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Sir,
The Bombay Chamber of Commerce and Industry (Bombay Chamber) thanks the Ministry for addressing some of our concerns and lowering reuse targets for products other than drinking water in packaging above 4.9 litres (or kg). This is a welcome and pragmatic step aligned with logistical constraints and sector-specific operational contexts.
We would, however, like to draw your attention to and clarify the reuse targets for rigid plastic packaging weighing greater than or equal to 0.9 litres (or kg) but less than 4.9 litres (or kg). These targets, more stringent than targets for packaging (other than drinking water) above 4.9 litres (or kg) pose significant logistical hurdles and are not attainable. The collection of such smaller packs (more than 0.9 litres (or kg) and less than 4.9 litres (or kg)), widely scattered across a geographically diverse country like India, is extremely challenging and operationally inefficient.
Exempt reuse of Small Rigid plastic containers > 0.9 litres (or kg) and < 4.9 litres (or kg)
While our member companies are committed to enhancing sustainable packaging practices and support the broader aim of promoting reuse, this category presents practical and immediate challenges. We wish to emphasize the significant operational, safety, and infrastructure-related barriers that render the assigned reuse targets for these containers unworkable under current conditions.
Industry constraints in reusing smaller rigid containers:
1. Modifying Packaging Will Lead to More Plastic Use: Containers in the 1 to 2 litre range are typically not engineered for multiple reuse cycles. Modifying their design to enhance durability would require additional plastic, which runs counter to the broader goals of reducing plastic use. Moreover, reinforcing the packaging would make usage and pouring more difficult for end users.
2. Risk of Product Contamination: In categories such as industrial chemicals and adhesives, products often leave behind hardened deposits after use. Current industrial cleaning methods are unable to fully remove these deposits, posing a risk of chemical reaction or contamination when refilled with new product.
3. Safety and Hygiene Risk: Containers below 4.9 litres or kg often have narrow necks, making them unsuitable for thorough cleaning through industrial systems. In many cases, manual cleaning would be required, raising serious concerns about worker safety and hygiene during the cleaning process.
4. Absence of Reverse Logistics Infrastructure: These smaller packs are consumed by millions of households and small contractors, sourced from a vast network of retail outlets across India, including remote areas. There is currently no viable system to collect, return, and sort used containers by brand at scale. Transporting used and soiled packs back to manufacturing units is neither cost-effective nor environmentally sound from a Total Product Lifecycle Assessment.
Our Recommendation:
Given the challenges outlined above, we respectfully recommend exempting plastic packaging sized between 0.9 litres (or kg) and less than 4.9 litres (or kg) from the current reuse targets.
As recommended in our earlier representation dated 22nd October 2024 (attached), we might want to consider a compliance mechanism that achieves an equivalent reduction in virgin plastic measured through a composite KPI (e.g. Absolute Reduction in Virgin Plastic). This may allow for a more thorough development of practical, safe, and effective reuse systems customised to individual industry needs.
As the oldest industry associations in India, representing a diverse membership base across multiple sectors, we fully support the government’s sustainability goals and initiatives aimed at fostering a circular economy. We request your consideration of our proposal and look forward to engaging in constructive discussions to advance our shared sustainability goals.
Yours sincerely,
Sandeep Khosla
Director General
