Plastic Waste Management (PWM) rules 2022 have brought in the much-awaited clarity on the implementation of EPR targets by producers, brand owners, and importers (PIBOs). Engaging with an EPR agency has always been one of the easiest ways for companies to meet EPR compliance. With PIBOs getting approached by so many agencies, it can be overwhelming to decide on the right EPR agency.
Based on our experience, going for the most economically priced agency often results in non-compliance due to pending orders and thus, the company has to start all over again. Attempting to set some benchmarks in this domain we chalked out the following defining characteristics which are very crucial for any firm scouring for an EPR agency;
1. Proven Track Record
2. Collection Network and Team
3. Financial Capabilities
4. Social Programs
5. Technology Usage
Proven Track Record
EPR agencies having on-field operation and execution experience of more than 2 years can be safely assumed to have a sufficient track record.
Do have a look at the agency’s existing clientele, e.g., companies working with recognisable brands such as HUL, Dabur, Marico, Cosmo Films, Amcor, Asian Paints, who provide more confidence since these brands have a vendor background checking process.
Collection Network and Team
A consolidated collection and sourcing network forms the backbone of EPF fulfilment. The network includes direct tie-ups with municipalities, municipal corporations, waste collection agencies, scrap dealers, cement plants, and recyclers. Operationally deep and wide networks increase the possibility of on-time and 100% guideline-compliant EPR fulfilment.
Having an EPR agency with a strong team both at ground level and at office level can really make a difference. CPCB regularly updates the guidelines and also the PWM Rules, with at least 2–3 amendments in the coming year. Fulfilling EPR within the dynamic nature of compliance guidelines necessitates an agile team that can quickly adapt.
Thoroughly enquiring EPR agencies with respect to their background, years of experience of the management and on-field team can bring more clarity on EPR agency capabilities.
Questions to ask
- How many municipalities, cement plants and recyclers are you directly working with?
- Please tell us about how much plastic will be procured from municipalities, scrap dealers, and recyclers?
- Tell us about your management team’s background and domain experience?
If you are producing or using 100 tonnes of multi-layered plastic per month, your annual EPR fulfilment expenditure will be around 27–34 Lacs. If your agency lacks sufficient financial stronghold, then EPR compliance can get deferred on a regular basis. Thus, you should ask;
- What’s the monthly volume (recyclable and non-recyclable) of plastic you are doing currently?
- What was your turnover for the previous two financial years?
- What is your revenue from EPR fulfilment operations?
The EPR mandate has the power to bring about a transformation into the lives of thousands of informal waste workers as they form an integral part of the system. Unfortunately, at present not much is done to integrate these waste workers into the EPR compliance.
Some EPR agencies that understand the contribution of waste workers are experimenting with different models. One such model is being worked upon in Goa; waste workers operating in the MRF plant, were covered by the NITI Aayog report. This model is implemented by Sampurnearth Environment Solutions. A few experiments are going on in Malegaon and Dhoraji as well. When negotiating with EPR agency you ought to ask:
1. About the number of waste workers benefited through their operations.
2. Capacity building programs run by them to improve the waste management system
EPR fulfillment is filled with all kinds of unethical practices such as bogus material movement, document forging, quantity exaggeration etc., appropriate use of digital technology can bring transparency and traceability reducing malpractices.
Scan these QR Code
Imagine such a unique QR code is assigned to each recycling certificate or order. Instantly anyone with QR code can verify all the information bringing down malpractices significantly. This technology is already perfected by Saksham.net * and recyclers in our network appreciate such initiative as it creates more credibility for them.
Another example could be activity history like the one we have when we order anything online, similar systems can be implemented for material movement as well. You can also check this free to use EPR Calculator tool to see your EPR obligation for FY 21–22 and FY22–23.
Companies must encourage EPR agencies to use technology to introduce traceability and transparency to the EPR fulfilment process.
All above parameters for deciding the right EPR agencies are not exhaustive and you can always add new parameters to suit your situation. Integrating these parameters will make life a little easier for your company.
Disclosure: Social Lab Environmental Solutions works in the waste management domain and also provides EPR fulfillment services. The article is written in view of creating more wider knowledge about the domain.
* Saksham was developed by Social Lab Environmental Solutions. It is being discussed here not for promotional purposes, but because no similar application has been released in this domain.