Module 2

Extended producer responsibility: a mainstay for e-waste management

The evolution of EPR has taken place in the broader context of sustainable development, which
largely focuses on healthy and safe environment. Most developmental concerns, principles have
been articulated from the perspectives of safe environment and sustainability. For example, the EU
started discussing issues of environmental protection policy circles since early 1970s; considering
a few fundamental principles of sustainable development, such as, the "precautionary principle, the
principle of 'prevention', and the 'polluter pays principle. The necessity for the introduction of EPR
comes from the growing awareness that other environmental policy measures might not be
sufficient to reach the environmental goals of society (ISWA 2014).
The concept of EPIR was first introduced by Thomas Lindhqvist, professor at the Lund University
in Sweden in 1990 (ibid.); he has discussed policy principle to promote environment improvements
of production systems in detail in his doctoral dissertation in 2000. During the 1990s, several
European countries were preparing and commencing the implementation of various policy
instruments to improve the management of EoL products, largely based on the preventive
environmental strategies as promoted by UNEP in the 'Cleaner Production Programme. The concept
implies that responsibilities, which were traditionally assigned to consumers and authorities
responsible for waste management, are to be shifted to product producers.

After introducing formal (primary) definition of EPR in 1992, Thomas revised the definition as a
concept as a policy principle in 2000.
EPR is a policy principle to promote total life cycle environmental improvements of product
systems by extending the responsibilities of the manufacturer of the product to various parts of the
entire life cycle of the product, and especially to the takeback, recycling, and final disposal of the
product

Davis Gary in 1994 defined 'Producer Responsibility Principle as a policy principle, which is as
follows:
Concept chat manufacturers and importers of produces bear a degree of responsibility for the
environmental impacts of their products throughout the products life cycles, including upstream
impacts inherent in the selection of
materials for the produces, impacts from manufacturers' production process itself, and downstream
impacts form the use and disposal of the products.
Producers accept their responsibility when they design their products to minimise the lifecycle
environmental impacts and when they accept legal, physical or economic responsibility for the
environmental impacts that cannot be eliminated by design.
Thus, EPR as environmental strategy, has been attempting to link the following dimensions: (i) area
of products (implying that product system improvement including product material, design,
expected life, etc.); (il) design for environment/ sustainable development (preventive environmental
policy making) or Design for Disassembly (DAD) activities leading to overall life cycle
environmental improvements of products and product systems; and (i) public policy framework
(which can ensure product will protect environment along with administrative, economic and
informative instruments), which includes well-organised collection with high collection results,
increased recycling, and costs connected to waste collection, recycling, or final disposal, etc
The practical development of EPR can be traced back to the enactment of the German Ordinance
on the Avoidance of Packaging Waste in 1991. The success of the Ordinance that saw the
consumption of packaging decoupled from the economic growth in Germany encouraged policy
diffusion.

EPR applied for waste management and extended for e-waste management

The EPR has been propagated as a mainstream paradigm in waste management since beginning of
the 2000s by the OECD (Organization for Economic Co-operation and Development) countries, it
was applied for packaging waste, electronic, and electrical equipment, batteries, bottles, paint cans,
automobiles, waste oil, tyres and refrigerators'

The OECD defined EPR in 2001, as an environmental policy approach in which a producer's
responsibility for a product is extended to the post-consumer stage of a product's life cycle.
According to the OECD (2001: 18), 'EPR aims at reaching two goals: (i) shifting the responsibility
away from the municipality and general taxpayer towards the producer; and (i) provide incentives
to producers to incorporate environmental considerations in the design of their products'

There is a need to redefine responsibilities; that is, the incentives provided to producers to redesign
products and packaging, which would reduce the share of waste destined for final disposal, and thus
increase recycling.
Also, EPR policy alone does not aim to achieve a full internalization of environmental costs; the
task of establishing an environmental price for a wide range of environmentally diverse waste
streams makes this impractical'

In the evolved EPR framework for e-waste management by OECD in 2016, the EPR embodies the
notion that 'extending the producer's responsibility describes producer's physical and/or financial
responsibilities and covers all stages - from environmentally compatible product design and
meeting material management goals through recycling to the post-consumer stage of a product life
cycle. The producers typically pay towards the costs of e-waste processing, such as, collection,
recycling, and disposal.
The OECD (2016) has mentioned four broad categories of EPR instruments/ responsibilities:
(i) product take-back;
(ii) economic and market-based instruments;
(iii) regulations and performance standards;
(iv) information-based instruments.

EPR applied for waste management and extended for e-waste

The product take-back is considered a strategy, and therefore often becomes a voluntary initiative
by the producers, by establishing collection and recycling targets for a product. The economic and
market-based instruments provide financial incentives in form of deposit refund, advanced disposal
fee", material tax, upstream combination tax/subsidy. These fees may be assessed by weight or per
unit of product sold. After useful life of any e-product, physical responsibility (regulations and
performance standards) of a producer encompasses take-back of the products from the consumers,
which may enforce collection rate targets, and undertake recycling (processing for recovery).
EPR: goals, implementation, and challenges for e-waste management Goals

ISWA (2014) stressed that EPR need not be a stand-alone policy measure; it should always be
incorporated in a mix of environmental policy measures.
EPR is usually conceived as a comprehensive policy package, combining various instruments to
simultaneously achieve the following goals: (i) create a sustainable production, consumption, and
waste management policy; (ii) incentives for eco-design; (iii) reduce landfilling and develop
recycling and recovery channels; (iv) full internalisation of environmental costs, other instruments
need to be introduced/ employed

EPR can lead to the following:

overall waste prevention; use of non-toxic materials and processes; development of closed material
cycles; development of more durable products; development of more reusable and recyclable
products; increased reuse, recycling and recovery; and transfer of waste management costs for used
products onto producers consistent with the Polluters Pay Principle.

Policy instruments

The EPR instruments have been implemented in a heterogenous or selective manner, mainly
because of differences in framing of laws and implementing them as per the requirements of a
country (Patil and Ramakrishna 2020). Among various regulatory instruments' mandatory take-
back; energy efficiency standards; minimum recycled content standards; secondary material
utilisation rate requirements; disposal bans and restrictions; material ban and restrictions; and
product bans and restrictions. Among different 'economic instruments, advance disposal fees;
deposit/refund; material taxes; etc. are known. The 'information instruments' include seal-of-
approval types of environmental information labelling - product environmental profiles for the
whole life cycle of materials, product hazard warnings and product durability labelling.

EPR implemented for e-waste management under the existing regulatory frameworks in
different countries

The GEM 2017 recognises that:

Most legislation and policies currently refer to the principle of EPR, which emerged in academic
circles in the early 1990s. It is generally seen as a policy principle that requires manufacturers to
accept responsibility for all stages in a product's lifecycle, including EoL management.

There are three primary objectives of the EPR principle:

• Manufacturers shall be incentivised to improve the environmental e their products and the
environmental performance of supplying those products
• Products should achieve a high utilisation rate.
• Materials should be preserved through effective and environment- collection, treatment,
reuse, and recycling.

The key principle behind the reasoning that producers or manufactures how primarily responsible
for this post-consumer phase is that most of the environmental impacts are predetermined in the
design phase (Baldé et al. 2017: 49).
The principle of EPR has been introduced in multiple countries and for variety of waste streams.
There is also a broad variety in the policy measures to implement EPR, the goals, and achievements.
There is no one-size-fits-all approach EPR, and its effectiveness will always depend on national
circumstances, con priorities, and waste streams. EPR implementation is a complex topic l many
potential challenges; therefore, more 'practical' or 'operational aspects considered for successful
EPR implementation (ISWA 2014:8).

Process of Implementation

The process to implement the EPR concept typically involves the following three stages:
(i) an appropriate policy instrument that embodies the EPR principles is identified and a legislative
framework is developed;
(ii) the legislation is translated into an EPR programme, involving design of a set of detailed
operational rules, such as, specific mechanisms to finance the operations of the programme, to
monitor, and evaluate the legal compliance of each entity involved, within the parameters of the
legislation, etc; and execution of the EP programme into a working system in practice

Due to the multi-agent nature of an EPR programme, efficiency of its implementation is greatly
influenced by the heterogeneity in its perspectives. A mandated EPR programme can give rise to
economic opportunities for businesses involved in e-waste collection and recycling. This may lead
to competing interests between producers and informal sector, especially on collection to recycling
mechanisms, on resource recovery, and management of secondary materials. However, establishing
collection and recycling mechanism may increase economic burden of producers; location of these
facilities also matters vis-à-vis transportation and storage cost or broadly, value of entire reverse
supply chain. For legal compliance, cost of collection and recycling mechanisms and operations
often result in a gap between the EPR system in practice and what is intended by the EPR principle
and/or EPR legislation

The Overview of EPR implementation in different countries

s
Role of PRO prescribed in Regulatory framework

A PRO is envisaged as an organisation that takes on the EPR mandate of a single

producer/collective group of producers to fulfil the FoL waste related legal obligations on their
behalf. In this conception, a PROs plays a centre-stage role, in thorough implementation of the
EPR on behalf of a producer, such as, meeting targets of collection, recovery, and recycling
obligations, etc.
A PRO works with a range of stakeholders, and expected to create systems that bring
transparency, and accountability in achieving goals defined/legal compliance for producers.
The scope of PRO functioning expands to establishment of take-back channel, sorting, recycling
target compliance, waste prevention, eco-design promotion, and communication material,
verification of data and its reporting to the producer as well as the government/national
authorities.
They should guarantee that the collected e-waste is treated properly.
For this, PROs need to have a solid financial basis. Governments must establish a strict
authorisation process so that only reliable organisations with secure finances can receive a licence
Some PROs have a public service mission, and operate in a not-for-profit or profit-not-for-
distribution basis while others seek profit. PROs are expected to maximise environmental,
economic, and social benefits along with their operational implementation.

Considerations for successful implementation of EPR

ISWA (2014: 6-7) has listed eight key considerations for successful
implementation of EPR; of them, seven are relevant to e-waste management. ISWA
mentions that effective policy design on EPR will depend on national
circumstances, conditions. and priorities

The key considerations include:

(i) involvement of stakeholders in the development of EPR;
(ii) clear allocation of responsibilities among all stakeholders;
(iii) producer's choice for IPR or CPR;
(iv) transparency of EPR;
(v) governmental support, monitoring, evaluation and control need to be
accompanied by an effective and efficient legal framework;
(vi) ambitious and clever policy targets are a necessity:
(vii) compensation of reasonable costs for the use of municipal infrastructure is
necessary.

1. Stakeholder involvement in the development of EPR, which creates a basis for

the EPR policy and improves the acceptability and effectiveness.
2. Clear allocation of responsibilities among all stakeholders involved is an
important requirement for a legislation, which would avoid conflicts of interest
between different stakeholders involved. While producers have the primary
responsibility, all other actors in the product chain (producers, import-ers,
wholesalers, retailers and consumers), as well as all the waste management actors
(waste management collectors, recyclers) must be allocated specific responsibilities.
This allocation should be made in view of the policy objectives and product
characteristics along with clear mechanism for implementation.
3. Regarding role of PROs, it is necessary for the government to consider that producers cannot
gain an unfair advantage over their competitors or avoid their responsibilities by choosing one or
the other of different mechanisms. And, if nation legislation allows multiple PROs to compete for
the same waste stream, it should be ensured that they operate effectively together and without
jeopardising the achievement of policy targets. This point has emerged from five models -
combination of systems and financing model - applied for design incentives under the WEEE
Directive. 15
4. Transparency of EPR, which is a primary requirement in its implementation, as EPR is strongly
linked to a public service; in this manner, both, producers, and consumers can make informed
choices. This should be ensured by using different ways to comply with the legislation, for example,
reporting by producers or PROs, and regular audits by the government.
5. Governmental support, monitoring, evaluation, and control needs to be accompanied by an
effective and efficient legal framework. Governments should enforce this legal framework to close
loopholes and trace free riders. The legal framework required to include control mechanisms
including monitoring, and actions vis-à-vis producers, in case of not achieving goals and targets.
Information related compliance by producers should be reviewed in terms of the value of the
information in relation to product, its disposal, burden to provide such data and information; in
case, a PRO is implementing on behalf a producer, an accreditation process for PRO is also required.
The implementation of EPR should also be periodically evaluated by governments and, if necessary,
targets be adjusted.
[Link], and clever policy targets are a necessity. As a fundamental goal of EPR is to
increase the collection and recycling of waste, clear targets on e-waste (generation, collection,
recycling) should be specified. The targets could be qualitative and/or quantitative and could be set
for a group of products or for individual product categories.
7. Compensation of reasonable costs for the use of municipal infrastructure is necessary. The
local and regional authorities should not have any obligation to hand over collected waste falling
under EPR if their reasonable costs are not covered by producers.

Challenges in implementation of EPR for e-waste management

EPR has been adopted by the most countries due to its promising potentials for effective e-waste
management, it has been scrutinised on the following counts: legal provisions and lacuna;
governance/enforcement related challenges including institutional mechanism for carrying out
various functions, monitoring, and evaluation etc

Legal provisions related challenges

This set of challenges includes ambiguity in definitions, leaving it open to varied interpretations
of each provision.
One of the first legal concerns is, clear definition of a 'producer (its definition for avoiding
ambiguities). A clear distinction is required with regard to the definition of a producer. A producer
can be a producer of an e-product/large multinational original equipment manufacturers (OEM), or
a manufacturer who assembles an electronic product using technology, or the one who earned by
selling e-product to a consumer, or the one who produce some parts and materials which gets sourced
in production of an e-product. If a 'producer' is not defined properly, the EPR related goals and
functions remain ambiguous, creating loopholes in implementation.
Governance/enforcement related challenges

As the EPR as a concept is to be translated into a programme, the perspective of governance

typically focus on the following aspects: (i) proper guidelines for every stakeholder covered
under the legislation for legal enforcement, and compliance; (i) proper institutional mechanism
available/ developed; (iii) whether every producer's EPR plan is being examined, e.g. e-waste
collection from whom, by whom, how, its cost, compliance process, etc. are mentioned in the
guidelines; (iv) whether risks of compliance are identified; and (v) whether proper monitoring
and evaluation guidelines are provided - process, mechanism, and standardization are well-
defined, and are functioning as planned. In addition, Bhaskar and Turaga (2017: 10) mentioned
two more challenges: political will and clarity in the enforcement of EPR, and careful attention
to policy instruments - their choice as well as design - within the broad EPR framework.

Collection and recycling related challenges

E-waste collection is considered to be a great challenge as part of management.

Though the 'take-back system' encourages users for recycling and resource conservation, and
protection of environment, and human health, it has created a few challenges as part of the
EPR.
A takeback system is a complex interrelated structure that has four key com-ponents: (a) the
rules that govern the system; (b) the operational areas of collection and processing; (c)
financing of the system; and (d) how to control the flow of e-waste into and out of a
jurisdiction.

Risks of compliance and adverse consequences

For compliance, if detailed guidelines and standards are not provided for collection and recycling,
the goals of resource recovery may suffer.
The detailed guidelines related to legal compliance include the following: whether adequate
awareness exists about different stakeholders and their requirements for compliance; whether
periodic monitoring takes place, and process and mechanism for compliance are in place; in
absence of monitoring and evaluation, paper trading"" in the name of compliance may increase,
and as a result, leakage of e-waste may continue on a large scale.
'When a policy instrument targets only one of the primary stakeholders with a potential to play a
pivotal role across the product lifecycle, it poses a compliance risk'. Therefore, 'recycling subsidies,
advance disposal fees, and command and control standards and point out the impact of certain
externalities in determining the efficiency of these policy instruments
Fair cost allocation and collective efficiency, volume uncertainty, long-term contract, local
economic development, education and outreach' etc. play critical roles in legal compliance by
producers under EPR. Producers are expected to pay costs for collection, aggregation,
transportation, storage, and recycling; if these costs are not shared by municipalities or any
government agency for collection, recycling cost by the recyclers, etc., and when producers are not
incentivised in any manner, motivation for compliance is found to be lesser, especially in the
developing countries, wherein collection to recycling related operations are carried out by informal
sec- tor efficiently.
Challenges faced by PROS

PROS, on behalf of producers, are expected implement mandated EPR through a range of activities
(setting up e-waste management systems across entire value chain, compliance management), and
working with different stakeholders. The selection process and its criteria set up by producers of a
PRO is usually a challenge in itself; a PRO is selected usually for a year or two - that prevents
PROS from making long-term and deep-rooted systemic transformation efforts... The success of
PROS is dependent on the success of EPR implementation and the maturity of the e-waste sector.
Producers will need to have a long-term vision and play an enabling role in the development of
collection channels and recycling infrastructure.

The concept of PROS is not yet mainstreamed in many developing countries; because of this,
performance of PROS is usually affected, especially in terms of col- lection of e-waste. Leakage
of e-waste from or to informal sector is a very common phenomenon in a country where informal
sector is dominant. PRO being sandwiched between producers, and the government is identified
with such malpractices and get discredited in the larger context of transparency and accountability,
Some scholars argue that the difficulty in identifying producers; illegal imports of e-waste; the
existence of a large informal sector; and weak regulatory capacity pose major challenges to EPR
regulations in developing countries.

Impact of EPR

This is one of the least explored areas; there are a very few studies that has captured impact of
EPR. For example, while in many countries, informal sector is dominant. which pays for different
scraps, including e-waste items. Such dimensions have created challenges in implementation of
EPR.
Regarding the impact of EPR, research conducted by the European Commission on 36 case studies
of EPR on different waste streams in the EU revealed that in most of the benchmark cases, the net
operational costs for collection, transportation, and treatment of separately collected waste are
covered by the EPR system. The extent to which net operational costs are assumed by producers
is highly variable and depends notably on the share of organisational and financial responsibilities
of the various stakeholders, as well as on the national framework for EPR
A study by Bhaskar and Turaga (2017) examining impact of E-waste Management Rules, 2011 on
e-waste management practices, they observed that:
the EPR regulation forced the producers to take action on a few relatively inexpensive aspects of
the rules, the collection and recycling system has not been made convenient for the consumers to
deposit e-waste in formal collection and recycling centers

EPR and e-waste management in India

EPR in India was first introduced through the E-waste Management Rules, 2011, and the
responsibilities for producers were defined, such as collection of e-waste generated during
manufacturing of EEE and channelisation to the registered dismantler or recyclers; setting up
collection centres or take-back system either individually or collectively; financing and organising
a system to meet the cost involved in ESM of e-waste generated from the EoL. However, no target,
neither collection nor the recycling amount of e-waste (in weight, item-wise) was specified under
the EPR.
Experiences of EPR and take-back campaign by Nokia in 2009 and 2012

Between formal and informal operations for collection to recycling, the Nokia mobile company's
example is often quoted among the industry actors, in the broader context of EPR and take-back
systems, which could be more effective when 'brand environmental responsibility' (BER) adopts
'ecosystem approach' reasoned Singhal (2010). Nokia organised take-back campaigns for mobile
phones in 2009 and 2012, in different phases. Nokia had promised that the company would plant
a tree for every mobile handset collected, and all old phones and accessories would be recycled;
over 50 tonnes of mobiles were collected and 60,000 trees were planted. The campaign became
popular as 'Planet ke Rakhwaale' (protectors of the planet); through this community platform,
Nokia could bring and engage like- minded people together, who were willing to take steps for
environment protection, starting from old phone recycling (Singhal 2010).
Along with a take-back campaign, Nokia conducted a survey covering 6,500 respondents from 13
countries about consumer attitudes towards and behaviours regarding recycling of mobile phones.
The survey highlighted a contradiction that 74% didn't think about recycling their phones, while
72% thought that recycling makes a difference to the environment. Among 13 countries, 84% of
Indians did not consider the need for recycling of unwanted devices; 83% did not know how
mobiles are recycled, and whether or not recycled materials from them could be reused for making
new products. In this context, Singhal (2010) has identified key factor that play crucial role in the
development of a recycling ecosystem and shaping up of consumers' behaviour towards
responsible recycling, which are valid even after a decade. These findings also have influenced the
government for enacting a legislation. They include existence of possibilities, ease of acting, and
incentive for consumers in a pro-environmental way; presence of information systems for
consumers on why to act, how to act, when to act, and the benefits of the action for environment
and society at large; existing environmental awareness amongst the consumers, and momentum in
the society for environmental protection; presence of adequate recycling infrastructure; and a
regulatory framework for e-waste management.

Effectiveness of EPR post-rules, 2011 In India: roles and responsibilities of producers

The Toxics Link (2014, 2015) attempted to evaluate and analyse the roles and responsibilities of
the regulatory agencies and the producers and their assigned responsibilities, in the consecutive
years in 2014 and 2015, after two years of the implementation of the Rules, 2011. Total 50 Brands
were evaluated on the basis of the decided criteria's (action taken by producers towards fulfilling
their responsibility under the Rules) and given score. The research of 2014 was conducted on 50
producers based on secondary data (accessing their website and contacting the helplines or
customer care numbers) while the study of 2015 collected primary data (direct responses/interview
method) and used secondary data (websites, information booklets, use of social media, print,
visuals, etc. used by the producers for creating awareness).
Major findings of these reports are briefly shared here: in 2014, 17 companies earned 'bad
performance'; 15 companies 'not so good'; 11 companies 'fair performance' and seven companies
'good performance. Among them, the biggest defaulters are the cell phone companies; 17 out of
11 companies belong to 'bad performance' (Toxics Link 2014b). In 2015, 18 companies earned
'bad performance'; 15 companies 'not so good'; 15 companies 'fair performance' and three
companies 'good performance'. Like 2014, many cell phone companies fared badly. RoHS
compliance has helped companies scoring good points, though 15 companies remained on the 'not
so good' slab. Of the seven companies in 'good performance' in 2014, three of them (Lenovo,
Microsoft and Ricoh) have maintained position in this slab (Toxics Link 2015: 15).
Toxics Link (2016) conducted a survey on 'awareness about e-waste rules' in 2015, covering 2,030
respondents from five cities of India - Delhi, Mumbai, Chennai, Kolkata, and Bengaluru. 50% of
people interviewed are acquainted with the term e-waste; the lowest among Kolkata, Delhi and
Chennai cities, and highest in Mumbai city. After almost five years of the Rules, 2011, 66%
respondents had no knowledge on the rules; among the aware respondents (34% of total), 12% had
heard about the rules but did not know the details. In response to, 'who is responsible for
management of e-waste/toxic waste', most respondents gave mul- tiple answers making more than
one to all the stakeholders (government, producer, consumer) responsible - most Kolkata
respondents claimed the government to be the exclusive responsible entity.
Regarding toxicity of e-waste, Mumbai respondents know the least (almost 90% are unaware), and
all respondents of Chennai are aware. Sources of information included newspapers (34%), media
(22%), internet (16%), friends (14%), product manuals (11%), and other (2%). More than half of
the respondents (51%) hand over their toxic e-waste to kabaadiwalas, which most likely end up
reaching to the infor- mal sector with crude methods of recycling, 36% discarded to second hand
market or exchanged them for new equipment, 16% gave away to their friends, relatives or maids,
0.7% people handed them to the licensed recycler.

Toxicity and impacts on environment and human health

Toxicity of e-product and e-waste due use of hazardous and non- hazardous substances, chemicals,
and persistent organic pollutants (POPs) is at the centre. The toxicity is a manifestation of a
substance/toxin on a living organism, a tissue, or a cell; it is observed in form of cancer,
malfunctioning of nervous systems, reproduction processes, respiratory systems, etc. on the human
body. Recycling is at the focal point that links environment, and health concerns. A conundrum is
created as to whether e-waste recycling is an "economic boom or an environmental doom". From a
legal standpoint, toxicity is well-defined, but legal enforcement depends on a range of issues, such
as, design of e-product makes it easy to dissemble and less hazardous; productivity, cost, availability
recycling technology; resource efficiency; and final disposal that ensures least leaching to soil and
water to prevent health hazards.

Much e-waste is considered hazardous waste from a toxicological standpoint biodegradable and
gets accumulated in the environment: in the soil, air, water, and in living things. The pollutants of
e-waste have adverse impacts on health, especially through water sources and the food supply chain
of livestock, fish, and crops.
The e-waste that is end-treated in a landfill leads to leaching of toxic metals and chemicals into the
soil...low temperature burning causes the emission of dioxins from PVC components. Also waste
material is just dumped into nature, and in water bodies.
The end-of-life of EEE including open and manual dismantling, shredding, burning, leaching and
uncontrolled dumping directly harm the exposed workers, and reach environment through
contaminating soil, ground water, surface water, and polluting air. The e-waste that is end-treated
in an incinerator leads to emissions of GHG and mercury (ibid.).
A vast literature exists on toxicity of e-waste, covering use of different methods to document toxins
generated or released during recycling processes. There are three main groups of substances that
may be released during recycling and material recovery, and which are of environment concern:
(i) original constituents of equipment, such as lead and mercury;
(ii) substances that may be added during some recovery processes, such as cyanide;
(iii) substances that may be formed by recycling processes, such as dioxins (Lundgren 2012:
18).
Dioxins' can be released when PVC parts are incinerated at a low temperature. Similarly,
massive literature exists on toxicity of e-waste, covering use of different methods to test
leaching effects of metals since late 1990s, for example, Milli Q (MQ) water, Synthetic
Precipitation Leaching Procedures (SPLP, a mild leaching agent with no buffering), Toxicity
Characterisation Leaching Procedure (TCLP), and Waste Extraction Test (WET) (Yadav et al.
2014). Of them, most articles are laboratory-based tests and findings of a specific e-product;
very few field studies are found. A vast literature exists on toxicity of a specific e-product, such
as cell phones (feature and smart phones), PCBs (used in every e-product), computers, and so
on

Significance of recycling technique and technology in e-waste management

Recycling occupies critical space in the discourse of e-waste management, and is considered to be
the best possible solution. With proper recycling, recoverable resources are collected, which further
save other resources, such as, energy, water, and other material footprints; also boost economy.
Consequently, the reduction in landfill may result into reduction in toxic effects on environment,
and human health. Landfilling has been the least favourable waste management option, mainly
because proper treatment to e-waste reduces release of toxins; lesser the toxicity, lesser the adverse
impacts on environment, and human health.

Recycling, if done in an environmentally sound manner, needs considerably less energy than mining
ores in nature; prevents secondary and tertiary emissions; creates economically and
environmentally sustainable businesses (optimise ecoefficiency); and considers the social
implications and the local context of operations (e.g. employment opportunities, available skills,
and education etc.
I: Environmental concerns

The report of UNEP (2010) titled, Assessing the environmental impacts of consumption and
production: Priority products and materials has focused on 'how different economic activities
currently influence the use of natural resources and the generation of pollution, and looked at the
economy via three perspectives - production, consumption, and resources - in conjunction with
environmental concerns, such as, climate change, water use, toxic emissions, use of fossils for
heating, the production and use of electrical appliances is of comparable importance, causing the
depletion of fossil energy resources, climate change, and a wide range of emissions-related impacts
(UNEP 2010: 2). 97% of all life cycle waste is generated during the production of input materials
(Figure 3.2).
While elaborating impacts on environment and human health, describes toxicity from two important
frameworks: first, life cycle thinking,' or 'life cycle impact assessment' (LCIA); and second,
regulatory provisions imposed/evolved through legislations at international and national level. For
example, the Basel Convention to regulate transboundary movements of e-waste; and the RoHS
Directive applicable to EU countries, which restricts the use of lead, cadmium, mercury, hexavalent
chromium, PBB and PBDES) in new electronic devices; and a regulatory method

of total threshold limit concentrations,' which refers to use of hazardous elements and its threshold
specified under the regulatory framework of every country. The existing literature also describes
toxicity by linking it to recycling by the informal sector to large extent across several countries with
rudimentary methods; and 'design for environment' of every e-product. It is argued that if the design
of every e-product is simplified and different materials are assembled in a manner which makes
disassembly/dismantling of e-waste smoother, toxicity question could be dealt effectively. The
experiences of Guiyu of China, and Ghana in Africa represent challenges of unregulated
transboundary movements, and functioning of the informal sector leading to damage of
environment and human health to a level
of crisis.
The life cycle thinking identifies environmental impacts from the climate perspective (resource use,
global warming potential, change in the ozone layer, energy- consumption, water use, carbon foot
prints, etc.); economic (recoverable and reus- able materials metals, plastic, etc.); and EoL
solution/treatment to e-waste, i.e its recycling, final disposal and impact on environmental elements
(impacts on air, soil, and water acidification, eutrophication and pollution); and impact on human
health, such as carcinogens, mutagenic, reprotoxic, and bio-accumulative Manufacturing of e-
products have direct effect on climate change; every product has a carbon footprint and is
contributing to human-made global warming.

Production process, treatment to e-waste, and its impact on environment

Typical environmental concerns are resource use, global warming potential, energy consumption,
water use, carbon footprints, potentials for damaging ozone layer (GHG emissions), deteriorating
soil and water quality, etc. Global warming could be
calculated for the life cycle stages of a product or service based on CO, equivalent (or carbon
equivalent) emission; ecological footprints, etc. The ecological footprint can also be expressed in
units like water intensity, total material requirement, and total amount of waste. Different
environmental impacts are induced from the gen- eration of air emissions, effluents, and waste
(Table 3.1).

Mapping of environmental Impacts of a cell phone

The average energy consumption for material extraction is 23 MJ (megajoules) for one mobile
phone; 120 MJ energy is consumed during manufacturing of compo- nents ICs (integrated circuit),
capacitors, and resistors; total energy consumption for assembly of a phone is 2 MJ; and 30 MJ is
assumed as energy consumption for packaging and transportation (Yu et al. 2010: 4137). Mobile
phones contain various valuable metals (copper, gold, and silver) along with some toxic or
hazardous metals (Pb, Cd, Hg, As, Ni, and Cr).
Approximately half of the elements of the periodic table go into the produc- tion of a mobile phone
including neodymium, terbium, and dysprosium
In 2009, for 2.7 billion mobiles in use, they accounted for about 125 million tonnes CO2e, which
is just over 0.25% of global emissions (Berners-Lee 2010). 'An Apple iPhone emits 70 kg of carbon
particles and 81% of the carbon particles are emitted during its manufacturing' ([Link]).
Extraction and production of raw materials generate 80% of total greenhouse gas (GHG)
emissions, compared to 14% from mobile phone use, and just 1% from EoL treatment (quoted in
ILO 2019b: 6) (Figure 3.3).
Mapping of environmental Impacts of a computer

'Manufacturing a tonne of laptops and potentially 10 tonnes of CO, are emitted' (PACE and WEF
2019: 13). Manufacture of one computer and monitor takes 530 lbs (240 kg) of fossil fuel, 48 lbs
(21.8 kg) of chemicals, and 1.5 tons of water ([Link]. in). For a laptop computer, 'about 1,200
kg of waste is produced over its life cycle' (Miliute-Plepiene and Youhanan 2019: 16). 'Recycling
one million laptops saves the energy equivalent to the electricity used by 3,657 homes in a year?'
([Link])
The annual life cycle burden of a computer is 5,600 MJ (megajoules), however, only 34% of life
cycle energy consumption occurs in the use phase. The rest of the energy is needed for the mining,
manufacturing, packaging, and transportation processes that are required in making a computer.
An average computer is made up of over 30 different minerals (silica, iron, aluminium, copper,
lead, zinc, nickel, tin, selenium, manganese, arsenic, and cadmium) which are non-renewable
resources; they are mined and extracted from the earth. 500 million PCs comprise about 2,872,000
tonne of plastics, 718,000 tonne of lead, 1,363 tonne of cadmium, and 287 tonne of mercury
(Puckett et al. 2002: 437). Manufacturing of one desktop computer takes 245 kg of fossil fuels, 22
kg of chemicals, and 1,500 litres of water (Kuehr et al. 2003). Reduction of waste is achieved
through reuse and recycling. From a climate perspective, GHG emissions are avoided with proper
waste treatment and disposal. An estimate says reuse and recycling of 40 personal computers may
lead to avoidance of CO, emissions from 2.1 barrels of oil consumed (Agarwal and Mullick
2014:8).
Amount of fossil fuels used to produce a computer are equivalent to approximately nine times the
computer's weight. Approximately half of the elements of the periodic table go into the production
of a mobile phone including neodymium, terbium, and dysprosium. (UNEMG 2017: 140).
The environmental impact/footprint of the primary metals (precious and special metals) production
is significant, which are mined from ores in which the precious and special metal concentration is
low. In mining, wastewater, sulphur dioxide is created, and energy consumption and CO, emissions
are large. For example, to produce one tonne of gold, palladium, or platinum, CO2 emissions of
about 10,000 tons are generated. The annual demand for gold in EEE is some 300 tonnes [in the
year 2007] at average primary generation of almost 17,000 tons CO, per tonne of gold mined,
which leads to gold induced emissions of 5.1 million tons in total' (UNEP 2009: 10).
Mapping of environmental impacts of a CRT monitor

There were 83.3 million CRT monitors by 2002 in the market across the globe; they begin to replace
by LCD (liquid crystal display) monitors.
There are 14 processes involved in producing, using, and disposing of a CRT. The major
components of the complete CRT monitor are the tube, plastic casing, and associated PWB
assemblies. The glass components contain approximately
70% lead oxide. The total number of inventory items for the CRT profile was 770); of them, almost
274 chemicals were classified as potentially toxic. Overall, 18,000 MJ of energy was reported per
CRT monitor produced within the manufacturing stage; roughly 87% of this can be attributed to the
glass manufacturing energy alone. During production, carbon monoxide released from the
production of LPG was the top contributor at 22%, followed by nitrogen oxides (9%) from
electricity gener- ation in the use stage, and by arsenic (9%) in the production of lead that is
eventually used in the CRT glass, and phosphorus (6%) and fluorides (4%) (Socolof et al. 2005).
'The average 14-inch monitor uses a tube that contains an estimated 2.5-4 kg of lead. One CRT
television or computer monitor can contain 4-8 pounds (1.8-3.6) of lead'

Linkages between resource recovery and improvement in environment

For special and precious metals, the environmental footprint of recycling is much smaller than for
primary production; for example, aluminium recycling uses only 1/20 of the energy required for
primary production. The environmental impacts per kilogram for the production of precious metals
(silver, gold, platinum, and palladium) is higher than for base metals (iron, copper, aluminium, lead,
and nickel); yet recovery of both types of metals may yield a commercial profit, which may generate
a new scope of work for the new generation. An example of PCBs is presented here - as a resource
and as a hazardous object.
Among environmental concerns, saving CO2 emission is one of the major considerations.
Therefore, harvesting the resources from used e-products substantially less carbon-dioxide
emissions than mining in the earth's crust is preferred as part of e-waste management. According to
WorldLoop,
every tonne of e-waste collected and recycled; 1.44 tons of CO, emissions are avoided...with the
954 tons of e-waste collected and recycled by WorldLoop's projects, 1,374 tons of CO, emissions"
have been avoided (That's 734,759 m3 of CO2, which is slightly bigger than the Statue of Liberty).

E-waste recycling chain

E-waste recycling chain comprises of four main steps: (i) collection; (ii) pre-pro- cessing (sorting
classification, separation/manual dismantling or disassembly," de- pollution); (iii) end-processing
that includes physical and chemical processing; and (iv) refining process. Every single step in the
recycling chain is closely interlinked in both an upstream and downstream direction (Table 3.3).
The first stage of recycling is collection from consumers once the EEE have reached their EoL.
This phase is crucial, as this ensures that the collected e-waste is not mixed with others; and less
dependent on technical solution, and highly influenced by socio-economic factors, such as level of
awareness and disposal by the users awareness and integrity of vendors who provide least
cannibalised e-waste, and so on

During second stage, de-pollution process includes one or several shredding pro- cesses aimed at
reducing the size of devices and elimination of potentially hazardous components. Once reduced in
size, the shredded components in e-waste undergo mechanical sorting, where different sorting
technologies are applied.

Regardless of the approach and the chosen technology, in the pre-processing stage four groups of
materials are extracted: (i) hazardous materials (e.g. batteries), (ii) valuable components, which
could be reused/resold on the market after dismantling, (iii) valuable recyclable materials (copper,
aluminium, plas- tics) that will be sold for further material recovery, and (iv) residues - non-
hazardous materials (ceramics, some plastics etc.), that are not suitable for recycling. This fraction
is likely to be disposed of in landfills or incinerated.

During the third stage - physical recycling, usually size reduction takes place through
disassembling, dismantling, chopping, shredding, crushing etc. Also, physical separation of ferrous
and non-ferrous parts takes place vis-à-vis magnetic parts, current connecting parts, electro-static,
etc. For chemical recycling, different methods are employed, such as, magnetic method for
recovering ferrous fractions (iron, nickel, and cobalt), gasification, melting process (pyro-
metallurgy), hydrometallurgy," and bio-metallurgy

During refining processes, plastics, fuels, oil-based resins, metals, glass, metha- nol, filler materials,
and phenolic composites are separated. Non-recyclable materi- als usually end up in waste
incinerators or landfills. For metal recovery, physical recycling is practiced across the world
(Debnath et al. 2018). The metal recovery involves various thermal and chemical treatments
depending on their merits and demerits. Thermal treatment avoids the liquid effluent disposal
problems associated with wet chemical extraction methods. Thermal incineration combined with
pyro- metallurgical treatments is applied in commercial use for metal recovery from PCBs
(Chatterjee and Kumar 2009:899).
Mainly three kinds of substances are released during recycling:
(i) the substances used in manufacturing of electrical and electronic equipment;
(ii) those substance are used in recycling process (auxiliary substances);
(iii) by-products, which are formed during the transformation of primary constituents.
The by-products are: fly ashes, fine particles, fumes, waste water, etc; of them, fly ashes, fine
particles, and fumes are transported to other places via air while waste water becomes leachate/
effluent and contaminate surface and the sediments contaminate ground waste.

Recycling and risks

If not properly managed, hazardous substances may pose significant human health and
environmental risks. Toxic substances can be found within the following types of emissions or
outputs: (i) leachates from dumping activities; (ii) particulate mat- ter (coarse and fine particles)
from dismantling activities; (iii) fly and bottom ashes from burning activities; (iv) fumes from
mercury amalgamate "cooking," de-soldering and other burning activities; (v) wastewater from
dismantling and shredding facilities; and (vi) effluents from cyanide leaching and other leaching
activities. Among them, most researchers have expressed concern about manual disassembly, and
acid-leaching operations1+ for value of valuable components from wires and cables, CRTs, and
PCB.
A particular hazard associated with the disassembly stage is the possibility of accidental release and
spillage of hazardous substances upon breakage of the shell, such as mercury, which is found within
light sources as well as switches. The primary hazards of mechanical treatment methods are
associated with the size reduction and separation steps, which can generate dusts from plastics,
metals, ceramics, and silica. Open-air storage raises concerns regarding the possibility of lead and
other substances leaching out into the environment. In addition, with lack of access to running
water, toxins are transmitted orally via people's hands when eating (quoted in Lundgren 2012:18-
20).
Toxics Link (2014a, 17) report has mentioned potential hazards of e-waste recycling by informal
sector in India. While breaking and removal of copper yoke CRTs, lead, barium, and other heavy
metals leach into groundwater. During PCB disordering and removing computer chips, air emission
of these substances remains in air for long time; and while processing dismantled PCBs, that is,
open-air burning to remove the metals, tin and lead contaminate immediate environment including
surface and ground waters, and brominated dioxins, beryllium, cadmium, and mercury emissions
take place. For treating chips and other gold-plated components, chemical stripping method (using
nitric and hydrochloric acid), along river banks Hydrocarbons, heavy metals, brominated
substances, etc. are discharged directly into river or left on the banks, which acidifies the river
destroying fish and flora.

II: Human health concerns

E-waste, toxicity, and its impact on human health

76% of workers in informal recycling operations in India suffer from respiratory ailments like
asthma, bronchitis, choking, coughing, irritation, breathing difficulties and tremors among
others...this is primarily due to primitive and polluting methods of processing e-waste, lack of safety
measures, awareness, and negligence.
Complex processes are employed for recycling of e-waste in India, such as, manual disassembly,
heating PCBs to recover solder and chips, acid extraction of metals from complex mixtures, melting
and extruding plastics, and burning plastics to iso- late metals. Mixtures of concentrated nitric acid
and hydrochloric acids are used for the extraction of gold and copper respectively. Various volatile
compounds of nitrogen and chlorine are known to be emitted during such processes. The heating of
PCB for de-soldering and removal of chips exposes workers to fumes of metals, particularly those
in solder (often lead and tin), and other hazardous substances that can be potentially released. Such
practices often exacerbate pollution by creating hazardous chemicals and additional pollution

Incineration

Incineration is a process of destroying waste through burning. The gases released during the burning
and the residue ash are often toxic, especially when incineration, or co-incineration of e-waste with
neither prior treatment nor sophisticated flue gas purification. Studies of municipal solid waste
incineration plants have shown that copper, which is present in PCBs and cables, acts as a catalyst
for dioxin formation when flame retardants are incinerated. These BFRs when exposed to low
temperature (600-800°C) can generate extremely toxic PBDDs and Polybrominated Furans. PVC
is also found in e-waste in significant amounts, which is highly corrosive when burnt and also
induces the formation of dioxins; its incineration also leads to the loss of valuable elements that can
be recovered if sorted and processed separately.

Open-air burning

Open burning is used mostly for waste disposal, at relatively low temperature; this is far more
polluting than controlled incineration process. Inhalation of open fire emissions can trigger asthma
attacks, respiratory infections, and cause other problems such as, chest pain, coughing, wheezing,
and eye irritation. Chronic exposure to open fire emissions may lead to diseases such as emphysema
(lung condition that causes shortness of breath) and cancer. Open-air burning of PVC releases
hydrogen chloride, which on inhalation mixes with water in the lungs to form hydrochloric acid,
which may lead to corrosion of the lung tissues, and other respiratory com- plications. Often open
fires burn with a lack of oxygen, forming carbon monoxide, which poisons the blood when inhaled.
The residual ash becomes airborne, and is dangerous if inhaled

Landfilling

This is one of the most widely used methods of waste disposal; it is well known that all landfills
leak. The leachate (cadmium, lead, and mercury) often contains heavy metals and other toxic
substances that contaminate groundwater resources. Even state-of-the-art landfills, which are sealed
to prevent toxins from entering the ground, are not completely tight in the long-term.
There are three major concerns regarding landfills and its impact on environment are its leach,
vaporization effects, and its proneness to uncontrollable open fires and release of toxic fumes. Older
landfill sites and uncontrolled dumps pose a much greater danger of releasing hazardous emissions.
From the PCBs and CRT monitors, lead is found to leach from their glasses. The land filled BFR
plastics or plastics containing Cadmium, both PBDE and Cadmium may leach into soil and
groundwater. The land filled condensers emit hazardous polychlorinated biphenyls. Besides
leaching, vaporization is also a concern in landfills - volatile compounds (mercury or di-methylene
mercury) are released through vaporisation
Informal recycling operations, toxicity, and health hazards in India

In India, informal sector treating e-waste is one of the focal points of the debate on resource
recovery, adverse impact on environment as well as human health. Two major arguments are:
because of rudimentary recycling methods are employed by the informal sector players health
hazards are rampant; resource recovery is much lesser than the scientific methods, advanced
technology and infrastructure for recycling e-waste; and higher proportion of waste directly going
to landfill, contaminating soil and water with high level of heavy metals. In order to measure
contamination, trace elements method is used wherein soil, air dust, and human hair are collected
from e-waste recycling sites (a recycling facility and backyard recycling units), and concentration
of various elements (including metals) are traced/ measured

The collection, storage, and transportation of e-waste are though need safety features in order to
avoid environment and health hazards, but these are not much dis- cussed in the existing literature
vis-à-vis recycling methods and resource recovery. In the existing literature, dismantling and
segregation of different parts - electronics, glass, plastics, and others - are considered to be relatively
safer processes

In the existing literature, impact on environment and human health mentioned as process (release
of toxins), end result (type of toxins) or in generalised manner; either of them is rarely quantified
through macio studies/ statistics. E-waste and toxicity in India were reported as early as in 2002.
The E-waste recycling and disposal operations found in China, India, and Pakistan are extremely
polluting and likely to be very damaging to human health. Examples include open burning of plastic
waste, exposure to toxic solders, river dumping of acids, and widespread general dumping.
(Puckett et al. 2002: 4) BAN/Puckett (2005) repeated similar concerns in the following study
conducted in 2005, saying,
the situation becomes worrying in situations where studies in China and India have shown that
unregulated disposal of such wastes can contaminate soil, groundwater, and air, as well as affect all
those involve in their processing. as well as the nearby communities.
Release of toxins is reported by the Greenpeace report (2005: 5) as, 'street dust samples from the
recovery units in Delhi detected alarmingly high concentrations of lead, cadmium, mercury, tin,
organochlorines, Chlorinated Benzenes, PBDEs, and Polychlorinated Namphalenes (PCNs) and
Polychlorinated biphenyls.' The PBDE and Polychlorinated biphenyls are known BFRs; they are
much higher in concentration at the estates where e-waste is treated, compared to the ones from the
resi dential or other commercial areas where significantly less concentrations of metal residues were
detected (Toxics Link 2019b: 8).
Another study, measuring trace elements, conducted in Bangalore and Chennai in December 2006,
collecting samples of air, soil, and hair of male workers engaged in recycling process, from storage
areas outside the main building of an e-waste recycling facility and backyard recycling sites in the
slum areas. The study revealed that though informal e-waste recycling technology extracts valuable
metals rapidly, the recovery is inefficient and incomplete. Generally, manganese (Mn) and copper
were high in all the soils. High level of bismuth (Bi), copper (Cu), indium (In), lead (Pb), stannum
(Sn), stibium (Sb), and zinc (Zn) were found in all the soil samples of Recycling sites. Silver,
Cadmium, and mercury (Hg) concentrations were higher in soils; presence of mercury in recycling
sites indicate that the crude extraction meth- ods of gold using mercury are contributing to the
higher mercury contamination in the soils of the slum areas. Higher concentration in air of
chromium, manganese, carbon monoxide, copper, indium, stannum, stiumb, thallium (Tl), lead, and
bismuth from recycling sites compared to city area. Generally, zinc concentration in human hair
was the highest, followed by copper, lead, and manganese.