Brand Audit toolkit

Baseline data to implement Extended Producer Responsibility

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1. Acknowledgment

Global Alliance for Incinerator Alternative, GAIA (www.no-burn.org), and #breakfreefromplastic movement had conducted a brand audit on several nations as part of World Environment Day celebrations. The audit was conducted by Green Army as per the guidance of Thanal, a GAIA member at Thiruvananthapuram. Methodology for Global Brand audit was framed by GAIA and #breakfreefromplastic movement. The methodology was improvised further to suit local scenarios in Thiruvananthapuram by Thanal. The document is consolidating learnings from Global Brand Audits, Brand Audit at Thiruvananthapuram, and Thanal’s position on Extended Producer Responsibility.

2. Background

Though plastics have been categorised into seven verticals as per the chemical monomer or polymer, diversity has increased as more & more manufactures are producing packaging material that is a mix of 2 or 3 types of plastic. Higher the rate of diversity among materials lower the chances of . The complexity of packaging material hinders recycling and thus sustainable use of resources through a circular economic model can not be achieved. Plastic, a petroleum derivative, can not follow the Linear economic model, where material from used plastic products is not recovered. Extended Producer Responsibility is a policy measure that helps the government to check the irresponsible use of plastic by any manufacture.

Implementation of Extended Producer Responsibility can ensure that manufacturers take up physical disposal of post-consumer material or finance scientific treatment and disposal or financial liability for environmental cost due to material generated/treated post-consumption. Brand Audit helps to identify manufacturers and brands that contribute the most to waste generated during / post consumption of a product.

3. Extended Producer Responsibility

Extended Producer brings the disposal of byproducts/waste generated by a product or by its use/consumption under the responsibilities of the manufacturer. The responsibility shall be carried out either in the form of physical disposal or cost for scientific treatment and disposal or financial liability for environmental cost/damage. In other words “the responsibility of a producer for the environmentally sound management of the product until the end of its life.” The method of implementing EPR is jointly decided by all the stakeholders. The principle is applied to those categories of waste that local governing bodies find difficult to manage. Plastic Waste Management Rules 2016 published via Gazette of India on 18th March 2016 and amended on 27th March 2018 mentions the role to be played State Pollution Control Board and Local Self Government units.

This principle is practised widely in developed western nations. Manufacturers or brand owners have established networks and infrastructure to take back byproducts/waste generated by their product during its use/consumption/post-consumption. Incentives are also provided to consumers to ensure a safe deposit of byproducts/waste generated at authorised collection centers.

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4. Brand Audit

Brand Audit is the process of accessing the contribution of all manufacturers and brand owners in municipal solid waste produced. The contribution is assessed in terms of both weight and number of pieces. The percentage contribution of each manufacturer and brand owner can be linked to the implementation of Extended Producer Responsibility. The audit process also analyses the presence of various types of packing material and the type of products that contribute the most to municipal solid waste.

The audit data presents a waste generation pattern for a particular section of consumers. Thus the result depends on the sample chosen for audit. It is advisable to conduct brand audits for specific sections of consumers so that accurate results are obtained. Conducting audits for specific consumer sections will also make the process easier. A similarly structured audit for various sections of consumers/consumer products can be compiled to prepare integrated action plans to implement extended producer responsibility.

A. Definitions

i Brand Owner A person or an umbrella company that owns trademark license, patents, share/equity, etc. OR A person or company who sells any commodity under a registered brand ii Product Manufacturer A person or a registered company/unit that manufactures a product. iii Manufacturer A person or unit or agency engaged in the production of plastic raw material to be used as raw material by the producer iv Product Name The name in which a product is sold/marketed

v Product A single word that describes material sold inside the packing

vi Product Category Classification based on usage of the product vii Packing The material used for packing the product

viii Single Layer A type of packing that uses one single material for packing

ix Multi-Layer A type of packing that uses more than one material for packing OR Any material used or to be used for packaging and having at least one layer of plastic as the main ingredients in combination with one or more layers of materials such as paper, paper board, polymeric materials, metalized layers or , either in the form of a laminate or co-extruded structure x PET Poly Ethylene Terephthalate

xi LDPE Low-Density Poly Ethylene

xii HDPE High-Density Poly Ethylene www.thanal.co.in Page 3 of 18

xiii PS Poly Styrene

xiv Other Hard Plastics Hard (PP) and Polyvinyl Chloride (PVC)

xv Study Area The area of human interaction where waste generation takes place

B. Tools & Equipments i. Sheet for Data Entry a. Input waste

Details regarding plastic waste subjected to Brand Audit is to be entered in the format provided below.

Zero Error =

Sl Sample Source Source Weight Volunteer Date & Time Duration of No ID Locality Details (Least Count: 0.01gm) Responsible of Entry waste collection

1

2

3

b. Brand Audit A datasheet would be used to enter names of Brand Owner, Manufacturer details, Number of Pieces, Weight, Type of packing, Product Category, Product details, etc. The sample data sheet is provided below. The table ready for is attached as Annexure 1.

Zero Error =

Product Total weight of Sl Product Brand Product Type of No of Manufacturer Product packaging No Name Owner Category packaging pieces (Address in Short) (Least Count: 0.01gm)

1

2

3

c. Post audit verification

Details to be filled in the format below to verify weight details entered in each category.

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Sl Category ID Total number of Total Weight Volunteer No (unique ID for each sack/) pieces (Least Count: 0.01gm) Responsible

1

2

3

d. Volunteer registration

Venue: Brand Audit Date:

Sl No Name Organisation Phone Number Signature

1

2

3

v. Measuring Equipments a. Weighing scale of large samples

Digital weighing scale with precision or with least count up to 1gm / 0.001kg is required to measure input waste and also to weigh audited categorised samples. The number of such equipment may be decided based on the size of the sample and the availability of volunteers. b. Precision scale for individual samples Digital weighing scale with precision or with least count up to 10mg / 0.01gm is required to measure samples that belong to each product name. The number of pieces may be as low as One and thus high precision weighing scale is required to collect data on weight-wise contribution of each product name to the total plastic waste analysed.

vi. Sorting Equipments a. Floor Mat

A tarpaulin mat or HDPE sheet or used Flex hoardings could be used as a floor mat for sorting. The floor mat also prevents material from scattering on the floor and loss in samples. It enables better cleaning post brand audit. b. Sacks Large sacks made out of polypropylene (PP) or jute could be used to collect samples from various locations. Sacks needs to be labeled as per Sample ID during waste collection. The same sacks can be used to collecting sorted audited samples as per sorting categories. Category ID should be labeled while storing material.

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c. Small-sized pouches / Carry / Small-sized pouches or carry bags are required to store segregated and categorised plastic waste as per Product Names. Pouches / carry bags from collected unbranded plastic waste can be used for this purpose. Weight & number has to be regularised at both categories.

vii. Safety, Hygiene & Health requirements

The following list of personal protective equipments and sanitation materials needs to be provided to volunteers. Face mask & Gloves shall be provided to each volunteer. Sanitation materials shall be as the total count of volunteers for emergencies.

a. Face mask b. Gloves c. Dettol / Salvon anti-septic d. Soap for hand wash. e. Band-Aid plasters f. Betadine ointment g. Availability of tap water & drinking water h. Availability of food & snacks

C. Auditing Process i. Audit preparation

The brand audit would be smooth and error-free if the below-mentioned procedures are followed. It would also ensure accuracy in data collected and analysed. a. Sample size determination

The study area and sample size need to be selected with caution. If the audit is intended to analyses brands of plastic waste generated from households, then sample selected for waste collection needs to be households. The sample size for analysis need not be more than 10% of the total number of units in the study area. The sample size can be as low as 0.1%. The sample size can be determined based on the diversity of units in the study area. The following aspects need to be represented well in the sample.

1. Representation from different geographical regions 2. Representation from different economical sections 3. Representation from different societal sections 4. Representation from various levels of urbanised settlements Brand Audit could be conducted for various Study Areas like:

1. Households 2. Transportation Hubs 3. Tourists / Religious centres 4. Ecologically sensitive zones. www.thanal.co.in Page 6 of 18

b. Waste collection The same duration of waste collection is to be maintained across all samples. It is advised to collect plastic waste for a period of 1 month / 30 days. 30 day period would allow the study to accommodate various human behaviour patterns that lead to waste generation. If the period of study can include a festive celebration, results would be more realistic. There is scope for studying festive behaviours alone when it comes to waste generation and brands responsible for the same. c. Product Categories for analysis Minimum categories for analysing waste collected are mentioned below.

1. Paper & Cardboard 2. Metal 3. E-waste 4. Hazardous waste (if any collected) 5. Slow decaying material (if any collected) 6. Plastic 6.i. Food & Snacks 6.ii. Personal Care Products 6.iii. Household products 6.iv. Unbranded plastic Additional categories in plastic can be introduced as per regional manufacturing units & consumer trends like:

6.v. Milk & Curd 6.vi. Flour Batter 6.vii. Provision 6.viii. Packaged Drinking water & Beverages 6.ix. Cooking Oil 6.x. Products in Analysis of plastic based on additional product categories is to enable local self-government units to use brand audit data in negotiating with Brand Owners to implement Extended Producer Responsibility. Categories specific to manufacturing units in the state/region can be included to collect specific data. d. Packaging materials for analysis

The type of plastic packing material is to be identified for collected waste. Minimum identification categories are

1. Single-layer plastic 2. Multi-layer plastic 3. PET / HDPE 4. Styrofoam 5. Other Hard plastics (PP & PVC) 6. Carry bag/pouches 7. Others www.thanal.co.in Page 7 of 18

If the role/contribution of the specific packaging material is to be analysed, additional categories can be introduced. e. Orientation of Volunteers

Volunteer orientation is required before the study is initiated. After the period of waste collection, volunteers have to be oriented on the importance of the below-mentioned topics before the Audit.

1. Period of study 2. Adherence to samples selected 3. Importance of number of pieces as per Product Name 4. Importance of weight of plastic pieces as per Product Name 5. Identification of Product Category 6. Identification of Packing material Four to five examples under each product category and under each packing material to be displayed at the venue for volunteer’s reference. Concept of Extended Producer Responsibility, Brand value, and role of Civil Society organisations to collect evidence and baseline data of Brand occurrences shall also be explained to volunteers.

ii. Brand Audit process a. Venue for audit

The following aspects to be followed while selecting the venue for conducting brand audit 1. Sufficient space for spreading collected waste for sorting & categorising. 2. Sufficient ceiling height & windows for ventilation 3. Proximity to tap water 4. Even floor surface 5. Minimal furniture 6. Convenience for loading and unloading material from truck/pick-up/car. 7. Availability of labeled waste bins. b. Volunteer Registration & Grouping

Organisers should make sure that all participating volunteers are registered, grouped as per the number of sorting categories, and instructed about the auditing process. The sample template for Volunteer registration is provided in 4.B.i.d. Each group of volunteers is to have 3 members. 2 members from each team shall weigh/sort the materials and the 3rd member shall note down details. c. Recording input waste

The weight of material subjected to brand audit is to be recorded. Details are to be recorded as per 4.B.i.a. A team that records the weight of input waste shall have 3 volunteers. 1st and 2nd volunteer shall weigh the material using a weighing scale for a large sample (4.B.v.a pg5) and the 3rd volunteer shall record details. Following precautions to be noted: 1. Weight of the sack (4.B.vi.b) is to be factored as Zero Error. To find out zero error, weigh an empty sack using 4.B.v.b. Weight considered for a sack (4.B.vi.b pg5). The zero error shall be noted in the form 4.B.i.a in the space provided for Zero Error.

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2. The zero error can be adjusted in the weighing scale (4.B.v.a pg5) by using tier feature or the value can be adjusted after data entry during analysis. 3. Details about the source of waste are to be recorded with caution. Details should include the number of houses/institution capacity/any other detail that can throw light on the number of waste generators. 4. Weight measured using (4.B.v.a pg 5) should have accuracy up to 1gm. d. Sorting & Auditing Separate volunteer teams are required to sort and audit waste collected. Allotment of volunteers for recording input waste and sorting shall be in such a way that the smooth flow of material from input data entry to Sorting/auditing mat is ensured. The following points to be noted for sorting & auditing waste. 1. Primary categories of sorting shall be as per 4.C.i.c pg7 2. Volunteers should be instructed to go through examples displayed under each product category and each packing material 3. The team should be allotted specific product categories to sort. 4. From the team that consists of 3 volunteers, 2 volunteers should sort material as per classification allowed. The Third member shall note down details required in Form 4.B.i.b pg4 5. Materials in the same product category are to be sorted as per Product Name (4.a.iv pg3). A thumb rule to identify Product Name is to locate/identify the name that is printed in the Biggest font on the packing material.

If no name is printed/visible/embossed, the item can be entered as “Unbranded”. 6. Details required in form 4.B.i.b pg4 are to be filled in clearly. The brand owner of the product name can be identified using the following keywords. 6.1. “Marketed by” 6.2. “Manufacture for” 6.3. “Trademark of” 7. The address of the Product Manufacturer is to be identified from “Manufactured by” written on the packing material. It is to be noted that a detailed address is not required for analysis. 8. A single word that can describe the material is sold inside the packing, is to be written against Product. 9. Type of packaging is to be noted once all the waste collected is sorted and ready for counting & weighing. The volunteer has to identify the type of packing from among the examples displayed at the venue. Please refer to 4.C.i.d pg7 for types of packaging material. 10. Volunteers must take special care to count and weigh materials sorted as per Product Name 11. Product Name, Brand Owner, Product Manufacturer must be written down legibly. 12. Small pouches / carry bags (4.B.vi.c pg6) can be used to weigh sorted material. Sorted materials are kept inside the pouch/carry bag and then weighed. Weight of small pouches/carry bag used for weighing must be factored as Zero Error. The same must be recorded in the data entry sheet 4.B.i.b pg4. Zero Error can be adjusted in the measuring equipment or while doing analysis. 13. Datasheets have to be filled in as per product category. Materials in the same product category are then later stored in larger sacks (4.B.vi.b pg5). A sack shall have material that belongs to only one Product Category. Each of the sack has to be labeled once filled. Three www.thanal.co.in Page 9 of 18

letters that symbolises Product category followed by a Numeric digit can be used as the nomenclature for labeling & storing sorted materials. e. Post audit verification

Form 4.B.i.c pg4 is used to verify that all materials collected have been sorted and audited. Sacks that are labeled as per clause 4.C.ii.d.13 pg9 are weighed. Volunteers should make sure that all sorted materials as per the categories mentioned in 4.C.i.c pg7 are weighed. The total weight of all the sacks is calculated and matched with total input waste from the form 4.B.i.a pg4. Any difference in input total waste and the total weight of sorted materials are to be noted, justified, and accommodated in the analysis.

i. Post audit analysis

Handwritten data sheets are to be entered in Microsoft Excel or any other analysis software. Data entry format can be the same as that of Datasheets mentioned in 4.B.i. pg4. The following parameters have to checked using analysis tools.

a. Total waste analysed b. Waste generated per household OR Waste generated per Institution / Unit / Entity

For: Period 1= 1month Period 2= 1 year c. Percentage contribution of each Major Product category 4.C.i.c 1 to 6, pg7 In terms of: 1. Weight 2. Number of pieces d. Percentage contribution of Branded products vs Unbranded products e. Percentage contribution of each Minor Product category 4.C.i.c 6.i to 6.x, pg7 In terms of: 1. Weight 2. Number of pieces f. Percentage contribution of Brand Owners in each Product Category In terms of: 1. Weight 2. Number of pieces g. Percentage contribution of Packing material in each Product Category In terms of: 1. Weight 2. Number of pieces h. Percentage contribution of Each Brand Owner in each Major Product category 4.C.i.c 1 to 6, pg7 i. Percentage contribution of top 20 Brand Owners against other brand owners.

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A. Sample Analysis

Figures to demonstrate analysis patterns listed below are taken from “Position paper on Extended Producer Responsibility: For Thiruvananthapuram Municipal Corporation”.

Source: http://thanal.co.in/resource/view/position-paper-on-extended-producer-responsibility-for- thiruvananthapuram-municipal-corporation-11414323 www.thanal.co.in Page 11 of 18

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5. Legal aspect

A. Solid Waste Management Rules, 2016

Relevant sections from Solid Waste Management Rules, 2016 are mentioned below. Highlighted portions show clauses mentioned in the rule that can be used directly to implement Extended Producer Responsibility.

therefore, in the exercise of the powers conferred by sections 3, 6 and 25 of the Environment (Protection) Act, 1986 (29 of 1986) and in supersession of the Municipal Solid Waste (Management and Handling) Rules, 2000, except as respect things are done or omitted to be done before such supersession, the Central Government hereby makes the following rules for the management of Solid Waste, namely:- 11. Duties of the Secretary–in-charge, Urban Development in the States and Union territories.- (1) The Secretary, Urban Development Department in the State or Union territory through the Commissioner or Director of Municipal Administration or Director of local bodies shall,- (a) prepare a state policy and solid waste management strategy for the state or the union territory in consultation with stakeholders including representative of waste pickers, self help group and similar groups working in the field of waste management consistent with these rules, national policy on solid waste management and national urban sanitation policy of the ministry of urban development, in a period not later than one year from the date of notification of these rules; (b) while preparing State policy and strategy on solid waste management, lay emphasis on waste reduction, reuse, recycling, recovery and optimum utilisation of various components of solid waste to ensure minimisation of waste going to the landfill and minimise the impact of solid waste on human health and environment; (h) direct the town planning department of the State and local bodies to ensure that separate space for segregation, storage, decentralised processing of solid waste is demarcated in the development plan for group housing or commercial, institutional or any other non-residential complex exceeding 200 dwellings or having a plot area exceeding 5,000 square meters; (k) arrange for capacity building of local bodies in managing solid waste, segregation, and transportation or processing of such waste at source; 14. Duties of Central Pollution Control Board.-The Central Pollution Control Board shall, - (i) publish guidelines, from time to time, on environmental aspects of processing and disposal of solid waste to enable local bodies to comply with the provisions of these rules; and (j) provide guidance to States or Union territories on inter-state movement of waste. 15. Duties and responsibilities of local authorities and village Panchayats of census towns and urban agglomerations.- The local authorities and Panchayats shall,- (a) prepare a solid waste management plan as per state policy and strategy on solid waste management within six months from the date of notification of state policy and strategy and submit a copy to respective departments of State Government or Union territory Administration or agency authorised by the State Government or Union territory Administration; www.thanal.co.in Page 13 of 18

(b) arrange for door to door collection of segregated solid waste from all households including slums and informal settlements, commercial, institutional, and other non- residential premises. From multi-storage buildings, large commercial complexes, malls, housing complexes, etc., this may be collected from the entry gate or any other designated location; (e) frame bye-laws incorporating the provisions of these rules within one year from the date of notification of these rules and ensure timely implementation; (f) prescribe from time to time user fee as deemed appropriate and collect the fee from the waste generators on its own or through authorised agency; (h) setup material recovery facilities or secondary storage facilities with sufficient space for sorting of recyclable materials to enable informal or authorised waste pickers and waste collectors to separate recyclables from the waste and provide easy access to waste pickers and recyclers for collection of segregated recyclable waste such as paper, plastic, metal, , textile from the source of generation or material recovery facilities; Bins for storage of bio-degradable wastes shall be painted green, those for storage of recyclable wastes shall be printed white and those for storage of other wastes shall be printed black; (r) transport non-bio-degradable waste to the respective processing facility or material recovery facilities or secondary storage facility; (v) facilitate construction, operation and maintenance of solid waste processing facilities and associated infrastructure on their own or with private sector participation or through any agency for optimum utilisation of various components of solid waste adopting suitable technology including the following technologies and adhering to the guidelines issued by the Ministry of Urban Development from time to time and standards prescribed by the Central Pollution Control Board. Preference shall be given to decentralised processing to minimize transportation cost and environmental impacts such as- (x) make adequate provision of funds for capital investments as well as operation and maintenance of solid waste management services in the annual budget ensuring that funds for discretionary functions of the local body have been allocated only after meeting the requirement of necessary funds for solid waste management and other obligatory functions of the local body as per these rules; (zd) ensure that the operator of a facility provides personal protection equipment including uniform, fluorescent jacket, hand gloves, raincoats, appropriate footwear and masks to all workers handling solid waste and the same are used by the workforce; (zf) frame bye-laws and prescribe criteria for levying of spot fine for persons who or fails to comply with the provisions of these rules and delegate powers to officers or local bodies to levy spot fines as per the bye-laws framed; and (zg) create public awareness through information, education and communication campaign and educate the waste generators on the following; namely:- (vii) storage of segregated waste at source in different bins; (viii) handover segregated waste to waste pickers, waste collectors, recyclers or waste collection agencies; and

B. Plastic Waste (Management and Handling) Rules 2016

Relevant clauses from Plastic Waste (Management and Handling) Rules 2016 are mentioned below. Important clauses are highlighted. From the highlighted portions, clause 9, sub-clauses (1) and (2), it is very evident that Plastic Waste (Handling and Management) Rules 2016 (amended in 2018) www.thanal.co.in Page 14 of 18

assigns responsibility for the management of plastic waste to Brand Owners, Manufacturers, and Importers. Date obtained from Analysis can be used to determine the scope and extend of Brand Owners’, Manufacturers’ and Importers’.

Notification dated: 18th March 2016, New Delhi

“in exercise of the powers conferred by sections 3,6 and 25 of the Environment (Protection) Act, 1986 (29 of 1986), and in supersession of the Plastic Waste ( Management and Handling ) Rules, 2011, except as respects things done or omitted to be done before such supersession, the Central Government hereby makes the following rules, namely:- 3. Definitions: (b) “brand owner” means a person or company who sells any commodity under a registered brand label. (h) “extended producer’s responsibility ” means the responsibility of a producer for the environmentally sound management of the product until the end of its life; (m) “manufacturer” means and includes a person or unit or agency engaged in the production of plastic raw material to be used as raw material by the producer. (n) “multilayered packaging” means any material used or to be used for packaging and having at least one layer of plastic as the main ingredients in combination with one or more layers of materials such as paper, paper board, polymeric materials, metalised layers or aluminium foil, either in the form of a laminate or co-extruded structure; (o) “plastic” means a material which contains as an essential ingredient a high polymer such as terephthalate, high-density polyethylene, Vinyl, low-density polyethylene, polypropylene, polystyrene resins, multi-materials like acrylonitrile butadiene styrene, polyphenylene oxide, polycarbonate, Polybutylene terephthalate; (p) “plastic sheet” means Plastic sheet is the sheet made of plastic; (s) “producer” means persons engaged in manufacture or import of carry bags or multilayered packaging or plastic sheets or like, and includes industries or individuals using plastic sheets or like or covers made of plastic sheets or multilayered packaging for packaging or wrapping the commodity; (i) "recycling" means the process of transforming segregated plastic waste into a new product or raw material for producing new products; 6. Responsibility of local body.- (1) Every local body shall be responsible for the development and setting up of infrastructure for segregation, collection, storage, transportation, processing and disposal of the plastic waste either on its own or by engaging agencies or producers. (2) The local body shall be responsible for setting up, operationalisation and coordination of the waste management system and for performing the associated functions, namely:- (a) Ensuring segregation, collection, storage, transportation, processing and disposal of plastic waste; (b) ensuring that no damage is caused to the environment during this process; (c) ensuring channelization of the recyclable plastic waste fraction to recyclers; (d) ensuring processing and disposal on the non-recyclable fraction of plastic waste in accordance with the guidelines issued by the Central Pollution Control Board; (e) creating awareness among all stakeholders about their responsibilities; (f) engaging civil societies or groups working with waste pickers; and (g) ensuring that open burning of plastic waste does not take place. (3) The local body for setting up of system for plastic waste management shall seek assistance of producers and such system shall be set up within one year from the date of final publication of these rules in the Official Gazaette of India. www.thanal.co.in Page 15 of 18

(4) The local body to frame bye-laws incorporating the provisions of these rules.

9. Responsibility of Producers, Importers and Brand Owners.- (1) The producers, within a period of six months from the date of publication of these rules, shall work out modalities for waste collection system based on Extended Producers Responsibility and involving State Urban Development Departments, either individually or collectively, through their own distribution channel or through the local body concerned. (2) Primary responsibility for collection of used multi-layered plastic sachet or pouches or packaging is of Producers, Importers and Brand Owners who introduce the products in the market. They need to establish a system for collecting back the plastic waste generated due to their products. This plan of collection to be submitted to the State Pollution Control Boards while applying for Consent to Establish or Operate or Renewal. The Brand Owners whose consent has been renewed before the notification of these rules shall submit such plan within one year from the date of notification of these rules and implement with two years thereafter.

(3) manufacture and use of non- recyclable multilayered plastic if any should be phased out in two years. (4) The producer, within a period of three months from the date of final publication of these rules in the Official Gazette, shall apply to the Pollution Control Board or the Pollution Control Committee, as the may be, of the States or the Union Territories administration concerned, for grant of registration. (5) No producer shall on and after the expiry of a period of Six Months from the date of final publication of these rules in the Official Gazette manufacture or use any plastic or multilayered packaging for packaging of commodities without registration from the concerned State Pollution Control Board or the Pollution Control Committees. (6) Every producer shall maintain a record of details of the person engaged in the supply of plastic used as raw material to manufacture carry bags or plastic sheet or like or cover made of plastic sheet or multilayered packaging. (12) Prescribed authority.- (1) The State Pollution Control Board and Pollution Control Committee in respect of a Union territory shall be the authority for enforcement of the provisions of these rules relating to registration, manufacture of plastic products, and multilayered packaging, processing and disposal of plastic wastes. (2) The concerned Secretary-in-charge of Urban Development of the State or a Union Territory shall be the authority for enforcement of the provisions of these rules relating to waste management by the waste generator, use of plastic carry bags, plastic sheets, or like, covers made of plastic sheets and multilayered packaging. (3) The concerned Gram Panchayat shall be the authority for enforcement of the provisions of these rules relating to waste management by the waste generator, use of plastic carry bags, plastic sheets or like, covers made of plastic sheets and multilayered packaging in the rural area of the State or a Union Territory. (4) The authorities referred to in sub-rules (1) to (3) shall take the assistance of the District Magistrate or the Deputy Commissioner within the territorial limits of the jurisdiction of the concerned district in the enforcement of the provisions of these rules.

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6. Stakeholder consultation

To implement Extended Producer Responsibility Successfully, the methodology for execution should consider problems faced by waste generators and include suggestions put forward by brand owners and product manufacturers. Implementing party: the local government body /district administration/state government should consult the below-mentioned parties before framing the implementation mechanism. i. Local Government Body Officials ii. State Pollution Control Board iii. Elected Representatives iv. Urban Development, State Government (Swachh Bharat) v. Civil Society Organisation vi. Retailers & Distributors vii. Brand Owners & Manufacturers viii. Informal Sector ix. Recycling / Forwarding Agents The following aspects should be discussed with all stakeholders: i. Brand Audit Results ii. Legal Provisions a. Duties of Government bodies/authorities b. Responsibilities of Brand Owners & Manufacturer iii. Collection / Tack back mechanism a. Brand Owners collecting waste generated from/by their products by themselves. b. Brand Owners collecting waste generated from/by their products through their distribution network c. Local Government Body facilitating waste collection for Brand Owners iv. Investment from Brand Owners & Manufacturers for environment-friendly disposal/recycling v. Financial Investment to improve existing Waste Management Systems vi. Case Studies Framework for implementing Extended Producer Responsibility should be finalised after considering inputs from all stakeholders mentioned above.

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7. Annexure

Image 01: Transferring waste collected to Image 02: Recording for Input Waste designated sack (4.B.vi.b pg5) for Input Waste

entry.

Image 03: Display of sorting categories with Image 04: Waste after sorting as per Product examples Name

Image 05: Entry of audit details into form 4.B.i.b Image 06: Labelled Sorted waste after auditing pg4

Photo courtesy: Thomas Varghese (Green Army Volunteer) Raphaelle Buisset (Volunteer, Thanal)

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