Estimates from the 2020-21 Central Pollution Control Board Annual Report indicate that India generates about 160,000 metric tonnes of solid waste each day, of which approximately 150,000 metric tonnes are collected daily. Of this total, roughly 10–12 percent of that — close to 19,000 tonnes daily — is plastic, and a large share of it is packaging: wrappers, sachets, pouches and multi-layered films with a shelf life measured in days, if not hours, before they become someone else’s problem.

The question of exactly whose problem is at the centre of a new study from the Centre for Science and Environment (CSE), Policy, Practice and Plastic: The Cost of Managing Plastic Waste in Indian Cities. Its finding, in essence, is that India’s flagship mechanism for making plastic producers pay for the waste they generate is quietly failing at arithmetic — and the gap is being filled by municipal budgets, informal waste workers, and the environment itself.

The Mechanism That Was Supposed to Fix This

On paper, India’s answer to plastic packaging waste is Extended Producer Responsibility (EPR), introduced under the Plastic Waste Management Rules. The logic is the “polluter pays principle” applied to packaging: producers, importers and brand owners (PIBOs, in the regulatory shorthand) are meant to fund the collection, transport, and recycling of the packaging they put into the market, rather than leaving that cost to city governments. PIBOs meet this obligation largely by purchasing EPR credits — certificates that, in theory, represent an equivalent amount of plastic waste being properly processed elsewhere in the system.

Under the rules, PIBOs are required to hit recycling targets of 50–70 percent by 2026–27. The CSE study’s contribution is to ask a more basic question underneath the compliance percentages: does the money actually flowing through this credit system come anywhere close to what it costs, in real terms, to collect and process the plastic in question?

Where the Numbers Stop Adding Up

CSE researchers examined actual waste-management costs across five Indian cities chosen to represent very different logistical realities: Indore, Pune, Goa, Dharamshala and Sri Vijaya Puram (Port Blair). The spread matters — a flat plains city with dense collection routes faces a completely different cost structure than a hill town like Dharamshala in Himachal Pradesh, where terrain alone drives up the price of moving waste.

That variation is exactly where the study finds the EPR framework breaking down. Flexible and multi-layered plastic packaging (MLP) — the sachets and laminated pouches that dominate everyday consumer packaging — is disproportionately expensive to collect and nearly impossible to recycle economically, since it typically combines several material layers that cannot be separated. In geographically difficult locations, that cost climbs sharply higher still. Yet the EPR credit rates paid out for this category remain largely flat regardless of where the waste is actually being managed, producing what researchers describe as a stark mismatch between real cost and real compensation — one that leaves municipalities absorbing the shortfall the rules were designed to place on producers.

Atin Biswas, who directs CSE’s municipal solid waste and circular economy programme, frames the core failure simply: inadequate cost recovery under EPR is pushing a financial burden back onto municipalities that the policy was explicitly built to lift off them.

A Regulatory Loophole With a Paper Trail

Part of the story here is a 2024 rule change that reclassified multi-layered plastic packaging into the broader “flexible plastic” category. On the surface, that sounds like a technical filing update. In practice, CSE researchers argue it removed much of the design pressure that once pushed PIBOs to reconsider how they package products in the first place — because once MLP is folded into a larger, less scrutinised category, the specific difficulty and cost of managing it becomes easier to average away in the compliance math. The result: the hardest-to-recycle packaging formats keep flowing into circulation at roughly the same volume, while the accounting environment around them gets softer, not stricter.

The gap this creates is not small change. Related CSE cost analysis has estimated that in a location like Dharamshala, managing a kilogram of difficult Category III multi-layered packaging can cost in the range of ₹9 per kilogram, against EPR credit rates sitting closer to ₹1–2.2 per kilogram for the same material — meaning the system is recovering a fraction of the actual cost, with the remainder absorbed by local governments, the informal waste workers who do the physical sorting and collection, taxpayers, and ultimately the environment when the shortfall shows up as waste that never gets properly processed at all.

The Fraud Problem Sitting Underneath the Cost Problem

Cost recovery isn’t the only crack in the system. Government pollution regulators, including the Central Pollution Control Board, have already surfaced evidence of fraudulent EPR certificates being issued — credits purchased by PIBOs to demonstrate compliance without the underlying waste-processing work necessarily happening as claimed. When a market is built on the promise that money paid in one place corresponds to waste genuinely processed in another, certificate fraud doesn’t just dent revenue — it breaks the entire premise the framework rests on. CSE’s recommendations here are pointed: shutting down fraudulent processors and certificate flows, requiring accurate reporting on the government’s compliance portal, and building the kind of baseline cost studies that this latest report itself represents.

What Fixing This Would Actually Require

The study’s prescriptions are less about tightening enforcement at the margins and more about rebuilding the pricing logic itself. Two recommendations stand out. The first is weighted EPR rates — credit prices that actually reflect the real, differentiated cost of managing different packaging formats, rather than a flattened average that quietly subsidises the hardest-to-recycle materials at the expense of easier ones. The second is localised obligations, recognising that the true cost of managing a kilogram of MLP waste in a hill town is not the same as managing it in a flat urban grid, and that a national average rate will always underpay the harder cases.

Both point toward the same underlying argument: for “polluter pays” to function as more than a slogan, the price signal has to be honest about where and how expensive plastic actually is to clean up.

Why the Packaging Question Is Really a Circular-Economy Question

It is tempting to read this as a narrow waste-management story — a technical dispute over credit pricing that matters mostly to municipal budget officers. It is worth resisting that framing. India’s circular-economy ambitions, and its packaged-goods economy’s own sustainability claims, rest on EPR functioning as advertised. Every consumer brand that markets itself around recyclability or “producer responsibility” commitments is, in effect, leaning on a mechanism that this study suggests is currently under-pricing its own promises.

The deeper issue is one of who absorbs risk in a growing consumer economy. As India’s packaged-goods market expands — more products, more single-use formats, more delivery-driven consumption — the volume of flexible and multi-layered packaging is not going to shrink on its own. Without a pricing mechanism that reflects the real cost of managing that packaging at end of life, the gap CSE has now quantified will not stay static either. It will scale with the market that created it, and the municipalities and waste workers currently absorbing the shortfall have no comparable capacity to scale in response.

“Who pays for plastic?” turns out to have a fairly clear answer once you follow the money: everyone except, for now, the parties the rules were written to hold accountable.

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