On August 13, the Ministry of Environment, Forest and Climate Change published the Extended Producer Responsibility (EPR) Guidelines on Plastic Waste Management, 2026. The reaction split along a fault line worth noticing. RFL, which already recycles over a fifth of its plastic, has called compliance straightforward for a firm its size. ACI’s business director called consumer-level collection impractical and wants a citywide waste-segregation system instead. Danish’s head of business asked how a firm could collect a used sachet from someone’s home, and suggested recycler incentives or residential drop points instead. The problem, however, lies not in the ambition behind the rules, but in the vastly different kinds of firms expected to comply with them.
Bangladesh generates around 800,000 tonnes of plastic waste a year. Only about 40 percent of it is recycled, according to the Bangladesh Plastic Goods Manufacturers and Exporters Association. Targets start at 15 percent collection and 7.5 percent recycling, rising to 30 and 15 percent by year five.
The government has clearly thought about scale. The rollout is staggered: large enterprises listed in years one and two, medium enterprises in years three and four, small enterprises only in year five. On paper, that is exactly the kind of phased approach CMSME advocates usually have to fight for. In practice, the phasing solves the wrong problem.
A “small industrial enterprise,” under Article 2, is any firm with fixed assets, excluding land and buildings, worth between Tk 50,000 and Tk 15 crore, employing up to 50 workers. That is a wide band, stretching from a two-person sachet-repacking operation in an urban slum to a firm on the edge of qualifying as medium. Nowhere in the text do the words “cottage” or “micro” appear.
Bangladesh already has a working taxonomy for this problem, which makes the gap harder to excuse. The National Industrial Policy divides enterprises into five tiers: cottage, micro, small, medium, and large. Bangladesh Bank’s lending circulars are calibrated to that taxonomy. The first four tiers, known as CMSMEs, provide employment to an estimated 87 percent of the country’s active labour force. An estimated 80 percent of CMSMEs operate informally, without the accounting infrastructure regulatory compliance assumes. Listing criteria will sort through that range: production volume, turnover, and import volume, under Article 4(4). But sorting for listing order is not sorting for obligation. When year five arrives, a sachet-repacking outfit and a 50-worker plastics workshop face the same form, compliance route, and three-year renewal cycle.
Every obligated entity must work through a Producer Responsibility Organisation (PRO), a body, single or grouped, that manages EPR obligations on a firm’s behalf, including collection, recycling, and mandatory annual reporting to the Department of Environment (DoE). A firm can register as its own single PRO, or several firms can form or hire a Group PRO, taking on the collective EPR responsibility of every member, funded through a pooled EPR project fund. The Bangladesh Plastic Goods Manufacturers and Exporters Association had itself proposed a voluntary-then-phased rollout and asked that small entrepreneurs be exempted outright. The government adopted the phasing but declined the exemption, offering the Group PRO instead.
Waste collected by local government bodies cannot count towards an obligated entity’s collection target, so the dumping-ground-to-recycler pathway many small manufacturers rely on will not satisfy the guidelines alone. Meanwhile, selling surplus as “plastic credit” to another entity or on the international market only pays off when a manufacturer has surplus to sell.
The guidelines give the government three years before it revisits collection and recycling targets, a window that should do more than adjust percentages. The DoE’s listing criteria should distinguish cottage and micro enterprises from small enterprises. Group PROs need explicit authority and funding to contract with city corporations and waste-picker networks, since municipal collection cannot otherwise count towards a firm’s target. A green-financing window should be there for small firms joining a Group PRO, run through Bangladesh Bank’s CMSME refinancing facilities, which would need only a central bank circular. A tax credit is the harder ask, needing an NBR notification or a Finance Act amendment, not redrafted guidelines. It belongs on the government’s agenda now, not after year five.
The EPR Guidelines 2026 already reject the false choice between clean rivers and small manufacturers who employ most of the workforce. They gave small enterprises five years, not zero. What they never asked is how small “small” is, and their one financial mechanism rewards firms that need it least. As it stands, a cottage repacker and a near-medium factory get the same five-year runway. Only one of them was built to survive it.
Md Rakibul Hasan is credit officer at Bangladesh Small and Cottage Industries Corporation (BSCIC). He can be reached at [email protected].
Views expressed in this article are the author's own.
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