National Resource Efficiency Policy (NREP): Can it revive the circular economy?

Over the last decade, much has changed in the regulatory landscape of waste management sector as number of old rules (Plastic Waste Management Rules 2011, Solid Waste Management Rules 2000) have been upgraded and new rules (E-Waste Management Rules 2016, Construction and Demolition Waste Management rules 2016) have been implemented. However, the ground realities remain grim: on the one hand, our cities are crumbling under piles of uncollected waste, while on the other hand waste management companies are unable to get enough waste.

In this context, the draft National Resource Efficiency policy (NREP), aims to create an overarching policy framework to promote resource efficiency across all sectors. It recommends a life cycle driven approach for managing resources right from their extraction to disposal. It proposes penalties for extraction of virgin material, design standards for product longevity and reuse, encouragement of production of green products, strict rules for collecting waste from consumers/bulk generators and taxes on landfills. The policy has good intent, but may not be able to achieve the desired impact in absence of a robust circular industry that can collect and process waste.

Historically, waste management policies have been implemented through Pollution Control Boards (PCBs), who are responsible for licensing and regulating the industry. As such, the emphasis has been on regulation, which now needs to shift to industry enablement. Further, NREP must address issues such as lack of access to waste, small scale of operations and high taxes that render circular companies uncompetitive.

Access to waste

India’s circular industry is nascent, with only handful of public listed companies and no unicorns. It mostly exists in selected sectors such as electronic waste, plastic waste and to some extent in tyre, metal recycling and municipal solid waste processing.

Getting access to segregated waste in large quantity is a big constraint for the industry. For example, while annual e-waste generation in India is estimated to be 20 Lakh tonnes, most formal sector recyclers are not able to collect even 5000 tonnes per annum. Similarly tyre recyclers that reclaim rubber from tyres face challenges in collecting waste tyres. Many waste and biomass based power plants have been closed down due to unavailability of segregated waste. Metal recycling industry relies on imported scrap, and construction waste recycling is yet to take off as segregating waste and converting it to useful products is not profitable.

Unlike regular manufacturing industries, where raw material can be bought from other sources, circular economy companies need to collect waste (their raw material) from a wide variety of sources and incur considerable cost in transporting it to the recycling centres. Additionally, generators of waste are not ready to pay for its disposal; instead, they expect to be paid for their waste. Moreover, composition of waste changes on a daily basis, making it difficult for companies to deliver standardised products, thus affecting their financial viability.

Waste can be divided into two categories; post-consumer waste and pre consumer (industrial) waste. The cost of collection of post-consumer waste is high and volumes are low, as consumers do not have sufficient incentives to dispose the waste in a responsible manner. For example, most of the Multi-Layer Plastic (MLP) waste cannot be recycled as it is mixed with household waste and the cost of cleaning MLP waste makes the recycling unviable. Industrial waste is somewhat easier to collect, but the waste generators are nonetheless unwilling to pay for its disposal. To add to this, high end machinery for recycling is mostly imported, adding to the project cost of recycling ventures.

Some of the remedial measures that could be implemented for this could are:

  • Funding mass awareness programmes on waste segregation, waste disposal and capacity building of informal sector should be routed through waste management companies who have incentives for doing it effectively as they stand to gain from higher waste collection
  • Incentivise domestic machinery manufacturers to develop indigenous machinery for onsite waste segregation/processing

Financial incentives to achieve economies of scale

India’s recycling industry is dominated by a large number of micro enterprises with low processing capacities. For example, a majority of the 7500 (Report by FICCI, 2017) plus formal and informal plastic recyclers, have capacities lower than 10 tonnes per day, whereas globally new plants are being built with a capacity of more than 100 tonnes per day. Similarly, most of around 300 e-waste recycling companies dismantle e-waste manually and have not invested in modern facilities for recycling/refining the waste. The tyre recycling companies that have been dismantling cross ply tyres need to invest in technology to be able to process radial tyres.

NREP has proposed to set up a green fund to facilitate access to finance for technology and process improvement. A part of this fund could be exclusively reserved for financing value addition related to capex of circular economy companies. This fund could work on the lines of energy efficiency cluster financing program of the World Bank/SIDBI which provides financing for energy efficiency/pollution reduction measures to foundries.

Rationalising taxes in the entire value chain

NREP proposes rationalization of the tax regime to make secondary raw materials price-competitive. The taxes would need to be rationalised throughout the product value chain. For example, the GST rates on plastic scrap have already been reduced to 5%, but the products made out of the plastic waste such as plastic granules, roofing sheets, furniture, sacks etc. attract 18% GST, in line with the products made from virgin material. Further, since recyclers buy their raw material from scrap sellers, many of whom are not registered with GST, they are not able to claim input credit, and therefore their effective taxation is higher than that of manufacturers of products based on virgin products.

Further, NREP may also want to advocate the case of rationalisation of taxes/subsidies on the products that compete with the recycled products. For example, organic fertilsier (made from food waste) competes with chemical fertilsier such as Urea/DAP, which are heavily subsidised. Rationalisation of subsidies on chemical fertilsier will provide a boost to the organic fertiliser sector and make the operations of agri waste recycling companies profitable.

Monitoring the health of circular industry

The new policy lists resource productivity, domestic material consumption, extraction and output as indicators for measuring resource efficiency. It may be prudent to add circular industry health to the list of indicators, which could be measured in terms of growth in sales of formal sector enterprises, their employee strength and capital expenditure.

In summary, NREP with its proposed measures of life cycle management of resources, is a good step toward building the circular economy. However, the implementation approach needs to be different though, one that gives priority to the entrepreneurs /enterprises in the sector.

How can we help?

We are an advisory firm for small and medium enterprises in green industries. We can help you evaluate the viability of your proposed green venture and assist you in raising funds for growing your business. If you are looking to purchase or sell your business, we can help you identify the right buyer/seller and hand hold you throughout the transaction.If interested, please get in touch with us at admin@finetrain.com We look forward to helping you negotiate your path to a successful SME business!

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Multi Layered Plastic Recycling: opportunities and challenges

Multi layered plastics (MLP) such as potato wafer packet, chocolate wrapper, wrappers for ready to eat foods and pharma products are criticised for their lack of recyclability, leading to littering of our cities and oceans. However, MLPs remain the cheapest and most viable option for packaging of food and pharma products and it may not be possible to completely replace them atleast in the near term. In this blog, we examine entrepreneurial opportunities available in MLP waste management and challenges faced by these businesses.

How big is the MLP waste problem?

India consumes close to 150001 tonnes of plastics per day, of which only 60% is recycled. Packaging plastics (MLPs and single use plastics such as light weight plastic bags, coffee cups, disposable utensils), contribute to majority of the non-recycled plastics. MLPs cannot be recycled economically, as these are made of two or more layers of plastics and separating the layers is not cost effective.

MLP waste can be broadly divided into two categories: industrial waste and post use waste. Industrial waste refers to the waste generated in the flexible packaging /converting units, this waste is relatively clean and can be converted into products such as plastic ropes/bags or fuel. Post use waste comprises waste generated from households and other consumption centres such as malls, commercial establishments. Such MLPs are contaminated and have high moisture content as they are mixed with the organic waste; it is this waste, which mostly finds its way to the landfill.

Is there a shortage of MLP waste processing capacity?

MLP waste can typically be converted into power or fuel, through a number of processes (see picture 1). Additionally, it can also be used a filler for laying roads.

Picture 1: Laminate waste treatment options
wastetreatment
Among above mentioned methods, co processing in cement plants has taken off to an extent. Currently around 542 cement plants all over the country have made investments in co processing facilities that allows them to use alternate fuel in the kiln. As per Cement Manufacturers Association (CMA), cement plants currently have a Thermal Substitution Rate (TSR) of 4%, indicating that they meet 4 per cent of their fuel requirements from alternate fuels including plastic waste. Cement industry has proposed to increase their TSR to 25% by 2025, which will allow them to consume up to 12 million tonnes of plastic waste. While cement plants can handle contaminated waste, it has to be moisture free as wet waste is difficult to process.

Waste To Energy (WTE) plants burn unsegregated waste to produce power. Currently there are around 7 operational WTE plant, 403 under different stages of construction. WTE plants are ideally meant for processing dry waste, as wet waste (largely organic in nature) has lower calorific value and therefore is ineffective. However, given the lack of availability of segregated waste, they use mixed waste. While these plants have faced issues related to their compliance with pollution control norms, they are still preferred by the municipalities around the country as they can handle large amounts of unsegregated waste.

Pyrolysis refers to the process of converting plastic to oil, which can be used as a fuel. This process also needs clean /moisture free waste. Pyrolysis is yet to take off, largely to due unavailability of clean waste and risks related to the pollution compliance of such units. However, these plans can work well in industrial estates where availability of 2-3 tonnes of clean waste per day is assured.

Plastic has been used to build roads in Chennai, Indore, Pune and Meghalaya. The challenges again are lack of availability of required amount of clean plastic waste.

As such, the key issue that hampers laminate waste management is lack of availability of clean laminates that are fit to be processed and not shortage of waste processing facilities as such. The existing capacity of the cement and waste to energy facilities is enough to meet the needs of the industry.

Where are the opportunities for new businesses?

On the one hand, there is huge amount of MLP and plastic waste which needs recycling and on the other hand waste treatment providers such as cement kilns, WTE and pyrolysis plants don’t get desired quality of waste. Thus, there is a large opportunity to set up businesses that can incentivise households to segregate dry and wet waste, collect the segregated waste and channelize it to recyclers. Given the potential opportunity, a number of companies (see Table 1) have started aggregating household waste and supplying it to recyclers.

Table 1: Waste Management companies
CompanyLocationRemarks
Lets recycleAhmedabadWaste management, waste handling and reporting services for corporates, also owns recycling facilities, funded by impact investors such as Aavishkaar and Asha impact
Waste venturesHyderabadWaste collection, segregation and channelization , has been funded by Vilcap investments
Karo SambhavGurugram, HaryanaE waste PRO, funded by IFC, clients includes HP, Apple Del and Xiaomi
GEM enviroDelhiPlastic waste PRO, counts Bislery, Pepsi, Coco Cola among its clients
Raddi ConnectMumbaiWaste collection and channelization
Thekabadiwala.comBhopalDoorstep waste collection and channelizing the waste,  recently raised angel funding of Rs. 3 crores
Saahas zero wasteBangaloreWaste management, EPR and consulting services, has raised funds from India Angels network
Rudra Environmental SolutionsPuneCollects plastic waste and converts it to fuel in their own pyrolysis plant. Has been acquired by Blue Planet environmental solutions Pte limited, Singapore
Source: FineTrain research

Further, changing regulatory landscape in plastic waste management sector has boosted the viability of this sector. The regulations on plastic waste management are evolving and EPR (extended producer responsibility) was introduced in 2016. EPR makes producers, importers and brand owners responsible for processing of end of life plastic waste generated by their products. These companies can also take services of a Producer Responsibility Organisation (PRO) to manage their waste. Although, EPR for plastic waste is still in its early days, some FMCG companies have started warming up to this idea. For example, Indian Pollution Control Association (IPCA), a Delhi based PRO is implementing a project called “We Care” on behalf of FMCG companies such as PepsiCo , Nestle, Dabur and other to collect MLPS and channelize them to the recyclers. Recognition and acceptance of a PRO in plastic waste management provides a sustainable source of revenue for waste management companies and therefore makes their operations more viable.

Regulation is also slowly making an impact on waste segregation mindset of Indians. For example, in Mumbai and /Bangalore in situ (on site) composting is mandatory for bulk generators who generate more than 100 kg of waste every day as the municipality does not collect wet waste from such bulk generators.

Increasing awareness about consequences of informal recycling on the health of workers and environment is also bringing about a change in the mindset of people to own up their waste and sell it only to authorised recyclers. This in turn is likely to lead to an increase in demand for PROs in the long term.

What are the key challenges?

While the opportunity is large, the waste management companies face challenges related to lack of adequate clean waste and funding.

  1. Competition from informal sector: Almost all companies in formal waste recycling sector including e waste, bio-waste and plastic waste do not get adequate waste. For example more than 90 per cent of4 e waste is handled by informal sector and 50 per cent5of plastic recycling is done by informal sector, resulting in less than adequate availability of waste to the formal recyclers. The informal sector is able to offer higher prices for the waste vis a vis formal recyclers as they their processing costs are lower due to lower operational/manpower costs/capex costs. For example, a formal plastic recycling units needs to invest at at-least Rs. 1 cr in a recycling unit including the processing machinery and pollution control equipment for treating dust and waste water. However, the cost for informal sector are negligible as most of the work is done manually, and without any compliance to pollution control.
  2. Access to funding: The waste related business are working capital intensive, as they need to pay for the waste upfront, while they get paid only after sizable quantity of each type waste is collected, sorted and sent to the recycler. Additionally, they need large godown for waste storage and employ a number of people in sorting the waste. Further, they require funds for conducting awareness campaigns and marketing. Since these businesses do not have large physical assets, traditional channels such as bank are not able to meet their requirements. Similarly, such businesses also find it difficult to attract equity capital, as it is difficult to scale up operations across geographies.
    However, emergence of impact investors and green funds has improved the funding prospects of these businesses. As can be seen in the Table 1, a number of investors including IFC, Aavishkaar, Asha impact and angle investors have invested in waste related businesses.

How can we help?

We are an advisory firm for small and medium enterprises in green industries. We can help you assess viability of your proposed plastic waste related venture including availability of waste, technology selection and market for recycled products. If you already have a waste related business, we can support you in raising capital for your growth plans and also in acquiring green businesses.

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Write to us: bchhatre@finetrain.com , admin@finetrain.com
Call us: 800 888 4932

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Loans to MSME in 59 minutes — A radical reform or just an eyewash?

One of the biggest announcements for MSME sector in 2018, was the 59 minute loan scheme, which promises loans of up to INR 1 crore to MSMEs from public sector banks (PSBs) through a seamless online lending market place called PSBLOANIN59MINUTES. This web portal approves a loan in 59 minutes and connects the borrower to the bank branch for sanction and disbursal.

The process is as follows: on submission of the information online, the portal does an analysis of the data and approves or rejects a loan. For loans that are approved in-principle, the portal provides information on banks that offer required product, loan amount, rate of Interest etc. The applicant has to choose the branch of the bank through which the loan shall be processed and disbursed and make payment of a convenience fee of INR 1000. The “in-principle” approval is valid for a period of 15 days from the date of approval. The Bank receives a preliminary report from the portal, where a set of 22 parameters are checked along with profile of the promoters, business activity, analysis of past financial statements, risk scoring, assessment of limits, fraud analysis and verification from GSTIN and MCA. Then, the applicant has to approach the bank branch along with the system generated approval letter and list of indicative documents. The bank would do required due diligence and sanction/disburse the loan.

As per MSME PULSE , the size of loans to MSME (under INR 25 crore) is estimated to be around INR 25 lakh crore, of which the share of public sector banks is large (around 48%). While the share of PSBs in MSME lending has been declining, they still retain a dominant share of over 75% for loans under Rs. 10 lakh, highlighting their critical role in financial inclusion. The biggest advantage of a PSB loan is its low cost, which could be 5-7 % lower than that of NBFCs and fintech portals. For a small borrower looking to borrow a collateral free loan under INR 1 crore, PSB loans are the most accessible loans, as both private banks and NBFCs mostly lend against a security. PSB loans are also an important source of funding for the manufacturing sectors such as food processing, textile, chemicals, and auto components.

As such, this policy measure may be a sincere attempt to reduce the time and effort required to secure credit from PSBs, thus easing the life of an entrepreneur. The demand for such a portal is validated by both the large number of applications (around 1.31 lakh) received within 2 months of its launch, and their total loan value. To substantiate, assuming an average loan size of INR 30 lakhs, these applications translate into loan requirement of INR 40,000 crore, which is almost 5% of the total MSME credit for loans below INR 1 crore . However, unless these applications translate into loan disbursals, the portal would remain just another channel for the PSBs to generate qualified leads

Advantages of the portal

The difficulties in getting a loan from PSBs stems from unwillingness of the ground level staff to even acknowledge/accept the loan application. Even after a loan is approved, the high turnaround around time for the disbursal of the loan remains a challenge. Therefore, the portal is a good first step to ateast reduce the number of branches to be visited. In addition, the MIS behind the portal would make it easier for the banks to closely monitor reasons for rejection of a loan.

Performance

While the intent of the scheme is good, its success depends on the ability of PSBs to quickly disburse the loans that have been approved by the portal. According to official data, the portal received 1.31 lakh applications during the first 50 days of its launch, of which around 1.12 lakh applications were approved, with a strike rate of 85%. However of these 1.12 lakh applications, sanctions were accorded for just 40,669 cases, which translates into a loan sanction ratio of around 36%. This loan sanction ratio could actually be overstated as the applications through the portal may include those for loan renewals from existing clients of banks, which are likely to have higher approval to disbursal ratio vis-a-vis that of a new client. Even if we assume that these applications are all new, the conversion ratio does seem low, as just over a third of the approved loans seem to have been sanctioned. The above performance indicates the following gaps:
1) High approval ratio of the portal suggests one of two things: either most of SMEs that are applying through the portal have good credit quality or the portal’s credit sanction norms are relaxed. Low loan sanction ratio suggests that there are differences in the credit assessment methods of banks vis-a-vis that of the portal;
2) Takeover of loans among banks is not easy, and banks are finding it difficult to extend loans under multiple banking arrangements
3) Lack of resources at bank branches to follow up with the SME and carry out due diligence
4) Unwillingness at branch level staff to lend under CGTMSE

Suggestions

To address the above issues, some of the following steps may be needed to improve the credit evaluation process of the portal along with related policy measures to facilitate loans by banks and improve their loan disbursals:

Process improvements that may be needed to improve loan disbursal

systems to increase the likelihood of the sanction of approved loans. Specific areas that require attention are:

  • The portal should be able to capture the existing liabilities of the borrower correctly so that rejection from the banker does not take place on account of inaccurate information on the existing debt levels. Moreover, the risk rating parameters of the portal have to be similar to that of the banks so that there are no disputes in the quantum of credit sanction.
  • For borrowers seeking term loans for a new asset, the portal needs to assess viability of new projects and the availability of other resources such as required land/technology with the entrepreneur.
Policy measures to support easy lending
  • Relaxation of takeover norms would be required to facilitate easy takeover of loans among lenders. For example, for borrowers who already have a secured loan, a new lender may not be willing to provide a collateral free loan and may want to take over the existing loans as well. Similarly obtaining any enhancement on working capital loan from a different lender would be difficult, as banks would not be inclined to share security on pari passu basis for such small exposures.
  • Since MSME sector credit seekers also require assistance in filing the application, consultants enrolled with SIDBI could be incentivised to take up the work related to filling application forms
  • Many small enterprises do not have GST registration and may not want to obtain the same as the threshold turnover for GST registration has been revised. The portal may want to waive GST registration as a mandatory requirement for companies with turnover of INR 40 lakhs. The credit assessment parameter for such companies could be based on bank account statements and alternate data points such as profile of their customers, industry profitability, and track record of the utility bill payments.

In the absence of the above measures, this web portal would just be a superfluous channel for generating qualified leads for the PSBs alongside their websites and tie ups with online e-commerce platforms; what would be really enterprising is converting these leads into qualified loans for disbursal.

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Green products: How to set up Compostable Plastic bags business?

Compostable plastic bags are plastic bags that decompose into natural components such as carbon, water and biomass upon their contact with soil. As per DS6400, the most widely recognised international standard for compostable plastics, such plastics should completely disintegrate into natural components within 180 days in composting environment.

India generates huge amount of plastic waste (nearly 15,000 tonnes per day). It is estimated that only around 60 per cent of this waste is recycled and remaining gets dumped in the landfills and other places. Prominent among non-recyclable plastics are poly bags made from Polyethylene (PE), which can take up to 100 years to disintegrate.

Plastic bags have been completely banned in Maharashtra[1] (except for milk packets and some specific applications). Further, 17 States and Union Territories in the country have imposed partial ban on these bags with restriction on the thickness of the bags to minimum 50 microns. Increasing awareness about environmentally sustainable products along with restrictions on the usage of plastic bags have improved the prospects of compostable bags.

What are compostable Plastics?

Compostable plastics can be made out of bio based or petroleum based compounds (Resins) as shown below.

Figure1: Types of compostable plastics

Currently, the market for compostable resins is small, at around 1 million tonnes[2] (less than 0.5% of world’s annual plastic consumption of 320 million tonnes). These resins are patented by large multinationals such as BASF, NOVAMONT and have to be purchased from them or their dealers, thus resulting in higher price and limited availability. However, their consumption is predicted to grow at a CAGR of 20% over the next five years[3], and with the rise in demand, the availability of such plastics is likely to increase and their prices would become competitive.

How do compostable bags compare with conventional bags?

Compostable resins’ tensile strength, printability and weight bearing capacities are similar to that of conventional polymers such as Polyethylene (PE). In fact, in some specific applications, compostable resin may offer higher density and tensile strength as compared to  PE, thus resulting in requirement of less tonnage of the resin vis-à-vis PE.

However, currently, the compostable plastic resin is 2-3 times costlier than the conventional resins. Further, the costs of processing these resins into products such as bags are also higher due to smaller size of the processing capacities. As a result, these bags are 3 times as costly as conventional bags. For example, a medium size compostable garbage bags is currently priced at Rs. 220 (for a pack of 30 bags) as compared to a price of Rs. 70-80 for similar conventional bags.

What are the international and domestic standards for compostable Plastics?

There are a number of standards for compostable plastics including ASM D6400 (USA) and EN 13432 (Europe) and ISO 17088.

An Indian manufacturer of compostable plastic bags has to obtain a certification from Central Pollution Control Board (CPCB) for selling compostable bags and related products. The certification process requires the product to be tested in a government authorised lab to check its compliance to ISO 17088.

Table 1. International Standards for compostable bags
S.NoStandardization BodyStandard
1ASTM – American Society for Testing and MaterialsASTM D6400
2European StandardsEN 13432, EN 14995
3ISO – International Organization for StandardizationISO 17088

Is manufacturing compostable bags complex?

No, the manufacturing is very simple and is a two-step process; first the resin is processed into a film through a blown film manufacturing machine, the film is then cut, printed and sliced as per the bag sizes. Currently most Indian manufacturers use conventional LDPE blown film machinery for sheet extrusion. The resin is either directly imported from the manufacturers (list of bioplastic resin manufacturers is available in Table.2), or their dealers.

Table 2. Bio Resin manufacturers
S.NoCompanyCountry
1BASFGermany
2Bio-FedGermany
3CarbioliceFrance
4FKuR KunststofGermany
5NatureWorksNetherland
6NovamontItaly

Is there a market for compostable bags?

The demand for compostable bags is rising driven by growing concern about the environment and changing regulatory landscape. The waste management regulations in India are getting more stringent about handling and disposal of all types of waste including plastic. Therefore, specific segment of the market such as trash bags, bags for nurseries are witnessing a lot of interest from supermarkets, retail chains etc.

Given the demand, a number of new manufacturers have entered the market in past two years. The number of CBCB registered manufacturers of compostable bags has increased to 12 from just 2/3 a couple of years back ( a list of CPCB approved vendors is available here ).

The usage of other biodegradable/environmentally sustainable products is also increasing. Recently McDonald’s India has proposed to replace its plastic cutlery with a combination of wooden and biodegradable plastic cutlery ( available in this link: McDonald’s India kicks out plastics )

How much capital is required and what will be the profitability?

The capital requirements would depend on the machinery and the scale of operations. For example, a blown film machine of a capacity of 15-20 tonnes a month available for around Rs. 30 lakhs. However a European machinery (smallest capacity of 400 kg per hour) specifically made to handle bioplastics can cost more than Rs. 3 crores.

The minimum capital requirement including working capital is likely to be over Rs. 60 lakhs. The overall profitability and return on investment would be contingent on the manufacturer’s ability to secure regular orders and keep processing costs under control.

What are the key challenges?

  • Most states do not have a policy on regulation of usage of compostable plastic bags currently. The guidelines on allowing such bags in retail market would be critical for the growth of the industry.
  • The processing machinery is designed for conventional plastic, which can withstand higher temperature as compared to compostable plastics. Therefore getting the right product requires a number of trials.
  • The certification process for compostable bags is time consuming and can take up to 6-8 months.

[1] As per the circular, dated 10th July 2018 of Maharashtra Environment department, the compostable plastic bags are allowed for horticulture, agriculture, and handling of solid waste.
[2] Source: Global production of bioplastics, a publication by European bioplastics
[3] Source: European-bioplastics.org

How can we help?

We can help you start a compostable plastic bags manufacturing unit through a number of services including viability assessment, market landscaping and technical consultation

Reach us @

Write to us: bchhatre@finetrain.com , admin@finetrain.com
Call us: 800 888 4932

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