Aipma at work
AIPMA's Suggestions Suggested Amendments to Draft Notifications - Plastics Waste Management Rules 2015
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n preambles we suggested to remove the word “Polluter” or define “Polluter”. The word “Polluter” can be replaced with “Waste Generator’s”. Anywhere in the complete notification the words Polluter must be eliminated if found.
“Plastics” and the definition should be simplified as follows: “Plastics” means material which contains as an essential ingredient a high polymer which at some stage in its processing into finished products can be shaped by flow;
2. Applications: the notification has everywhere mention of Manufacturer and Producer but nowhere mentioned Importer. So the word Importer needs to be added everywhere there is manufacturer and Producer’s responsibility. Also the word Importer should be well defined.
3 (n) “Plastic Sheet” should be replaced with following “Plastic Sheet / Films”
3 (b) The definition of Carry bags need to be reverted to either same as 2009 definition or bring more clarity on “CARRY BAGS” word as the other packaging are considered to be carry bags under the current definition. We Suggest “Carry Bags” mean bags from plastic material, having carrying features used for the purpose of carrying or dispensing commodities, but do not include bags that constitute or form integral part of any other packaging in which goods are packed/sealed prior to use 3 (g) The words “environmentally sound management” should be explained with more details. 3 (i) The following words should be added before recycling “….collection, storage, recycling…” 3 (k) Under “Manufacturer” either we include Importer or separately add “Importer” and define it. 3 (m) “Plastic” should be changed to
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3 (o) in the end following words can be added “as per IS 14534:1998 “ 3 (q) “Producer” definition should be rephrased as “Producer” means a complete value chain of Persons, Industries or individual’s engaged in the manufacture of Polymers and Packaging of Plastics. 3 (w) The words “Scientific” should either be better explained or eliminated. The word “reclaiming” should be added. The words “or disposal” must be removed as Plastics are meant to be recycled and not disposed. 3. More definitions / clarifications should be added as follows: 1. Importer/s 2. Recycling which should be phrased as “Recycling can be of any type Mechanical, Waste to Energy or Waste to Fuel.” 4 The word “Import” should be added after manufacture and before stocking. 4 (b) The para should be rephrased as “The food contact layer of Packaging sheet / Film shall not contain recycled
Plastic or products made of recycled Plastics” 4 (c) & (d) The “Carry Bags” thickness should be maintained at 40 Microns and not increased. If increased it will lead not only lead to increase of packaging cost and hit common man’s pocket but also lead to excessive consumption of precious fuel. Stringent Penal Clause should be implemented on companies not producing “40 Microns thickness Carry Bags”. Increasing thickness will not lead to better collection as value increase of “Waste Carry Bag” will increase negligibly. The thickness also should be across the board maintained in all states and each state should not be permitted to change these norms. 4 (e) The words “Importer” should be added after manufacturer. 4 (h) The year of IS Standard should be changed from 2008 to 2010. 4. MOEF must add one more condition “Mandatory use of recycle content in the next 2 years to a minimum of 25% in Carry bags and non food Packaging as per international Guidelines and norms. Lower percentage of recycled content can be passed if the the quantity requirements doesn't allow so as per international guidelines. BIS should define standards for such materials“.The above clause will create a PULL effect in generating value for thin plastic waste which will inturn self-develop a sustainable ecosystem. 9 Responsibility of Producers should also include “& Importers”