Environmental Science and Policy 139 (2023) 219–227

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Environmental Science and Policy

journal homepage: www.elsevier.com/locate/envsci

Plastic bans in India – Addressing the socio-economic and

environmental complexities
Emmy Nøklebye a, *, Hans Nicolai Adam a, Avanti Roy-Basu b, Girija K. Bharat b,
Eirik Hovland Steindal a, c
a
Norwegian Institute for Water Research (NIVA), Økernveien 94, 0579 Oslo, Norway
b
Mu Gamma Consultants, Unit 29, 18th Floor, One Horizon Centre, Golf Course Road, Sector 43, Gurugram 122003, Haryana, India
c
Norwegian University of Life Sciences, Department of International Environment and Development Studies (NORAGRIC), Ås, Norway

A R T I C L E I N F O A B S T R A C T

Keywords: As one of the flagship amendments to the Plastic Waste Management (PWM) Rules, 2021, the pan-Indian ban on
Single-use plastic products a group of single-use plastic products (SUPPs) introduced in mid-2022 provided a departure point towards more
plastic pollution progressive plastic waste legislation. The amendments have mostly been welcomed, yet challenges persist to
governance
facilitate its implementation, assess potential environmental impacts of alternative materials, and socio-
plastic waste management
economic concerns raised by various stakeholders. Considering the recent amendments to the PWM Rules, we
India
critically engage with and highlight key considerations and prevailing challenges with regards to phasing out
SUPPs. We argue that to shape sustainable solutions that reduce plastic pollution, uncertainties related to the
environmental fate of SUPP alternatives need to be better understood, whilst recognising and accounting for
broader socio-economic impacts of SUPP bans, including industry concerns, impacts on socio-economically
disadvantaged communities, and the informal recycling sector. A stronger knowledge base on these aspects
can mitigate negative social and environmental externalities, including potentially harmful consequences of
ambitious plastic pollution reduction measures.

1. Introduction not an isolated issue of developing economies with nascent waste

management infrastructure. Wealthier countries are historically and
The global and transboundary challenge of plastic pollution poses presently considered significant contributors to plastic consumption and
major threats to the environment, human health, and sustainable pollution (Law et al., 2020; Ocean Conservancy, 2022). Waste trade
development (Lau et al., 2020; Kumar et al., 2021; UNEP, 2021a). The from higher to lower income economies is placing further strains on
impacts from plastic pollution span the entire life cycle of plastics (La­ fragile waste management infrastructure in poorer countries, raising
vers et al., 2022), whilst its repercussions on livelihoods, human questions of environmental justice and post-colonial relationships
well-being, and ecosystems are experienced and perceived differently (Liboiron, 2021; Fuller et al., 2022).
across diverse socio-economic and geographical contexts (Orellana, Considering these complexities, tackling plastic pollution demands
2021; Owens and Conlon, 2021). Governing plastic pollution has only both international and sub-national approaches to implement effective
become more complex, with growing production and consumption, in­ solutions (Hardesty et al., 2021). Policy interventions have oftentimes
ternational waste trade, and diversified pollution sources (Dauvergne, targeted fast moving consumer goods and littering through
2018). consumer-oriented reduction measures (Pathak, 2022), rather than
Effective waste management is a key tool to reduce plastic pollution pollution sources across the lifecycle of plastic products (from reducing
from land-based sources in rapidly growing and urbanizing areas (Kaza production to end-of-life solutions). This narrative is shifting towards
et al., 2018). Developing economies in Asia are often highlighted as the emphasizing more holistic life-cycle approaches, with the adoption of
largest sources of plastic pollution to the marine environment (Jambeck circular economy and extended producer responsibility (EPR) concepts
et al., 2015; Lebreton et al., 2017). At the same time, plastic pollution is (UNEP, 2022a). Within this broader context, there is a growing emphasis

* Corresponding author.
E-mail address: [email protected] (E. Nøklebye).

https://doi.org/10.1016/j.envsci.2022.11.005
Received 24 May 2022; Received in revised form 3 November 2022; Accepted 10 November 2022
Available online 19 November 2022
1462-9011/© 2022 The Author(s). Published by Elsevier Ltd. This is an open access article under the CC BY license (http://creativecommons.org/licenses/by/4.0/).
E. Nøklebye et al. Environmental Science and Policy 139 (2023) 219–227

on enabling a just transition (Kantai et al., 2022; Adam et al., 2022). 2. Methodology
Such a transition prioritises questions of social justice and inclusion
hand in hand with environmental sustainability through the promotion The article draws on qualitative data gathered between 2020 and
of broad stakeholder inclusion in decision-making processes, as well as 2022. Due to the restrictions imposed by the COVID-19 pandemic, this
protecting human and labour rights (ILO, 2015). material is largely sourced from digital sources and interviews. In our
The relatively recent advent of plastic pollution as a priority area in analysis, we have used both primary and secondary data to capture the
international development has been followed by a surge in regional and most pertinent debates and prevailing challenges related to phasing out
national policy initiatives and regulatory measures, commonly targeting SUPP in India. Considering the recent amendments to India’s Plastic
the manufacture and use of problematic types of plastic waste, including Waste Management (PWM) Rules (2021), we analyse regulatory de­
Single Use Plastic Products (SUPP)1 (UNEP, 2018; EC, 2021; Diana et al., velopments with respect to phasing out SUPP since the PWM Rules from
2022). Whilst some studies have drawn attention to the environmental 2016. The analysis was supplemented with recent academic and grey
implications of SUPP bans (e.g., Herberz et al., 2020; Gomez et al., literature on environmental policy tools and alternatives to SUPPs,
2022), others have highlighted social and economic impacts of banning gathering data from Web of Science and Google Scholar using a com­
single-use plastic (SUP) bags (e.g., El Mekaoui et al., 2021) and straws bination of key search terms such as ‘Plastic ban’, ‘Single-use plastic’,
(e.g., Jenks and Obringer, 2020), as well as constraints faced by micro, ‘policy’, ‘regulation’ and ‘India’. We attended over 20 webinars and
small, and medium enterprises (MSMEs) and informal workers (e.g., online conferences between April 2020 and December 2021, focusing on
Nagarajan, 2022). There is, however, a limited appreciation of the plastic pollution, extended producer responsibility, PWM Rules and
interlinked environmental, social, and economic implications and proposed solutions relevant to the Indian context (Appendix 1). Findings
consideration with regards to banning SUPPs. There is a need to consider were substantiated by conducting six key informant interviews, with a
bans in the context of broader sustainability dimensions to avoid selection of key stakeholders, including municipal government repre­
potentially harmful consequences amidst rapidly evolving international sentatives, research institutions, private sector companies, and informal
and national policy, where bans are often promoted as a key tool to and private sector recycling industries (Appendix 2). The interviews
reduce plastic pollution (Godfrey, 2019). were conducted digitally through a semi-structured interview guide. By
India represents an interesting case to investigate these inter­ triangulating data using a combination of qualitative research methods,
linkages, given the country’s rapid economic growth, urbanization, and we draw on experiences from phasing out SUPPs in India to complement
socio-political diversities, in addition to its important role in interna­ broader national and international policy discussions surrounding
tional negotiations. These trends and diversities provide a backdrop to SUPPs, plastic pollution, and marine litter.
explore priorities, stakeholder interests and socio-economic impacts of
commonly promoted pollution reduction strategies, taking into consid­ 3. Key considerations of SUPP bans
eration the recent pan-Indian ban on certain SUPPs.
In the Indian policy context, plastic pollution has largely been 3.1. Coupling bans with other policy tools
framed as a littering issue, particularly focusing on promoting ‘cleanli­
ness’ and ‘aesthetics’ over larger concerns related to plastic waste A multi-faceted combination of legislative and non-legislative in­
management, such as improving source segregation and waste collection terventions from various stakeholders is needed to address the use and
coverage and reducing toxic releases of chemicals, burning of waste, and management of SUPPs (Schnurr et al., 2018). Bans can achieve a
fossil fuel dependence (Pathak and Nicher, 2022). Although India’s reduction in emissions and pollution levels in previously unregulated
target to combat plastic pollution has been enunciated through the markets, but the success of these largely depends on the degree of
Government of India’s (GOI’s) pledge to eliminate all SUP in the country informality, availability of appropriate alternatives, public knowledge
by 2022, the implementation of related regulatory measures continues and awareness, and monitoring and enforcement mechanisms (Xanthos
to face challenges. These link to health and environmental concerns of and Walker, 2017). Motivation, implementation and enforcement can
SUPP alternatives, industry interests, and social equity considerations. also be linked to the countries’ broader development goals and interests
This perspective article aims to critically examine and cast light on in being perceived as environmental leaders and regional economic hubs
key considerations for enhancing the sustainability of a commonly driving implementation (e.g., Kenya and Rwanda), in contrast to
applied policy tool to combat plastic pollution, particularly, the widely countries with interests in developing oil industries (e.g., Uganda)
debated and publicized ban on SUPPs in India. We start by situating the (Behuria, 2018).
use of bans as a policy tool within broader interventions to reduce plastic Bans are part of top-down, command and control policy tools that
pollution, before examining how SUPP bans have been applied to have been widely used to govern environmental issues (e.g., the
manage plastic pollution in India. The following section reviews worldwide ban on ozone depleting chemicals in 1987 and the ban of
emerging debates around alternatives to SUPPs and argues that the several toxic industrial chemicals and pesticides for agricultural use
contextual applicability of biodegradable and compostable plastic in under the Stockholm Convention since 2004). More recently, govern­
India must be better understood before promoting these as sustainable ments across the world have placed complete and partial bans on certain
alternatives. Lastly, we explore social and economic impacts of SUPP SUPPs that commonly target import and manufacturing of SUP bags
bans with respect to economic vulnerabilities amongst marginalised (UNEP, 2021c). However, the effects of SUPP bans in practice are
societal groups. We add to existing debates and narratives by consid­ oftentimes hampered by insufficient focus on regulating plastic through
ering the interlinked environmental, social, and economic implications its lifecycle (e.g., China), partial bans being favoured over blanket bans
of SUPP bans, and argue that these must be better understood in tandem (e.g., Madagascar), multiple exemptions (e.g., Cambodia), and lack of
to avoid unintended consequences and build increasingly sustainable restrictions on plastic bag production, and incentives for alternative
pollution reduction strategies. materials (UNEP, 2018). A growing number of countries and regions
across the world (e.g., India and the European Union) have also banned
other commonly used SUPPs, including plastic cups, plates, and cutlery
(EC, 2021). In countries without national legislation on SUPPs, many
states, cities and municipalities have independently implemented local
bans on certain plastic products (Karasik et al., 2020).
1
Common types of SUPPs ending up as unmanaged waste and marine Top-down legislative interventions that ban plastic bags and other
pollution include cigarette butts, food wrappers, beverage bottles, bottle caps, SUPPs can effectively trigger a so-called ‘green policy-industry feedback
bags, straws, take-away containers, cutlery, and lids (Hardesty et al., 2022). spiral’, where an initial policy stimulates adaptive industry responses,

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catalysing a growing coalition for regulation which feeds back into commitment to eliminate all SUPPs by 2022 and reiterated its
policy making by increasing the political viability of more stringent commitment internationally by calling for a phase-out of SUPPs by 2025
regulation (Kelsey, 2014). Drawing on this theory, regulations on SUPPs at UNEA-4 in 2019. India’s Ministry of Environment, Forest and Climate
can trigger producers to invest in waste handling infrastructure or the Change (MoEFCC, 2021) subsequently notified two consecutive
design of alternative products to gain a competitive advantage as ben­ amendments to PWM Rules on August 12 (GOI, 2021a) and on
eficiaries of the policy at hand, whilst non-adaptive industries will bear September 22 (GOI, 2021b). The amendment introduced significant
the economic costs of stricter regulation. In the Indian context, it has changes with a stepwise approach (see Fig. 1) including increases in
been argued that larger corporations with a great degree of public vis­ single-use and non-woven plastic carry bags’ thickness and bans on 17
ibility are more likely to engage in voluntary plastic control initiatives as problematic SUPP categories2 from July 1, 2022. SUPPs made from
part of their corporate social responsibility (CSR) to prevent reputa­ compostable plastics are exempt from the bans, but manufacturers are
tional damage, comparatively to smaller businesses which often have required to register with the Central Pollution Control Board (CPCB)3
limited financial capabilities to adapt to legislative changes (Pathak, before manufacturing or selling compostable products. The amendment
2021). also pre-emptively proposes that any notification prohibiting the
Bans can also effectively be coupled with economic instruments manufacture, import, stocking, distribution, sale and use of carry bags,
incentivizing behavioural change and associated information measures plastic sheets, MLP packaging, and SUP commodities issued post the
that raise awareness. Economic instruments may include taxes on 2021 amendments will face a 10-year delay to enter into force.
certain problematic SUPPs or multi-layered plastics (MLPs), emissions Following this, the GOI issued a draft notification on January 18, 2022,
trading schemes (as recently introduced in the context of tradable cer­ defining biodegradable plastics4 and introducing a new protocol for
tificates under the Indian EPR Rules, 2022), subsidies for switching to compostable and biodegradable materials (GOI, 2022a).
more sustainable alternatives, and tax reductions or levies for products In the first PWM Amendment Rules of 2021 (GOI, 2021a), SUPs were
containing recycled materials. Raising public awareness through envi­ defined as “plastic commodities intended to be used once for the same
ronmental education allows individuals to make informed decisions and purpose before being thrown away or recycled”. This aligns with the
may encourage environmentally sustainable behaviour, norms, and at­ definition of the UNEP, whilst the European Union adds that the SUPP
titudes (Latinopoulos et al., 2018). In this instance, information mea­ category also includes items which are used for a short period of time
sures may boost awareness towards enhanced public acceptance and before being thrown away (UNEP, 2018; EU, 2019). National SUPP bans
compliance with the SUPP bans. On the contrary, when it comes to lower were initiated with the minimum requirements for SUP bag thickness,
income segments of society, the number of consumer choices may be set to 50 µm under the PWM rules of 2016, and further increased to 75
limited. Moreover, the complex trade-offs associated with consumer and 120 µm under the 2021 amendments, with all below being banned
products, life-cycle assessments, and labelling and certification schemes from December 31, 2022. States and Union Territories (UTs) have also
are often not significantly mature to facilitate behavioural change. imposed partial bans and legal restrictions on certain plastic packaging,
Similarly, there is a risk that a disproportionate attention towards for example, in areas surrounding religious, historic or nature sites.
awareness raising shifts the responsibility of an essential service – waste However, bans and restrictions on SUPPs often lack uniformity and vary
management – from the state to individuals, who may have little re­ widely across the country, as illustrated in Table 1.
sponsibility for causing plastic pollution in the first place. Table 1 is based on information submitted by each state to CPCB for their
Top-down market-based interventions may also be complemented most recently available Annual Report of the year 2018–19 (CPCB, 2019).
with bottom-up non-legislative interventions to effectively reduce The states are listed alphabetically, and it must be noted that the situation in
plastic pollution, including actions from citizens, non-government ac­ each state may have developed since this information was compiled by the
tors, and private sector (Schnurr et al., 2018). For instance, local level CPCB.
initiatives such as the ‘world’s largest beach clean-up project’, initiated The GOI has since taken several measures for effective enforcement
on Versova beach in Mumbai, India (2015), has channelled considerable of the SUPP ban. For instance, enforcement teams have been formed to
environmental stewardship locally, and attention globally. At the same check illegal manufacture, import, stocking, distribution, sale, and use
time, such end-of-pipe solutions have received criticism for not of banned SUPPs. States and Union Territories have set up control rooms
addressing the root causes of littering and pollution, unjustly placing for better enforcement and border check points to stop inter-state
responsibility for waste and pollution on poorer sections of the society, movement of banned SUPP. In addition, non-legislative interventions
and failing to close the gap on plastic production and leakages (Owens to raise awareness and wider public engagement to curb SUPP have been
and Conlon, 2021). It may be noted that the question of what a ‘clean pursued.
environment’ is, and who shapes this collective imagination, is also a
question of power and class. The drive to clean a public beach like 3.3. Tracing the background for bans on certain SUPPs
Versova for example, holds symbolic value of a clean environment used
for a specific purpose (e.g., recreation and leisure), and tends to receive The bans on certain SUPP were determined with the help of an expert
more attention and resources in relation to improving waste collection committee, constituted by the Department of Chemicals and
infrastructure and processes in Mumbai’s crowded, and poorer central
areas.
2
Including ear buds with plastic sticks, plastic sticks for balloons, plastic
flags, candy sticks, ice-cream sticks, polystyrene [Thermocol] for decoration,
3.2. India making a firm move on single use plastic products
plates, cups, glasses, cutlery such as forks, spoons, knives, straw, trays, wrap­
ping or packing films around sweet boxes, invitation cards, cigarette packets,
On World Environment Day in 2018, India announced its plastic or PVC banners less than 100 µm, and stirrers, plastic carry bags less
than 75 µm thickness, and non-woven plastic with less than 60 GSM (grams per
square metre) (GOI, 2021a, 5).
3
CPCB is the prescribed authority for pollution control in India, responsible
for the enforcement of regulations, providing technical guidance and con­
ducting environmental assessments.
4
Biodegradable plastic is defined as plastic ‘which undergoes complete
degradation by biological processes under ambient environment (terrestrial or
in water) conditions, in specified time periods, without leading any micro
plastics, or visible, distinguishable, or toxic residue […]’ (GOI, 2022a).

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Minimum Minimum
30th thickness for 1st Ban 31st thickness for
September carry bags July on certain December carry bags
2021 made from 2022 2022 made from
single-use plastic SUPPs1 single-use plastic
>75 microns >120 microns

Fig. 1. Stepwise approach implemented by the GOI to restrict or phase out selected SUPPs by 2022 (GOI, 2021a).

of hazardous air and water pollution (WHO 2022). Medical waste is

Table 1
however regulated through a different set of revised guidelines,5 illus­
Status on implementation of bans on SUPPs and plastic carry bags across Indian
trating a rapidly evolving and complimentary policy landscape.
States and Union Territories.
The ban on select SUPPs can arguably be traced to the complex
Ban-status on SUPPs and carry bags States and Union Territories process of policy making (Lindblom, 2018), in which industry actors
Ban on certain plastic products Assam; Lakshadweep; Maharashtra; within the plastic sector have varying influence and interests that usu­
including SUPP packaging and Manipur; Puducherry; Tamil Nadu; ally promote consumption and business interests (Pathak, 2021). The
carry bags irrespective of Uttarakhand; Uttar Pradesh.
push for regulating SUPPs in India can, however, also be traced to
thickness
Partial ban on certain plastic Delhi; Odisha. judicial activism. Nagarajan (2022) highlights 28 court cases across
products different benches of the High Courts of India since 2000, where envi­
including SUPP packaging and ronmentalists and civil society groups sought partial or complete bans
carry bags on certain SUPPs. However, these petitions focused primarily on envi­
Complete Ban on Plastic Carry Andaman & Nicobar Islands; Bihar;
Bags Chandigarh; Chhattisgarh; Daman Diu &
ronmental impacts with little attention to socio-economic consider­
irrespective of thickness Dadra Nagar Haveli; Haryana; Himachal ations, such as lost revenue and employment amongst MSMEs and the
Pradesh; Jharkhand; Karnataka; Madhya informal sector. The prioritization of certain forms of ‘cleanliness’, may
Pradesh; Nagaland; Punjab; Rajasthan; in fact even adversely affect pollution levels (i.e., when informal set­
Sikkim; Tripura.
tlements are displaced in favour of high-consuming and waste gener­
Ban on carry bags Goa; Jammu & Kashmir; Meghalaya;
> 50-micron thickness Telangana; West Bengal. ating infrastructures) whilst excluding marginalised social groups
Partial ban on plastic carry bags Andhra Pradesh; Arunachal Pradesh; Kerala; (Baviskar, 2018). Linking ecology and justice by ensuring broad and
Mizoram; Gujarat informed stakeholder representation and participation are consequently
indispensable aspects in discussions towards addressing plastic
pollution.
Petrochemicals on ‘Single Use Plastic’, which assessed SUPPs based on
criteria for utility and environmental impacts (Table 2) (MoCF, 2019).
The SUPPs listed to be phased out by 2022 were all assessed as ‘prob­ 3.4. Environmental uncertainties related to compostable and
lematic’ based on scores that consider their relative utility in terms of biodegradable SUPP alternatives
hygiene, product safety, essentiality, and social and economic impact.
On the other end of the score line, SUPPs were assessed high on their Biodegradable materials are increasingly promoted as a sustainable
environmental impacts in terms of recyclability, possibility of end-of-life alternative to SUPPs. Although the availability of biodegradable alter­
solutions, environmental impact of alternate materials, and littering natives is growing, these are often expensive, and their environmental
propensity. In other words, the targeted SUPPs were considered impacts are uncertain (Bolton, 2019). Part of the success of plastic bans
commonly littered, difficult or expensive to recycle with existing tech­ relies on the access to viable alternatives (Xanthos and Walker, 2017),
nology, non-essential to ensure human health, and not causing detri­ however, this has received insufficient attention (UN Environment,
mental impacts on livelihoods and businesses. At the same time, items 2018; Fetner and Miller, 2021). The most recent PWM Amendment
such as tea bags and cigarette filters were considered low on the utility Rules incentivize the use of compostable and biodegradable alternatives
scale and high on the environmental impact scale, yet these items have through an exemption from the bans for SUP commodities made from
not or only partly been included in the ban, despite being commonly compostable plastics (GOI, 2021b). The most pressing concern here re­
littered and non-biodegradable (Chevalier et al., 2018; Hernandez et al., lates to what degree alternative materials are more sustainable than
2019). SUPPs when applying a life-cycle perspective.
In contrast to the above examples, medical SUPPs, such as blood bags Understanding the requirements and implications of categorizing
and plastic syringes were considered high on utility (hygiene, safety, compostable and biodegradable plastic materials vary significantly,
essentiality, and social impact) but low on environmental impact, and both nationally and internationally, and is part of an evolving debate,
are not considered problematic. Following the outbreak of the COVID- continuously challenged with new science, innovations, new market
19 pandemic, medical SUPPs have added pressures on biomedical developments, and business interests. Internationally, compostable
waste handling, with medical SUPP waste mainly being incinerated in plastics typically refer to any plastic that can degrade under composting
facilities lacking adequate emission controls, causing less visible forms conditions, often through processes such as hydrolysis, thermal degra­
dation, and photodegradation (EC, 2020). However, this does not mean
that compostable plastic products will break down completely (i.e., with
Table 2 no residues <2 mm), degrade in all composting environments (e.g.,
Criteria for phasing out SUPPs in India (MoCF, 2019).
home compost), or that this process will be without undesirable impacts
SUPPs scoring low on the utility SUPPs scoring high on environmental (i.e., (micro)plastic particles and toxic additive releases). Moreover, it
index impact

Not important for hygiene Low recyclability

Few problems with product safety Few end-of-life solutions 5
The Guidelines for Handling, Treatment, and Disposal of Waste Generated
Low essentiality of product High environmental impacts of alternatives
during Treatment/Diagnosis/ Quarantine of COVID-19 Patients – Rev. 5.
Few social and economic impacts Likelihood of items being littered
(CPCB, 2022).

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must be recognised that biodegradable plastic waste may be transported production chain. For instance, many MSMEs and plastic industry rep­
from an environment certified for biodegradability (e.g., soils) to resentatives have opposed the SUPP bans due to their potential adverse
another environment where it is not certified for biodegradability (e.g., impacts on economic revenue and employment (Appendix 2, Informant
water bodies), and may as such, not degrade. Thus, the potential rate of 1), on similar grounds as industry associations argued against the
compostability and biodegradation in Indian soil contexts should be implementation of plastic bag bans in Kenya (Njeru, 2006). Other con­
considered when looking into SUPP alternatives. Moreover, mis­ cerns highlighted by industry stakeholders relates to the cost of alter­
perceptions around compostable and biodegradable materials is prob­ natives to SUPPs, lack of waste segregation systems for biodegradable
lematic considering the tendency to believe that these represent a ‘green and compostable waste, and limited uniform definition and under­
choice’, whilst it may in fact encourage littering. standing of these materials (Appendix 2, Informant 4 and 5). One
Certain alternative materials may have a potentially higher envi­ informant highlighted that there is a lack of willingness to pay for
ronmental footprint than SUPPs (Spierling et al., 2018). One of the most alternative materials amongst brand-owners and consumers, and that
pertinent examples relates to the popularity of polypropylene the end-of-life solutions for these materials are limited (Appendix 2,
non-woven bags (PNB) as an affordable replacement to SUP carry bags Informant 4). Biodegradable materials may also contaminate the recy­
after the thickness requirements set by of the PWM Rules, 2016. PNB cling waste stream and perceptions of compostable materials being
bags are usually made of non-biodegradable plastic fabric, which is environmentally friendly causes confusion and new environmental
difficult to recycle below a certain thickness. The PWM Amendment problems (Appendix 2, Informant 4 and 5).
Rules, 2021, required that PNB “shall be no less than 60 Gram Per Bans on SUPPs may aggravate existing vulnerabilities amongst
Square Metre (GMT) with effect from 30th September [in 2021]” (GOI, workers directly or indirectly engaged in the plastic sector and the
2021a p. 5). However, PNB (as well as other SUPP alternatives) may be (informal and formal) waste management system, and may limit choices
equally harmful to the environment if littered or mismanaged, and for price-sensitive consumers. For example, it is anticipated that bans on
products’ environmental footprint will be determined by potential single-use sachet packaging may restrict access to low-value consumer
negative impacts from production to their end-of-life management. A goods that are commonly used by poorer segments of society, such as
study from Singapore showed that a PNB must be reused 50 times to be sachet packaged personal care and food items, if alternative packaging
more environmentally friendly than the typical SUP bag (made from materials are more costly (Prahalad 2010). However, it should be noted
HDPE plastic), but both alternatives had a lower environmental impact that critical voices have also pointed out that it is in fact middle-class
than kraft paper and cotton woven bags, in relation to global warming segments that prefer and consume SUPPs (Singh et al., 2009) with
potential, toxicity, acidification and eutrophication potential (Ahmed some poorer segments employing traditional and cheaper alternatives
et al., 2021). In the Indian context, studies have pointed to kulhad (Kay and Lewenstein, 2013). Thereby, the narrative of regulatory in­
(earthen) cups baked in kilns and virgin cotton bags having a higher terventions restricting access to essential items is not straight forward.
environmental footprint than the SUPPs they are replacing, so leaf Sachets made from flexible and multi-layered materials are rarely
cutlery and jute or upcycled cloth bags has been promoted as potentially recycled due to being time-consuming to collect and costly to recycle
more viable alternatives (Sambyal, 2019). with available technologies, due to which these items are classified as
Despite the increasing availability of SUPP alternatives, it must be problematic. EPR schemes developed with the active participation of
recognised that biodegradable and other alternatives often require informal recycling workers can increase the collection of multi-layered
separate waste streams, which place further pressure on waste man­ plastics whilst supporting livelihoods in the informal sector, as effec­
agement systems in areas where household segregation, collection sys­ tively trialled under the SWaCH model in Pune.6 Scaling up such ini­
tems, and awareness is at nascent stages. With limited awareness, poorly tiatives whilst assuring the accessibility to environmentally sound and
understood labelling systems, limitations in source segregation, and no accessible SUPP alternatives can contribute to ensure that standards of
established collection and recycling streams for biodegradable alterna­ living does not collide with environmentally focused PWM goals.
tives, existing recycling streams may become contaminated. Awareness
raising initiatives amongst consumers, industries, and producers may
partly contribute to reduce this risk and broader environmental conse­ 3.6. Anticipatory changes in the market for recyclables and the informal
quences on the road towards developing guidelines, regulations, and sector
contextually feasible alternatives to SUPPs. However, as mentioned,
disproportionate emphasis on such initiatives forms an opportunity for Concerns have been raised that a complete ban on SUPPs may drive
the state to evade its responsibility by stressing instead the responsibility informal recycling practices underground, making it harder to deliver
of individuals and pointing to the performative nature of the market to technology improvements and health services to the communities
address a waste management issue (Pathak, 2022). involved in plastic waste recycling (Bailey, in IKHAPP, 2021). The
informal recycling sector (IRS)7 significantly contributes to collect and
3.5. Industry opposition and inequitably distributed impacts of SUPP bans recycle municipal waste across India (Singh, 2021), decreasing the
amount of waste sent to landfills by up to 70 %, according to recent
Beyond unforeseen environmental impacts of alternatives, blanket mapping technology (Hande, 2019). In line with arguments by indus­
bans on plastic products may have inadvertent consequences particu­ trial actors, advocates for workers in the IRS have raised concerns that a
larly for people living on the margins of informality. SUPP bans have ban on SUPPs can significantly impact waste pickers and collector’s
also faced backlash from industry players on account of economic con­
cerns. Recognising and counterbalancing these impacts is important to
6
increase public acceptance and effective implementation of bans and SWaCH Pune is India’s first wholly owned waste picker cooperative, with a
other reduction policies. Moreover, it is key to facilitate a just transition current membership of 3800 wastpe pickers. Since 2008, SWaCH has a mem­
towards ending plastic pollution, which meets broader sustainable orandum of understanding with the Pune Municipal Corporation to provide
door to door waste collection in the city on a user fee recovery basis.
development goals of decent work, social inclusion, and poverty eradi­ 7
Broad term encompassing informal waste collection and recycling activities
cation (ILO, 2015). In a populous and geographically vast country such
that are not part of municipal services or a registered private entity. Data on the
as India, with significant regional wealth disparities and rural-urban scale and recycling capacity of the IRS in India is scarce, but it is generally
gaps, centralised plastic pollution policies will face different imple­ believed that the sector consist of 2–4 million people, often referring to one
mentation challenges and unequally distributed impacts. preliminary yet comprehensive study (Annepu 2012, in Oates et al., 2018).
Since the pan-Indian ban on SUPPs was first announced in 2018, it Estimates of informal collection vary from 20% to 60% of the total recyclable
has provoked dissatisfaction amongst industry players across the plastic waste (Chikarmane, 2014; Chandran et al., 2018).

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income (Chintan, 2021). There is some tension centring around this, Since SUPPs that are produced from alternative materials are exempt
because most of the informally collected waste is of high recycling value from the bans, caution is also needed whilst assessing the potential
(such as PET bottles), and most of the banned SUPPs are low-grade and environmental impacts of mismanaged alternatives to SUPPs in the In­
non-recyclable (which typically would go to landfills or be left unman­ dian context. In line with the ‘green policy-industry feedback spiral’, it
aged in the environment). Nevertheless, regulatory changes and market could be anticipated that such regulatory actions, in spite of their de­
uncertainties leading up to the SUPP bans pose risks to recycling busi­ ficiencies, should be seen as a step that may trigger industry adaptation
nesses and IRS workers, such as seen in the instance of the introduction and progress (Kelsey et al., 2014).
of a goods and services tax on recycled plastics, which negatively Our article has also underlined that complete bans on plastic prod­
influenced IRS workers’ income (Karelia, 2017; Narayanan et al., 2019). ucts may have adverse social and economic impacts, if these lack
Whilst larger businesses may smoothen temporary drops in prices and sensitivity for local realities, including MSMEs, marginalised commu­
income, adapting to sudden market fluctuations is more difficult for nities, and the IRS. Understanding and counterbalancing these impacts
smaller businesses and IRS workers, particularly informal waste pickers whilst promoting broad stakeholder engagement is key to increase the
and collectors at the lowest levels of the IRS, whose income typically public acceptance and large-scale implementation of bans and broader
consist of meagre margins and daily wages (Singh, 2020; WIEGO, 2021). reduction policies.
Added to these uncertainties, COVID-19 induced impacts (health, mar­ Whilst we focus on specific elements and measures of policy in this
ket fluctuations, and lockdowns) significantly impacted IRS activities piece - instrumental in nature - we also acknowledge the limitations and
and reduced the availability of high-quality waste (INOPOL, 2020). possible risks within the current, mainstream discourse surrounding
Despite its significant societal contribution, the IRS is often excluded plastic pollution. There are larger political economy questions at play
in the development of strategies to reduce plastic pollution, leading to an with respect to how to govern the environmental challenges of our time
exacerbation of existing socio-economic vulnerabilities, including inter- (e.g., green growth vs de-growth; market-based vs state) and what shape
generational poverty, limited access to social security schemes, health a ‘green’ transformation takes. Bans can also be viewed critically as a
and education, the absence of labour protection, and hazardous and symbolic and highly visible action by the state to address an issue of
exploitative working conditions (Gill, 2010; ESCAP, 2019). Unregulated environmental concern through ‘techno-bureacratic’ means (e.g., see
recycling practices are often also associated with limited access to Ferguson, 1994). In doing so, root causes that are more systemic and
environmentally sound recycling technologies, causing further pressures relate to larger questions of production and consumption, wealth dis­
on environments and health (Chakraborty et al., 2022; Powrie et al., tribution, infrastructure and access to it, as well as environmental justice
2021). Including the IRS in strategies to reduce plastic pollution can are potentially side-stepped or intentionally deflected from.
contribute to reduce unmanaged waste and pollution and improve Bans are thus only one potential instrument in a diverse toolbox to
end-of-life PWM solutions, whilst promoting broader environmental, tackle plastic pollution. Alternative legal, economic and information
economic, and social sustainable development goals (Singh, 2020; Barde measures could effectively complement regulatory control measures,
2020). Broadening the scope of solutions to reduce plastic pollution, whilst prioritizing the interests of socially vulnerable sections of society.
from SUPP bans towards officially recognising and including the IRS and The suitability of measures will differ regionally and locally based on
its role in PWM, calls for IRS stakeholder representation when devel­ resource availability and existing institutional practices. A combination
oping future PWM strategies, particularly in the context of the devel­ of contextually appropriate measures that considers the aforementioned
opment and implementation of EPR schemes, expanding waste environmental, social, and economic aspects is necessary when
collection coverage, and privatising and decentralising waste manage­ addressing plastic pollution in a more just and effective manner. The
ment systems. experience in India with respect to addressing plastic pollution may thus
also hold important lessons for countries pursuing similar strategies,
4. Conclusion considerations which are important in deliberations of a forthcoming
global agreement to prevent plastic pollution (UNEP, 2022b).
Bans as a policy tool can be considered a resolute and decisive way to
limit inputs of plastic pollution into the environment. They have some
degree of shock value and stringency, and have also generated a Declaration of Competing Interest
considerable degree of public awareness. At the same time, they only
address a few aspects of a complex challenge and may not always have The authors declare that they have no known competing financial
the desired outcome on which they are premised. interests or personal relationships that could have appeared to influence
In a rapidly changing world, we also need to be prepared to adapt to the work reported in this paper.
emerging research and future challenges. It is therefore problematic that
the 2021 Amendment Rules specify that any future ban on SUPPs will Data availability
face a 10-year delay to enter into force (GOI, 2021a). Although pre­
dictability is key for industry adaptation, a decade delay on a ban to Data will be made available on request.
combat potentially urgent issues are likely to have severe long-term
implications. Acknowledgements
Current debates surrounding biodegradable and compostable plas­
tics emphasize that uncertainties persist regarding their environmental This article is an outcome of research carried out in the ’India Nor­
impacts, and that these differ across geographical contexts. It is key to way cooperation project on capacity building for reducing plastic and
consider the potential rate of biodegradation and compostability in In­ chemical pollution in India’ (INOPOL), funded by the Royal Norwegian
dian climatic conditions and soil types. Adding to these uncertainties are Embassy in New Delhi and the Norwegian Development Assistance
challenges that are associated with biodegradable plastic which may Programme to Combat Marine Litter and Microplastics. The authors are
create additional waste streams and contaminate existing recycling thankful to all INOPOL project partners for cooperation and knowledge-
value chains in places where waste segregation is still in nascent stages. sharing on pollution related issues and want to offer particular gratitude
Awareness raising and education can contribute to public awareness to Dr. Rachel Hurley ( NIVA), Dr. Nandini Kumar (NIVA) and Dr. Smita
about contextually and environmentally sound disposal of biodegrad­ Mohanty (CIPET) for reviewing and providing input in the development
able and compostable materials. However, this comes with caveats when of this paper. We also appreciate the valuable insights and comments
considering the role and responsibility of the state in managing an provided by the two anonymous reviewers that helped improve the
environmental problem. manuscript.

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Appendix 1

Nr. Date Title Relevant topics

1 16.04.2020 Covid-19 and the Informal Economy: Responses, Relief and Informal recycling sector, plastic policy, socio-economic impacts, Covid-19.
Research
2 27.04.2020 Sanitation and urban poor in the context of Covid-19 Public services and sanitation, informal economy, marginalized societal groups.
3 07.05.2020 Single Use Plastic and Extended Producers Responsibility in India Plastic Waste Management Rules, Extended Producer Responsibility.
4 08.05.2020 Covid-19 and the Developing World Socio-economic livelihood impacts, informal livelihoods, lockdown, unemployment.
5 22.05.2020 Caught in a pincer: India’s migrants: Between corona and climate Informal sector, worker’s rights, migrant workers, resilient communities.
change
6 22.05.2020 Re-Imagining the Future: Peoples’ Agenda for a Post Covid Decentralization, food distribution, resilient communities, empowerment.
Economy
7 03.06.2020 International Developments in Single-Use Plastics Bans Extended Producer Responsibility, lack of plastic alternatives, long-term sustainability
concerns, waste-to-energy infrastructure, deposit return schemes.
8 04.06.2022 Effects of Covid-19 on Plastic Recycling markets and possibilities SUPP consumption, plastic recycling challenges, Basel Convention.
9 04.06.2020 Webinar on the eve of World Environment Day: E-Launch of Climate change, biodiversity decline, Green, clean, circular and inclusive economy,
WSDS 2021 resilient technology, private sector finance.
10 05.06.2020 Covid-19, Justice and Sustainability in Cities Locally adapted solutions, urban transformations, citizen empowerment, knowledge
transfer.
11 08.06.2020 Marine Litter and UNEA-5 Digital tools, business driven solutions, structural change, holistic solutions, circular
economy, new pollution challenges, multilateral agreements.
12 24.09.2020 Safeguarding the Plastic Recycling Value Chain – Insights from Low-value plastics, multi-layered plastics, value chain perspective, investment, informal
Covid-19 Impact in South and Southeast Asia sector, market driven interventions, locally adapted policies.
13 24.09.2020 Managing plastic waste in India: An agenda for action Single-use plastics, extended producer responsibility, de-coding recycling, informal
economy, source segregation.
14 30.09.2020 Trade and policy in the fight against plastic pollution: Plastic trade flows, trade policy, international cooperation and agreements, Basel
Convention, global agreement on plastic pollution.
15 23.01.2021 Closed Door Meeting on Extended Producer Responsibility with Principles of Extended Producer Responsibility, Complexity of circumstances in India.
International Experts
16 27.04.2021 EPR and Informal Sector Extended Producer Responsibility, inclusive waste management, plastic governance,
policy implementation, impacts on informal recyclers.
17 02.07.2021 Webinar on Evolution of Plastic Waste Policy Plastic Waste Management Rules Amendments, circular economy, end-of-life
management, extended producer responsibility, single-use plastics.
18 22.07.2021 Managing Solid Waste in India: Integration of the Informal Sector Social inclusion, informal recycling industry, recycling hierarchy, models for integration,
decentralized waste management, ecosystem approach.
19 05.08.2021 Plastic Recycling Decoded Plastic waste generation, informal recycling sector, waste value chains.
20 15.12.2021 Regulation on Extended Producer Responsibility for Plastics: Industry perspectives, civil society perspectives, state’s perspectives.
Stakeholder Dialogue

Appendix 2

Nr. Date Informant representative for: Key features

1 08.07.2021 International organization UNEP India

2 08.03.2021 Environmental consultancy Sustainability and waste management focus
3 24.01.2022 Industry association Confederation of Indian Industries (CII)
4 16.03.2022 Plastic recycling company Private
5 18.03.2022 Plastic recycling company Private
6 06.04.2022 Large plastic producer National

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