Gap between packaging placed on the market and material that returns to productive use is where producer responsibility becomes important: Hariharan K Nair of EPL

Producers and recyclers can operate in disconnected systems, with limited data exchange and little visibility into what happens after packaging leaves consumers’ hands.
19/10/2026
4 mins read
EPR

The role of packaging does not end once the product has been used. Where it goes after use is important for sustainability and circularity. But circularity cannot be achieved through recyclable packaging alone. It has to be considered from the way packaging is designed and produced to what happens after use. It requires a system in which packaging materials are collected, recovered, processed, and returned to the supply chain.

Globally, 434.5 million tonnes of packaging waste were generated in 2025, rising to 525 million tonnes by 2030, a 3.9% CAGR. 2024 data shows that 36 kg of waste was recycled out of 53 kg of packaging waste generated per person, while 17 kg was sent to disposal. Plastic packaging had a much lower global recycling rate of 27.9%.

This gap between packaging placed on the market and material that returns to productive use is where producer responsibility becomes important. India has been moving in this direction for more than a decade. EPR became part of India’s e-waste rules in 2011, making producers more accountable for what happens to products after use. Since then, EPR requirements have expanded to areas such as plastic packaging and batteries.

The bigger question is whether businesses can turn EPR into functioning circular supply chains. That requires more than recycling. It calls for coordination across the packaging value chain, investment in infrastructure, and better visibility into what happens to materials after use.

Circularity Starts with Design

Circularity starts with how packaging is designed, from the choice of materials and packaging format to how easily it can be collected and recycled after use. Eco-design should focus on creating packaging that can be reused, recycled, or recovered more effectively. For example, mono-material high-barrier structures can reduce the complexity created by multiple material layers. Fully recyclable HDPE tubes and fully recyclable tubes with PCR content are examples of how packaging design can focus on recyclability and material reduction. Packaging designers also need to consider how formats will be processed in the markets where they are sold. Designing for circularity therefore means considering the package’s entire lifecycle, not just its appearance or shelf performance.

A Collective Effort to Build Circular Packaging

A collective effort across the packaging value chain can turn circularity into a workable business model. When brands commit to using recycled materials, they create stronger demand and give material suppliers, recyclers, packaging manufacturers, and other players greater confidence to invest in capacity and infrastructure. Similar commitments can connect material supply with market demand and make recovery systems more commercially viable.

This requires coordination between material producers, suppliers, converters, brands, retailers, waste-management companies, and recyclers. Sharing information on material specifications, recycled-content requirements, collection volumes, and processing capabilities can improve planning across the chain and help ensure that packaging designed for circularity can be recovered and converted into useful material at scale.

Tracing Through Technology

Traceability is becoming essential to making circular packaging work in practice. 2D barcodes, EPCIS data, RFID, IoT sensors, and digital product passports are making packaging flows more visible, from movement through the supply chain to what happens after use. AI and computer vision are taking this further, with data analysis and automated identification becoming part of how materials are tracked and sorted. This matters because circularity depends on more than collecting packaging.

Companies need to know what was collected, where it went, and what happened to it afterwards. Without that visibility, it is difficult to know whether materials are actually returning to the supply chain or simply being reported as recovered.

Why One EPR Model Cannot Fit Every Market

Voluntary cleanups and brand-led initiatives have a role to play, but EPR needs clear accountability for the packaging companies placed on the market. The same approach cannot work everywhere. What works in London cities may not work in Bangalore, where collection systems, recycling infrastructure, consumer behaviour and local capacity can differ. EPR frameworks therefore need clear responsibilities while allowing implementation to reflect local conditions. This balance can make compliance more practical and help circular packaging systems work beyond the largest markets.

Implementation Challenges & Mitigation

Implementing EPR has practical challenges. For small and medium-sized enterprises (SMEs), redesigning packaging or joining Producer Responsibility Organisations (PROs) can add costs. Sorting and contamination can make recyclable packaging difficult to recover. Changes in packaging materials or formats may reduce weight, transport costs, or certain fees, but can also create environmental or recycling challenges. This makes material decisions more complex than simply choosing the option with the lowest cost or environmental impact.

Producers and recyclers can operate in disconnected systems, with limited data exchange and little visibility into what happens after packaging leaves consumers’ hands. Regional regulations also make it difficult to standardise reporting or scale practices.

Consumer awareness needs public infrastructure, including segregated bins, reliable collection systems and local waste-management capacity. Government support can help build these systems and create conditions for EPR to work effectively.

Including the People Behind Recovery

For EPR to work in emerging markets, businesses must recognise the role of informal waste collectors, who remain central to material recovery. Bringing them into formal systems through fair wages, safer working conditions, protective equipment, and better medical facilities can strengthen collection networks while improving accountability. It also depends on giving the people who collect and recover these materials safer working conditions, fair pay, and a more recognised role in the formal waste-management system.

Shared Responsibility for Building Circular Packaging

Since 2022, about 232 lakh tonnes of plastic packaging waste have been processed under India’s EPR framework, according to government data released in July 2026. That is a substantial amount, but it is only part of the story. Packaging still has to be collected after use, sorted properly, moved to the right processing facilities, and turned into material that can go back into production. That cannot be solved by regulation alone. It needs investment from businesses, workable systems from government and local bodies, the involvement of recyclers and waste workers, and consumers who actually segregate packaging and dispose properly. EPR can create the framework, but making packaging circular will depend on how well the entire system works together in practice.