6th December 2023
Naresh Pal Gangawar
Additional. Secretary
Ministry of Environment, Forest and Climate Change
Indira Paryavaran Bhawan, Jor Bagh Road, Aliganj
New Delhi – 110003
Via email: asnpg.mefcc@gov.in; satyendra.kumar07@nic.in; amit.love@nic.in
Our comments on Plastic Waste Management (Second Amendment) Rules, 2023 dated 30thOctober, 2023: Notification No. G.S.R. 807(E)Dear Additional Secretary Mr. Naresh Pal Gangawar:,
The Japan Machinery Center for Trade and Investment (“JMC”) is a non-profit organization.
It was established in December 1952 in accordance with the Japanese Export and Import Trade Law
under the authorization of the Minister of Economy, Trade and Industry of Japan. The objective of theJMC is to engage in activities that enhance the common benefit of member companies and promote
the sound development of international trade and investment by the machinery industry. JMC
comprises member companies engaged in machinery and systems-related exports and foreign
investments such as machinery manufacturers, trading houses and engineering companies. At present,
the total number of JMC member companies is about 240.
Our committee handles environmental and product safety issues regarding products for trade and isstrongly concerned with overseas environment- and product safety-related regulations on products.
From this standpoint, we would like to comment on Our comments on Plastic Waste Management(Second Amendment) Rules, 2023 dated 30th October, 2023: Notification No. G.S.R. 807(E)Rm. 401, Kikai Shinko Bldg., 3-5-8 Shiba-koen Minato-ku, Tokyo 105-0011, Japan
Tel : 81-3-3431-9230 , Fax : 81-3-3436-6455
E-mail : morikawa@jmcti.or.jp
URL : https://www.jmcti.or.jp

If you have any questions, please feel free to contact our secretariat (Mr. Chiaki Morikawa, E-mail:morikawa@jmcti.or.jp)).

Sincerely yours,

KANNO YasuhikoChairman
Environment Law Committee2Our comments on Plastic Waste Management (Second Amendment) Rules, 2023 dated 30thOctober, 2023: Notification No. G.S.R. 807(E)We, the Japan Machinery Center for Trade and Investment, would like to send the following
comments to the Ministry of Environment, Forest & Climate Change regarding Plastic Waste
Management (Second Amendment) Rules, 2023 dated 30th October 2023: Notification No. G.S.R.
807(E).
We welcome the Government of India’s efforts to strengthen the effective implementation of the Rules.
Having given the rules careful consideration, we are concerned about a number of provisions that will
be difficult for producers to comply with in practice and submit the following comments.
As for Rule 11 (1):The requirement to mark on plastic packaging the brand owner’s name, its registration number, andthickness in the case of packaging made by a plastic sheet or the like was once introduced in August
2021; however, it was abolished for imported products according to Plastic Waste Management(Second Amendment) Rules, 2022 published in July 2022. This requirement is re-introduced forimported products according to Plastic Waste Management (Second Amendment) Rules, 2023
published on the 30th October 2023.
We propose that the marking requirement be exempted for packaging for imported electronic products
and their accessories.
Reason:Electronic products and their packaging are generally designed for worldwide use. Marking unique to
India will require further design changes of packaging for different products for the Indian market,
requiring additional resources, administrative costs, and the recovery of unwanted packaging, resulting
in an increased environmental impact.
Many overseas manufacturers were forced to spend considerable resources to meet the marking
requirement in 2021, and the marking was removed when the requirement was abolished the following
year. We are not ready to spend additional resources to once again meet this unique requirement inIndia.
End3