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Shri Avinash K Shrivastava, No. IBA/44/15-16
Subject: Replacing One Time Use Plastic Bottles for Drinking Water with Suitable Alternatives
Sir, We thank you for inviting the Indian Beverage Association for the meeting on September 9, 2019 taken by the Hon’ble Minister of Consumer Affairs to discuss the issue of replacement of One Time Use Plastic Bottles for Drinking Water with suitable alternatives. We would like to place some facts on the table which differentiate PET bottles from other types of plastics. The Indian Beverage Association is an association of beverage companies which also produce packaged drinking water and, combined, have a market share of +50% at the national level. We would like to place on record the correct statistics on the global trends which were discussed in the meeting and wish to inform you that PET packaging is economical in comparison to other viable alternatives.
In India retail packaged drinking water is largely sold in PET and Pouches made of LDPE, but, due to poor collection and recycling of pouches, state PCBs have discouraged this format. PET packaging has made packaged drinking water affordable to all sections of our society. Its proliferation under BIS standards has been far reaching and also helped reduce water borne diseases substantially. The PET bottles have the highest recycling rates in India at 85% and a net REUSE of 7%, i.e. a total of 92%. With further action as per the Extended Producer Responsibility (EPR) regulations, the industry is confident of reaching close to 100% collection and recycling of PET bottles. As per report by NCL Innovation titled “ PET recycling Landscape of India “, 70% of PET bottle waste is recycled by a formal Fibre industry alone and the rest (approx. 15%) by other sectors. The executive summary of the study is also available at www.petrecycling.in. PET Industry has the highest recycling rate of ~85% and this is higher than other alternate material like glass – 45% (source: AIGMF) and metals – 27% (Source: MRAI) and paper based cartons – 28% (in South East Asia – report by TERI). Presently, GoI has allowed recyclers to import post-consumer PET flakes from across the world as the availability of discarded PET bottles is much less than recycling capacity. The imports have reached a level of 1, 50,000 MT per annum. A Life Cycle Assessment Study (LCA) conducted by ICT Mumbai in 2016-17 compared glass and PET. The Global Warming Potential (GWP) of glass is 16 kg CO2 equivalent as compared to 0.0526 kg CO2 equivalent in case of PET over a period of 100 years. So, the GWP of glass is 300 times more than that of PET. CFTRI, a CSIR Institution, has recently completed a comprehensive study on PET that included examining its Composition, its Leaching and on Endocrine disruption activity from PET bottles. CFTRI has uploaded the Executive summary of the report on its website www.cftri.res.in. CFTRI has concluded that PET Bottles are free from Phthalates, BPA, and Heavy Metals and are not a source of endocrine disruption activity. Hence, PET as polymer has the highest levels of safety for a consumer. We earnestly urge that the above facts are considered by DoCA in guiding the evaluation process to replace PET with alternative materials. We are enclosing: WHO Document. Presentation on Socio-Economic and Ecological impact of PET Bottle. It captures the list of recyclers and how the whole economy is structured. LCA Study by ICT Mumbai. “PET Recycling Landscape of India” study by NCL Innovation. Executive summaries of CFTRI studies on: We would be happy for an opportunity to provide any further briefing on this subject. (Any delay in submitting this material may kindly be condoned.
Secretary General
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