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Plastic waste management is the waste producer’s responsibility

Repeated warnings issued by scientists on the negative impact of plastic waste such as wrappers, discarded packaging material, and sachets, not only on the environment but also the health of people, have triggered action from packaged consumer goods companies. Dabur India Limited, one of India’s largest manufacturers of Ayurvedic medicines, has taken these warnings seriously and responded with a nationwide model for Extended Producer Responsibility (EPR).

Dabur plans to become plastic waste neutral by March 2022. For this, the company will be collecting, processing and recycling 22,000MT of post-consumer plastic waste from across the country under EPR. This covers both recyclables (like PET, HDPE, beverage cartons) and non-recyclables (multi-layered plastic). Tusar Ranjan Pattnaik, Corporate Head-EHS and Nitin Mishra, Associate Manager, Corporate EHS, Dabur India Limited take us through its EPR model.


L-R Tusar Ranjan Pattnaik, Nitin Mishra

Waste assessment study

Dabur’s EPR journey began in 2016 by appointing Nepra Environmental Solutions Pvt Ltd (NEPRA), an Ahmedabad-based waste management company, for a waste assessment study of all its units. Authentic data for EPR liability was obtained after studying all of the packaging categories of products, both qualitatively and quantitatively.

Each product is wrapped in a different way. Some are packed in glass bottles while others are packed in beverage cartons or PET/other plastics etc, which forms its primary packaging. Each product is labelled and packed in a shrink film or mono cartons, which forms its secondary packaging. In the end, they are dispatched in corrugated boxes which form its tertiary packaging.

This way, an entire inventory of plastic packaging was developed, plastic consumption for wrapping of each product was considered, and the quantum of each category of plastic put in the market was identified.

Categorisation of plastics

  • Category I: Rigid plastic packaging
  • Category II: Flexible plastic packaging of single layer or multilayer (more than one layer with different types of plastic), plastic sheets or their like and covers made of plastic sheets, carry bags (including carry bags made of compostable plastics), plastic sachets or pouches.
  • Category III: Multi-layered plastic packaging (at least one layer of plastic and at least one layer of material other than plastic).

Pan-India implementation of EPR

DIL has been implementing EPR since 2018. We use the EPR model ‘Engagement with Urban Local Bodies (ULBs) through Waste Management Agencies (WMAs)’ to do so.

We are currently working with 12 of India’s best waste management agencies to implement EPR in 36 states and union territories, with direct engagement with 80+ urban local bodies, 3,000+ rag pickers for collection of flexible, rigid and MLP plastic waste, and 35+ registered recyclers and 15+ co-processing facilities for sustainable disposal of plastic waste.

Auditing nationwide efforts

In order to achieve traceability in EPR execution, we have selected BDO, a world-class audit agency, to review the documents submitted by different WMAs against a standard audit checklist. We are also executing on-site audits to examine the collection and disposal processes. Various parameters like involvement of rag pickers, actual collection center working and provisions related to health and safety of the workers are checked during the site audit.

Dabur has appointed a service provider for collecting plastic waste from the market (irrespective of whether it was generated by Dabur or not) and delivering the same to recycling/co-processing units. The service provider issues a certificate to Dabur, which is submitted to the Central Pollution Control Board. The auditor has to:

  • Verify the existence of the underlying documents maintained by service providers for collection & recycling of plastic waste.
  • Review terms and condition of an agreement between brand owner & service provider and provide recommendation to standardise and benchmark with best industry practices to safeguard the interest and risks of brand owner as a company.
  • Assess the compliance to the terms of business agreed as per the contract between brand owner and service provider.
  • Assess and identify potential improvement opportunities in documentation (physical/soft copy) maintained by service providers.
  • Verify the accuracy of Extended Producer’s Responsibility calculation done by the brand owner.
  • Verify if the source of collection of waste material is through the eligible source as per the Plastic Waste Management rules/Agreement signed with service provider i.e. Rag pickers, waste collectors/NGOs, dry waste centers.
  • Ensure EPR diversion certificates issued are duly certified by Central & State Pollution Control Boards.
  • Physically visit different locations across India to check their collection system, the breakup details and to obtain a real time walkthrough assessment of the entire chain of activities (from waste pickup to compression to recycling).
  • Ensure compliance of statutory requirements applicable to brand owner, service provider, collection center & recycling/co-processing vendor

End-to-end process

  • Calculation of EPR liability on the basis of purchasing data of total plastic packaging material.
  • EPR liability calculation state-wise
  • EPR action plan preparation state-wise, and submission of action plan to CPCB & SPCB
  • Selection of WMA agency for implementation
  • Agreement of WMA with ULB and Agreement of WMA and Dabur
  • Agreement of WMA with registered recycler
  • Agreement of WMA with registered co-processor, waste-to-energy plant
  • Urban Local Body endorses the EPR quantity collected by WMA on behalf of Dabur
  • Submission of half-yearly report to the concerned SPCB.

Environmental impact

Through our EPR implementation, we have avoided 6871.39 MT of CO2 emissions through recycling, saved 784 MT of CO2  emissions through co-processing and waste-to-energy disposal, and avoided 10356 MT of CO2 emissions through beverage carton recycling, for a total of 18011.39 MT of CO2  emissions avoided.

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