Issue Series #1: Extended Producers Responsibility and Inclusion: Informal sector integral to the success of India Inc’s waste management initiatives

by Pranshu Singhal

2020 and the pandemic has forced us to re-evaluate and reconsider how we deal with our environment and sustainability issues. Organisations, globally, had to pivot their plans to adapt to the new normal while balancing their SDG ambitions. The pandemic also impacted India’s waste management sector. In this paradigm shift, it has been made clear that frontline waste workers remain one of the most important elements of the entire waste management ecosystem- and will continue to remain so. Systemic solutions which address the needs of the informal sector and leverage their strengths will provide us with a pathway to solve some of our biggest environmental challenges.

It is not unknown that India and developing countries have a vast reliance on the informal sector for waste management. The informal sector jobs- sometimes built upon generations of families in the same trade and personal relationships between consumers and traders- are now facing a significant shift. This is happening in the foreground of changing consumption patterns and regulations which are trying to formalise the waste management sector. In some ways, these traditional jobs- our kabadiwallahs and kachrawallahs– are what empowers our citizens to maintain a significantly lesser per capita carbon footprint than various developed countries. It is also those in the informal sector who continued waste collection amidst the pandemic, even while established supply chain systems broke down, becoming the backbone of urban waste disposal systems. It is quite ironic then as our consumption pattern grows, it is also increasing the potential for displacement of jobs for lakhs of people engaged in the sector.

India is one of the largest waste generators in the world. In 2016, Extended Producer Responsibility (EPR) as a legislation came to the fore for the first time in the country. In its essence, EPR mandates brands and producers to be responsible for the end-of-life treatment of their product i.e.  it extends a producer’s responsibility beyond the sale of the product and allots financial costs and/or responsibility of physical infrastructure for its end-of-life management. First coined by my mentor, Professor Thomas Lindhqvist in 1990, EPR was designed with an aim of creating upstream changes i.e., system and design related improvements as well as downstream changes i.e., improved collection, treatment and utilisation of secondary materials from the dead product.

Producers are at the centre of this policy instrument because they know their product the best and can drive systemic changes in the most effective manner. It should be clarified that producers do not and cannot have all of the responsibilities in an EPR framework. There are many contributors in the waste management ecosystem. EPR can be successful only when duties are allocated to various actors in the product value chain, including consumers, recyclers, collectors and there is a level playing field for these stakeholders. Furthermore, in a country like ours, EPR needs to be inherently inclusive and contributions, especially of the informal sector, cannot be overlooked. Waste management industry has an immense potential to create legitimate, green jobs. 

In 2017, we formed Karo Sambhav with a goal of providing a sustainable, inclusive and scalable solution for brands that can fulfil their E-waste EPR mandate, as per the EWM Rules. Led by technology thought leaders, Karo Sambhav functions as a producer-led organisation which attempts to fulfil an ambitious vision of transforming the waste management industry and provide fair value to all actors. In September 2019, an Industry Coalition of 30+ companies announced the set-up of a new ‘Asia’s Largest Packaging Waste Management Venture’ in partnership with Karo Sambhav. Over a period of three years, this venture will operate over 125 material recovery facilities, collect over half a million tons of plastic waste by engaging over 2500 aggregators. 

There were 2 key components of our work that we identified to be critical for the success of the EPR frameworks that we have designed for e-waste and plastic waste management: 

• Complete transparency and visibility of our value chain: We wanted to ensure that our members had access to complete information and operations of Karo Sambhav. We co-created the processes and programmes with our founding members- Apple, Dell, HP and Lenovo. We attribute our current success to this strong foundation and thought leadership of these brands.
• Inclusion of the informal sector in a way that champions the EWM Rules: The EWM Rules do not make a reference to informal sector workers directly. We wanted to work towards sustaining these livelihoods dependent on the sector and help them in their transition for more stable sources of income. This allowed us to tap the informal sector for bulk quantities of e-waste and ensure the collection targets for producers could be met. While we worked on changing consumer behaviours, we learnt that the shift in waste procurement from waste collectors to consumers directly will need to be gradual. We did this by upskilling and building capacity of waste collectors on EWM Rules, providing support with GST registrations and overall building trust and relationships with various stakeholders in the sector. 

In the past 4 years of our operations, we have observed deep insights and learnings from having worked directly in the heart of the informal sector. The informal waste management sector, while informal, is not necessarily unorganised. Actors across multiple levels of the waste hierarchy have direct and indirect networks with waste generators i.e. consumers. The depth and breadth of these networks and connections are unmatched by any formal collection system in India. Last mile waste collectors, though at the bottom of the pyramid, are on the frontlines of waste collection and have direct access to consumers. Plagued by socio-economic factors, they are not able to leverage this access in the most efficient manner. They are influenced by the market dynamics which is set by perceived financial value in different types of waste streams. This also directly influences what waste is able to enter the formal recycling value chain. For eg, a PET bottle has more value than an MLP wrapper. Hence, low value plastics end up getting filtered out of the systems at source itself, negatively influencing the possibilities of innovations and development of an entire value chain. The gap between waste collectors’ contribution to the waste value chain and how well they are integrated in the system is quite wide. Hence, it is important to have a significant effort in engaging and educating the sector to enable them to become a stronger voice in the waste management ecosystem.

The recent Guideline Document on Uniform Framework for Extended Producers Responsibility (Under Plastic Waste Management Rules 2016) is a welcome step in this regard. For the first time, there is a proposed legislation which directly acknowledges the need for inclusion of waste pickers in a manner that improves their working conditions and incomes. We believe that this is an important step in fulfilling the spirit of Extended Producer Responsibility based Rules. There are also other positive measures mentioned in the Guideline Document which will have a systemic impact on waste pickers’ involvement in EPR:

• Focus on traceability of waste and transparency in operations. This will help bring visibility on the impact and contribution of waste collectors in the ecosystem.
• Digital systems for capturing EPR plans of producers, document trails / proofs will allow quantification of impact, better monitoring of compliances and driving efficiencies within programmes. Data-driven decisions can be taken about waste sources and waste hotspots. This will also ensure traceability and legitimacy of waste movement. 
• Registration of all stakeholders on one platform will allow a smoother transition of informal sector workers into legitimate livelihoods.
• Identifying and acknowledging the various existing collection channels including the informal channels will utilise the strengths of the waste pickers and the informal sector and unlock the various quantities of waste with them for scientific recycling.

An impactful implementation of EPR requires creation of win-win scenarios for various stakeholders in the system and holding all stakeholders accountable.  Government interventions, which clarify the roles of various stakeholders and create harmonised monitoring mechanisms, can accelerate some of the above initiatives. This will directly help in increasing the participation of the informal sector in formal waste management initiatives. These interventions could include: 

1. EPR based legislations (EWM Rules, PWM Rules) include a provision which allows informal sector actors to become legitimate collection channels
2. Establishing and implementing standards for the entire waste management and recycling value chain
3. Facilitating traceability in processes to track material flows
4. Enabling full transparency of the costs of EPR compliance. This will stop the race to the bottom and enable development of value-adding systems and processes which will help the whole sector to raise the bar and avoid exploitation of waste collectors.

EPR is a huge opportunity for the informal sector to become an active part of India’s journey to become a leader in sustainable waste management.  As a social enterprise, we will continue to leverage this opportunity and work in tandem with our peers in the informal sector. 

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Pranshu is the Founder of Karo Sambhav, an  organisation that enables producer brands to 

close material loops by collecting and recycling  waste related to their products. It is developing  socially responsible and financially viable circular  solutions by collaborating with disintegrated  players across waste value chains. It designs and  implements transformative Extended Producer  Responsibility programmes for electronics waste  

and plastic waste. 

Prior to Karo Sambhav, Pranshu was Director,  Digital Learning Strategy in the Worldwide Education team of Microsoft for 3 years. He had  worked with Nokia as Head, Sustainability for 11 years and was based in Finland, Singapore  and India. He is an Aspen Fellow, an Ashoka Fellow, a Chevening Gurukul Fellow, and an Aspire Fellow. He has been a co-chair in the GAP action Network on Education for  Sustainable Development of UNESCO. Pranshu has a Master’s in Environmental Management  and Policy from the International Institute for Industrial Environmental Economics (IIIEE), Sweden.