Tackling the issues – an action plan

We accept been writing about the problems that could crop upwardly if the Government of India's Plastic Waste Management Rules 2022 are implemented as appear. Sadly, there has been an almost total lack of response or feedback on this issue from both brand owners and the packaging industry. Standing his caption of why the blanket ban on multilayer flexible packaging is based on a lack of understanding of the requirements and the possible solutions, South Chidambar says in this open letter to industry that while the blanket ban is impractical and unrealistic, information technology is also a serious claiming that cannot exist ignored. The packaging manufacture and brand owners need to go their act together with a real and pro-agile programme for concrete and positive activeness.

I am sad to point out that this ostrich-like reaction of burying i's head in the sand is not going to make the likely bug go away. It will only foster and strengthen the impression in the Government's listen that industry is not too unhappy with the rules as they have been framed. I think industry needs to act more than responsibly in their stakeholders' interests by taking positive pro-active measures. Then, here is a recommended activeness programme that I would like to put forward.

The issues

• Per se, the perceived threats could more or less be summarized equally follows:
• Banning of multilayered structures.
• Banning of multiple polymer or polymer/non-polymer combinations.
• Mandatory setting up of waste material collection (both in-institute and post-consumer use) and recycling/reprocessing infrastructure by make owners as extended producer responsibility.
• Seeking registration from statutory bodies to continue operations without putting such facilities in identify.
• Very substantial increases in costs if rigid not-polymer systems (like cans, bottles or cartons) or single-polymer solutions replace the optimum flexible packaging systems; these increases can certainly not exist absorbed by make owners and, if passed on to consumers, will result in large-scale price increases and inflation.
• More than 90% of the flexible packaging industry will accept to be shut down and thousands of jobs will be at stake if the PWM Rules 2022 are implemented equally presently framed.

A comprehensive all-inclusive road map has to be designed to address all these problems. I am giving below a proposal for such an action plan.

Need to unite
Beginning and foremost, the unabridged packaged goods manufacture (and this ways the unabridged manufacturing and retail industry – practically every product manufactured and supplied/distributed except for some essential services has to be packaged) must become together as i to collectively have this up with the regulatory and legislative system/authorities. This means putting aside competitive issues, conflicts of interest, rivalry, opportunism and diverse personal agendas and axes to grind and getting together to ensure that the very beingness and well-being of manufacture itself is non threatened.

Nobody in manufacture can have the mental attitude that he/she does non desire to be the 'bad boy' in the regime's eyes – allow someone else do the muddy work since, ultimately, the benefits volition come to them anyhow. There is another attribute to this – the powers that be volition accept serious cognizance of arguments only if they realize that the supplicants collectively course a large number of aggrieved people representing a vast and significant majority of industry.

Representations from individual organizations and fragmented industry associations will not have equally significant an impact and will not be taken as seriously fifty-fifty if pursued legally. The spin-off of this united front will exist that it can be used to pursue other issues as well. Ideally, this united body should have representation from consumers and consumer fora and the common man as well.

The association will need to be driven by the large boys in the consumer packaged appurtenances (CPG) business organization viz. the large FMCG companies, packaging majors and large-scale manufacturers of basic industrial materials similar resins, polymers, metals and industrial chemicals including PSU'due south similar IOC, GAIL, OIL and SAIL. The constituents will take to come from the entire spectrum of user industry sectors ranging from FMCG, food, nutrient service, appliances, white goods, healthcare, electronics and chemicals to basic, intermediate and industrial materials. Existing industry associations like CII, FICCI, Assocham, AIPMA, OPPI, Plastindia Foundation and IPI can too pitch in and back up the clan.

Complexity of communications
One of the problems that the association will come against is the complicated matrix of communication and interaction. Although the rules accept been issued past the Ministry building of Environment, Wood and Climate Modify and will be administered by them, several other ministries and administrative bodies will as well be involved in the mix and will have to be dealt with. Some of these are the Ministries of Commerce, Industry, Company Affairs, Urban and Rural Evolution, Chemicals and Fertilisers, the PMO, the Department of Science and Technology, diverse Land Pollution Control Boards, diverse State Governments and a host of Municipal bodies.

This is where a really widespread clan membership will come up in handy and individual companies with potent 'clout' with respective ministries and bodies can be used as the via media to exploit their relationships to get things done and for quick action. Therefore, the need for collective action is all the more important as opposed to individual initiatives.

Establishing brownie
Needless to say, the association volition have to establish credibility and take a positive and artistic approach to help address the government'south concerns on sustainability and transition to round economies for conservation of finite non-renewable resources. Every constituent volition accept to prove he is a responsible corporate citizen truly committed to reducing carbon footprint and Green House Gas (GHG) emissions and towards sustainable evolution. For example, rather than fugitive information technology, they should come frontwards with their own recommendations on how they can aid develop and establish infrastructure for waste product segregation, collection, reprocessing and recycling as role of extended producer responsibility.

(Here, again, this is best washed as a collaborative and collective effort beyond the entire manufacture rather than implementing individual stand-alone programs. This would brand the whole exercise work on a larger scale and be more cost-effective.) They could too offer to educate consumers and incorporate constructive communications in their packages/supply chains to make them more conscious towards their responsibilities on waste management and disposal.

In other words, the efforts should be focused not only on pointing out the impracticality of a large part of the PWMR 2022 in its nowadays form but besides on taking a positive pro-active approach to help the authorities solve some of the problems identified by them, (The ane affair we can exist sure of is that municipal bodies will be of no help in their willingness to either taking on boosted responsibilities or implementing them efficiently.)

Activeness Plan

• I would suggest that the action plan should initially be aimed at the following objectives:
• Unite and course a strong credible clan with the big boys taking the lead and working collectively. The association membership should exist as broad-based and every bit numerically high equally possible to found 'ascendancy.'
• Initiate a commonage communication and mass education plan to get their arguments across and to get government and consumers on lath to working on applied solutions.
• Exercise an extensive analysis and testing of the multilayered and composite structures in current use in packaging. Clearly establish how they cannot be replaced effectively by rigid or single-polymer systems particularly for high-barrier applications and how they incur a much lower carbon footprint and resource utilization past carrying out formal Life Cycle Analyses (LCA'south) and other testing programs from well-known industry,scientific and bookish institutions to buttress their case.
• Build upward and present an irrefutable example on how no country anywhere in the world has been able to develop viable alternatives to multilayered and multi-polymer systems.
• Conspicuously institute how flexible packaging solutions are by some distance the optimum mode out in and so far as utilization of input resources are concerned.
• Come with at to the lowest degree initial proposals on how the industry can collectively set up a in-institute and mail-consumer waste product segregation and collection system.
• Efforts will besides have to be initiated on developing waste reprocessing and reuse technologies (finding equivalent or upscaling reuse options and not downscaling them) and finding markets for the 'regenerated' resources.

Conclusion
I sincerely hope that the top honchos in industry realize the enormity of the impending crisis if the government gets balderdash-headed (which they well might given that lack of manufacture response and overall industry ennui has been and so palpable) and decides to implement the PWMR 2022 in its present grade. Time is running out – and fast!

If manufacture needs whatsoever assistance in getting its act together and work out suitable plans, we can more than provide this. This time, I promise that industry will react and provide feedback expressing their willingness to implement most of what I take been talking about. I am eagerly looking forward to receiving this. z

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