption of bioplastics. A few of them are mentioned
below:
• All bioplastics are relatively more expensive than oil based plastics. There are high research and
development costs associated with them. The scale of production is low, and hence the price bias
exists. There are technical uncertainties with the right choice of material for selected applications.
• The legal framework for the utilisation of biodegradable materials is still very unclear. Within
waste management, local authorities have not treated bioplastics as compostable material (Edwards,
Kellet, 1999).
• Definitions of biodegradability and compostability are unresolved. An international standard for

degradable materials is now being developed, which is vital for the bioplastic stream to operate
successfully.
• The achievement of total biodegradability.
The development of starch-based biodegradable plastics looks very promising given the fact that starch
is inexpensive, available throughout the year, and biodegradable in various environments. The main
drawbacks the industry is running into are low water-barrier properties of bioplastics and the migration
of hydrophilic plasticisers with consequent ageing phenomena.
The bioplastic industry is still in its infancy and there are still several uncertainties that prevent the
large-scale adoption of bioplastics but continuous research in this direction may ensure that bioplastics
of the future will be produced from renewable sources and will display in-use properties similar to
those of conventional plastics. This in turn may change the scenario of plastic waste management to a
large extent.
One has to remember that moving from one technology to another based on non–toxic renewable
input, will not by itself change the development paradigm. Bioplastics and products made from
renewable sources may address the issues of toxicity and conserving finite oil resources, but bioplastic
is just another manufactured material. Introduction of bioplastics may well solve the waste problems of
packaging, and more so single use disposals, but it will still encourage a more conscience free consume
and throwaway culture (Edwards, Kellet, 1999).
67
6.7 Concluding remarks

The recommendation relating to various options has been highlighted. It has to be remembered that
there is no single solution to the problem of polybags and PET in India. Source separation and
decentralisation of waste management appears to be workable in metropolitan cities, where the
throwaway culture is rampant. Simultaneously, the recycling industry that needs technological
enhancement could be reorganised by a stepwise approach. The Cess or environmental tax can
facilitate this process by generating the revenues necessary. The deposit refund system could work if
the government enacts a legislation mandating a take back by the packers/fillers to prevent littering of
plastic products (PET in particular).
Moving towards more sustainable products is the need of the future, and hence bioplastics as an option
cannot be ignored. There are several factors that impede its full-scale adoption today, but it may be
ready for commercialisation on a large scale in the next few years. If our material needs can be fulfilled
in a more sustainable way, using renewable resources, then definitely one should consider the transition
from use of hydrocarbons to use of carbohydrates. Potentially India is better placed than other
societies to make this transition, as one third of India’s population still fulfils its material needs77 in
sustainable ways.
77 The richness of biodiversity in the developing world is abundant. Most of rural India already has a sustainable agriculture
system for manufacturing bioplastics. Localized bioplastic production requires few infrastructures and creates less pollution.
68
7. Conclusions
Population growth and the rapid pace of urbanisation pose several environmental challenges for large
cities in India. One of these challenges is waste management, and specifically plastic waste
management. Plastic waste has attracted widespread attention in India, particularly in the last five years
due to the widespread littering on the landscape of India.
The environmental issues regarding plastic waste arise predominantly due to the throwaway culture that
plastics propagate, and also the lack of an efficient waste management system. Problems have been
identified in the collection, transportation and disposal, and these primarily stem from the inefficiency
of the municipalities. Municipalities, who are responsible for collection, have failed in fulfilling their
responsibilities in the face of increasing amounts of waste, and the scarcity of budgets for waste
management.
In parallel to the formal system, are the wastepickers, who value much plastic waste since it represents a
source of livelihood. However, plastic carry bags and PET do not figure in their priorities, because
collecting them is not profitable. This is primarily because the rewards do not match the efforts
required for collection, which leads to plastic bags and PET continuing to pose a major threat to the
environment. With the formal and informal sector failing to collect such waste, India’s landscape is
littered with polybags and PET, with polybags dominating the litter. Polybags in particular have been a
focus particularly because it was found choking sewers, killing animals and clogging soils in India.
Plastic recycling presents a unique scenario in India. Polybag recycling is carried out by the informal
units, which are characterized by outdated technologies, unskilled labour, and poor health and safety
conditions for workers. Unless these pressing issues are addressed, the quality of the recycled products
from this sector will continue to remain poor.
Unlike polybag recycling in the informal sector where several illegal units have mushroomed, PET
recycling units are a part of the formal sector, and are also very few and far between. The exact reasons
for the lack of collection of PET waste by these units are not very clear. Information is available on
only one recycling unit that carries out recycling of PET into polystyrene fibres, using imported waste
for this purpose. Given the fact that such type of recycling does not require clean PET waste, it
remains unclear as to why the local PET waste (which is not as clean as imported waste) is not
attractive to these recyclers. Further there is no interest from the packers and fillers to collect and
utilise the 1 litre and 500 ml bottles that contribute to the litter, as they are thin and cannot be reused.
As the littering problem in the country increased, the government convened a task force that identified
the issues relating to plastic waste, and possible solutions to the problem. Based on the
recommendations made by the task force, the Government drafted the first comprehensive Rule on
plastic waste entitled Recycled Plastic Manufacture and Usage Rule. The Rule enforced in 1999 aimed
to curb the littering problem and minimise the health risk associated with polybags.
Prior to this national legislation, several states such as Mumbai, Goa, Shimla, and Kashmir, that attract
a large number of tourists had formulated policies of their own, to address the acute littering problem.
Since there exists no comprehensive legislation on handling PET waste, the existing situation and
discussion on a take back policy for PET bottles was discussed during the task force meetings.
Detailed analysis of the case study of Mumbai has revealed that despite adequate enforcement the
Recycling Rule has not been able to address the littering problem. The Rule has several flaws that make
it weak and cause it to fail in achieving the desired objectives. Clearly, the notification by calling for
increasing the thickness of the plastic bags has skirted the real problem of reducing plastic waste. The
69
primary aspect that should have been addressed was the uncontrolled use of plastic bags, since
polybags, to a large extent are a problem of downstream consumption. Since polybags are cheap, they
propagate a throwaway culture. The Rule has not been able to restrict this throw away habit by
minimising consumption.
The lack of efficient waste management also contributes to the problem of littering. The waste
management process in India needs complete reorganisation, with a clear definition of roles and
responsibilities among the various stakeholders. The existing waste management system has several
bottlenecks at each stage, and overcoming these bottlenecks requires adequate financial resources. The
Rule makes no provisions for mobilising the resources required to improve the existing system.
Another crucial aspect is the lack of involvement of all the stakeholders in addressing the problem of
littering. The Government has failed to recognise that polybags are an issue, be they virgin or recycled.
Instead, they blame only the recycled bags for being the root cause of litter. As a result, the virgin
plastic industry has been let off the hook, with no roles and responsibilities in ameliorating the
problem.
Given the inherent lacunae in addressing littering and its associated problems, the Rule further worsens
the existing situation by pushing more virgin plastics into the system. Ideally, policies should prevent
waste generation, and encourage more efficient resource use. This Rule, however, ignores the idea of
resource conservation.
In the case of PET, the Government has overlooked rising consumption. There is an interest from the
policy makers to discuss a take back solution, but the discussion with various stakeholders is still in its
infancy. The failure to establish a proper system through legislation to manage the rising PET
consumption is the key cause of littering.
Looking into the underlying causes of littering, the end of life management of the products in question
contributes to the problem. It is also undeniable that the gradual changes in lifestyle, littering habits of
citizens, and lack of an efficient waste management system contribute to the widespread problem. So,
policies aiming to address littering should not only focus on preventing waste generation, and reducing
the throughput of the products, but also consider reorganising the waste management system to keep
pace with the changing consumption patterns of society.
A few recommendations have been made that may help in assisting policy makers in their future
decision making on plastic waste management. Since the key problem with polybags is the
indiscriminate use and disposal, disincentives such as environmental taxes have been discussed, which
might help to reduce the consumption of polybags. This also has the additional benefit of generating
revenues for waste management. However the key problem with an environmental tax is that it is
difficult to enforce given the existing state of regulatory agencies in India.
The Government and industry in India have been favourably disposed to establishing incineration with
energy recovery plants in India. This technology may be able to address the immediate problems of
plastic waste management but could well aggravate the environmental problems in the long term if
stringent emission standards are not enforced. Further it may also affect the recycling industry by
possibly sparking competition between recycling and incineration. Incineration with energy recovery
also entails huge costs, which is a crucial factor that needs to be considered prior to its introduction.
Another aspect that requires attention is the calorific value of the waste in India. Municipal waste in
India is characterised by low calorific value, high moisture content, and high quantities of non-
combustibles. So, additional fuel may be required during the incineration process, and this leads to
additional costs. European countries such as Sweden and Denmark have found this technology
attractive since their waste has high calorific value and heat generated is effectively utilised for district
70
heating purposes. In the light of above mentioned facts, careful considerations need to be given to
establishing waste to energy plants in India.
It has been realised that waste management is not the sole responsibility of the municipal authorities;
instead, it needs the involvement of all the stakeholders. This is crucial for improving the existing
system. Reorganising the waste management system by decentralising it may help to organise waste
management in India. A number of innovative partnerships for decentralising waste management
already exist in the country today, but there is a need to sustain such partnerships, and spread them
throughout the country. This requires the cooperation of the waste owners (Municipalities) and waste
generators (consumers). The idea of source separation and decentralising waste management clearly
provides a long-term solution to the problem of waste management in the country. This would also
help to ensure a good quality of recyclables into the recycling sector, and reorganisation of the recycling
sector will help to effectively utilise the waste, and thus produce better quality products. Reorganisation
of the recycling sector also entails costs, which could be mobilised through an environmental tax or
cess on the plastic industry.
A take back system for PET will help facilitate proper collection and recycling of PET in the country.
Since the secondary market for PET is well developed in the country, the availability of clean PET
waste through take back may help to effectively utilise it for recycling of various kind either fibre
production or bottle-to-bottle recycling. The non-availability of clean water has boosted PET
consumption in the country. So it would be worthwhile to conserve fresh water supplies, and ensure
that they are made available to the public at large. This will prove to be a long-term solution for
decreasing PET consumption.
Bio-plastics are a promising technology that can change the scenario of plastic waste management.
There are still several aspects that are unclear about bio-plastics, but further research may bring to light
several features that might aid the replacement of oil-based plastics. Such a development may of course
solve several waste problems related to packaging, but would probably still propagate a throwaway
culture.
Plastic waste is a pressing issue in the country today. A large number of Indians have turned away from
traditional modes of consumption, and are moving towards more wasteful patterns of resource use.
The increasing purchasing power and consumerism of the burgeoning Indian middle class is moving
India into the vicious use-and-discard cycle. Halting these consumption patterns seems difficult in the
light of globalisation and modernity. Ideally, looking at more sustainable means of satisfying need
should be the goal for the near future, but we also have to face the reality and challenges of the existing
situation. The consumption of plastic will double to 8 million tonnes in 2006, and subsequently, the
plastic waste will also escalate. Given this scenario, it is crucial for India to check the use of plastic in
the country. The existing policies have not been able to provide any respite against littering and its
associated problems. Therefore there is an urgent need to identify policy options that can help in
establishing an efficient waste management process, and ensure efficient resource use in the country.
However finding solutions to these problems calls for an active involvement from the stakeholders,
particularly the Government, to translate the goals into reality, by taking the required initiatives. Such a
proactive approach by the Government, along with a clear policy agenda, and the cooperation of all the
stakeholders to realise the policy goals, will only help to ensure sustainable use of plastics in the
country.
7.1 Future research

There are several issues that require further research with regard to polybags and PET. Among them,
PET represents a potentially significant area of research, since it has not been studied in great detail in
India. The various stakeholders (i.e. the PET producers, packers/fillers, and PET recyclers etc.), and
the incentives they face to collect PET waste have not been clearly identified. Thus, in view of the
71
limited research conducted in this sector, it would be worthwhile to carry out a detailed study on PET
waste, prior to considering a system for the management PET bottles in India.
72
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List of Interviewees
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Mr. A.M. Deshpande, Maharashtra Pollution Control Board, Mumbai (3 July 2001)
Mr. Achrekar, Deputy Municipal Commissioner, Mumbai Municipal Corporation, Mumbai. (3 July
2001)
Mr. S.M.Rathod, Chief Engineer, Solid waste Management Department, Mumbai Municipal
Corporation. (Email Communication: 4 August 2001).
Industry Associations
Mr. O.P.Ratra, Indian Centre For Plastics and Environment, New Delhi. (29 June 2001)
Mr. Rajendra Naik/Dr Bhat, Indian Centre For Plastics and Environment, Mumbai (2 July 2001)
Mr.V.K.Grover, Chairman, Indian Plastic Institute, New Delhi. (29 June 2001)
Mr.V.K.Taparia, President, Organisation of Plastic Processors of India, Mumbai. (5 July 2001)
Mr.Rajesh Mittal/Sunil Jain, President, Recycled Plastic Manufacturers Association, New Delhi. (21
June 2001)
Raw material Manufacturers
Dr Swaroop, Business Development, Reliance Industries Limited, New Delhi. (24 July 2001)
79
Mihir Banerjee, Manager Applications Development, Indian Petrochemicals Corporation Limited, New
Delhi (28 June 2001)
Plastic Processors
Mr.Vijay Merchant, President, Polycraft Chemicals, Mumbai. (6 July 2001)
Packers/Fillers
Mr.Ashish Sethi, Director, Bisleri, New Delhi. (27 July 2001)
Mr.Deepak Jolly, Marketing Manager, Pepsi Foods, New Delhi (21 July, 2001)
Research organisations
Mr.V.P. Malhotra, Deputy Director, Shriram Institute of Indusrial Research New Delhi. (20 July 2001)
Non - governmental Associations
Ms Bharati Chaturvedi, Director, Chintan Environmental Organisation, New Delhi. (25 June 2001)
Ms Nidhi Jamwal/Mr.Kushal yadav, Research Associate, Centre for science and Environment, New
Delhi (28 June 2001)
Mr. Ravi Aggarawal, Chief Coordinator, Toxic Link/Srishti, New Delhi. (25 June 2001)
Mr. Nishant Bharadwaj, Development Alternatives, New Delhi. (27 June 2001)
Mr. Jaising Makawana, Project director Anti Plastic Campaign, Dignity Foundation, Mumbai. (13 July
2001)
Ms Priya Ubale, Coordiantor ICPE –NAGAR project, NGO Alliance For Governance and Renewal,
Mumbai. (12 July 2001)
Ms. Mahalaxmi Bhobe, Goa Foundation, Goa. (Email Communication: 7 August 2001)
Mr. Frederick Noronha, freelance journalist, Goa. (Email Communication: 20 July 2001)
80

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IIIEE Reports 2001:11

Analysing Plastic Waste Management in India

Thesis for the fulfilment of the

LIST OF FIGURES ......................................................................................................................................III

4.2.2 State specific initiatives.............................................................................................................................................. 34

LIST OF INTERVIEWEES ..........................................................................................................................79

The Indian currency is Rupees and 1 Rs =100 paise

• What are the existing policies initiatives to address these issues?

• What are the strengths and shortcomings of the existing initiatives?

• What policy options can be considered to ameliorate the existing problems?

4. Analysis of the information gathered in the above phases.

1.4.1 Study for developing a framework for policy evaluation

1.4.2 Study of the plastic waste management system, its problems,

1.4.3 Interviews with various stakeholders in the plastic chain

1.4.4 Analysis of the information gathered in the above two phases

1.5 Structure of the Thesis

2.1 Objectives of Sustainable Waste Policies

As a major component of municipal waste, packaging waste contributes to various environmental

1. Prevention of waste generation at source as the first priority

3. Reuse and recycling should be practised to the extent possible

4. Treatment of waste prior to disposal

5. Disposal is the least preferred option.

Waste prevention in the context of Waste Minimisation (OECD, 1999)

Incineration with Energy Recovery

Figure 2-1 Linkage between waste prevention and waste minimisation

• Waste prevention and reduction

• Increased use of recycled materials

• Reduced natural resource consumption

2.2 Characteristics of Sustainable Environmental Policies

2.2.1 Environmental effectiveness

2.2.2 Cost efficiency

2.2.4 Administrative feasibility

2.2.5 Social and political acceptability

2.2.6 Incentives for improvements

2.3 Framework for Policy evaluation

Existing policy for evaluation

Analysing the objective of the

Policy evaluation based on the criteria of

Criteria for evaluating • Equity

• Incentives for Improvement

Figure 2-2 Framework for policy evaluation.

3. Plastic Industry in India

3.1 Sector Profile

Consumer (Finished products) Processors of the virgin

Post Consumer Waste

Figure 3-1 Structure of the Virgin plastic and Recycling Industry.

3.2 Plastic Consumption in India

Table 3-1 Demand scenario for key commodity plastics in India

Polymer 1995-1996 2001-2002 2006-2007

Table 3-2 Indian PET market (tonnes)- Current and projected

Market Segment 2000 2003

3.3 Plastic Waste Management in India

The predominant sources of post consumer plastic waste are:

• Municipal sources that include residential households, markets, small commercial

Virgin resin manufacturers and plastic processors

Post Consumer Waste

Waste plastics Uncollected waste

! Sorting and cleaning

Figure 3-2 Plastic waste management in India

3.3.1 Plastic waste generation

Table 3-3 Plastic waste generations in India

1995-1996 2001-2002 2006-2007

3.3.2 Plastic waste collection and disposal