Recycling Responsibility or Regulatory Theatre?

Introduction: The Illusion of Progress

As environmental concerns grow around plastic pollution, Extended Producer Responsibility (EPR) has emerged globally as a strategy to shift waste management responsibilities from governments to producers. In theory, EPR aims to hold companies accountable for the post-consumer phase of their products. But in practice, particularly in developing economies like India — the policy is often reduced to a bureaucratic formality. It’s a system that appears robust on paper yet fails dramatically at the point of execution.

Behind the metrics and legal frameworks lies a murky landscape where waste is rerouted, data is unreliable, and the financial incentives rarely reach those actually managing the waste. This article dissects the major systemic flaws in India’s EPR regime and situates them in the broader context of the global plastic trade, exposing how a well-intentioned policy is being subverted by design flaws, opportunistic intermediaries, and institutional inertia.

The Global Waste Shuffle: Exporting the Problem

Developed nations in Europe, North America, and East Asia have long treated plastic waste as an exportable problem. For decades, enormous volumes of waste were shipped out to developing countries under the guise of recycling. Countries like China, Indonesia, Vietnam, and India became dumping grounds for the Global North’s plastic glut — often with little regard for the environmental or social costs in the receiving countries.

The landscape changed dramatically when China banned plastic waste imports through its National Sword policy. This left countries scrambling for new outlets, triggering a rapid shift in trade flows to South and Southeast Asia. In India’s case, this translated into a sudden influx of post-consumer plastic waste — waste that frequently exceeded the domestic capacity to handle, monitor, or even track it effectively. Instead of focusing on local circularity, many Indian recyclers became part of a new international patchwork of unregulated or barely-regulated waste trade.

The EPR Model in India: Structured But Hollow

India introduced EPR through its Plastic Waste Management Rules in 2011, later revised in 2016 and beyond. On the surface, the rules mandate a shared responsibility system, where brand owners, importers, and producers must ensure that the packaging they bring into the market is eventually collected, processed, and reintegrated into the value chain.

In practice, however, EPR compliance is most often achieved through the purchase of digital credits from authorized recyclers — a system that mimics a carbon credit model. These credits are meant to represent actual quantities of waste processed, but they often operate in isolation from real-world logistics. The rules leave a loophole large enough to accommodate an entire trading industry: credit brokers now buy and sell certificates, sometimes multiple times over, with little connection to the underlying recycling activity.

For companies, this offers an easy compliance route. For the waste management ecosystem, it creates a distorted economy where funds flow sideways through middlemen, rather than down to collectors, aggregators, or actual recyclers.

Paper Compliance Over Practical Action

Many companies participating in EPR see it as a box-checking exercise — an item to tick off during audits or investor disclosures. There is minimal engagement with the ground realities of plastic waste management. Few producers are involved in infrastructure building, community engagement, or technological upgrades to improve recyclability.

The financial flows within this ecosystem are telling. At ₹2–4 per kilogram of EPR credit, the amount is far too low to fund collection, transportation, cleaning, and recycling. When considered against the full cost of running a legitimate recycling facility — wages, electricity, compliance, certification — the math simply doesn’t add up.

As a result, recyclers treat these credits as marginal income at best. They are not a reliable incentive but a paperwork requirement that may or may not be fulfilled based on political priorities and portal downtimes.

Regulatory Dysfunction: Technology Without Transparency

The CPCB’s digital portal — the backbone of the EPR tracking system — was intended to bring transparency. Instead, it has introduced opacity. Access to the portal is restricted, data is inconsistently reported, and the interface changes so frequently that users — especially recyclers and smaller brands — are often left confused.

In one glaring incident in 2024, the portal was hacked and thousands of tonnes worth of credits were reportedly stolen. The breach laid bare the fragile IT infrastructure and the lack of data validation mechanisms.

Moreover, the sheer volume of pending applications for EPR registration and certificate approval points to bureaucratic gridlock. Many recyclers have waited months, even a year, to get their operations formally recognized. In the meantime, they are unable to issue credits, access formal markets, or qualify for financing — driving them into informality or financial distress.

The PET Illusion and Polyolefin Reality

India often claims a high plastic recycling rate — upwards of 60% — but this number is grossly misleading. It is inflated by the efficient recycling of PET bottles, which have long been channeled into the textile industry. Polyolefins like LDPE, HDPE, and PP — which dominate flexible packaging — are far harder to recycle and far less integrated into any organized system.

Without disaggregated data by polymer type, policies are built on averages that don’t reflect the ground reality. This undermines planning, leads to skewed investment, and allows companies to buy credits for high-value, easily recyclable polymers instead of tackling harder-to-recycle formats.

Biodegradables, Bureaucracy, and Broken Promises

This pattern of over-regulation and under-execution is not unique to plastic packaging. The experience of biodegradable plastic manufacturers mirrors the same struggles — overcomplicated application processes, conflicting mandates from different authorities, and a general lack of technical knowledge among bureaucrats.

Despite official interest in promoting alternatives to traditional plastics, approvals for biodegradable materials have stalled under unclear guidelines, leaving innovators stuck in regulatory limbo. The same fate could befall recyclers trying to build scalable, sustainable businesses if institutional reform isn’t prioritized.

The Way Forward: Structural Overhauls, Not Cosmetic Fixes

To fix India’s faltering EPR system and plastic waste ecosystem, incremental tweaks will not suffice. What’s needed is a fundamental redesign of roles, responsibilities, and technologies. Key steps include:

•Establishing direct subsidy pathways from brand owners to verified waste handlers through a transparent escrow mechanism.

•Decentralizing EPR enforcement to include regional waste boards with technical support and decision-making autonomy.

•Recruiting environmental engineers and polymer scientists within CPCB and SPCBs to evaluate applications and advise on infrastructure development.

•Public dashboards and traceability tools that show real-time progress on targets, volumes processed, and regional plastic flow.

•Credit pricing linked to real costs — adjusted by polymer type, region, and recycling complexity — rather than one flat rate.

Conclusion: A Call for Co-Ownership

The flaws around innefiency of EPR in India is not because the idea is flawed — but because its execution has been hollowed out by tokenism, data opacity, and regulatory myopia. A compliance culture that values paperwork over environmental outcomes will always fall short.

Policymakers, brand owners, recyclers, and civil society must co-own the solution. Only then can we move from paper compliance to planetary responsibility. Until then, India’s EPR regime will remain a ticking time bomb — one where the cost is paid by nature, not those who profit from packaging it.