Module 5: MOVING TOWARDS HORIZONS

E-Waste Management in India

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Role and scope of statistics and data driven actions:
*With mandate for all the stakeholders of maintaining records and updating
time to time, and filing annual returns, have created a huge opportunity and a
possibility of a strong database, inventory of the e-waste.
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*Every stakeholder’s performance could be monitored and evaluated, as and

when required, based on the available database.
*These reporting items on e-waste are limited, some essential data would not
be created/available on other important aspects of e-waste management, such as,
extent of resource recovery and improvement in efficiency, secondary market
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scenario, jobs/employment created and other economic benefits.

*Data may be collected on collection, dismantling, and recycling but in absence
of due processing the collected data, the monitoring by regulatory authority may
not take place or remain weaker.
Legal compliance by producer, through PRO
*Under EPR, producers pay for entire reverse supply chain, clarity on funding
mechanism is required.
*If producer cannot implement all the responsibilities mandated under the
Rules, performing these duties through an authorised PRO is an opportunity to
achieve objectives of the Rules, as it sets up entire value chain (from collection
to recycling e-waste)/ecosystem.
*Though the concept of PRO as an entity is an integral part of EPR, which is
mainstreamed across the world; Indian stakeholders covered under these Rules
are still not well aware of it.
*The partnership between a PRO and a producer is critically based on principle
of cooperation, on long term basis;
*A couple of PROs, dealing with e-waste in the country have started sharing
their work experiences, and are articulating challenges based on their work

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experience.
*A PRO has to build a holistic system/ecosystem that goes beyond ‘compliance’
in its simplistic form.
*PRO’s varied tasks include quality of e-waste collected, ensuring safety
measures for storage and transportation, fair pricing, recycling and recovery,
etc.
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*Creating and maintaining database for such varied tasks and activities become
necessary for a PRO which demands commitment and efficiency.
*reduction in illegal e-waste collection and recycling requires due diligence in
such long-term processes. Usually, a producer engages a PRO on annual,
contractual basis.
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*Most bulk consumers are not aware of PROs and their role in e-waste
management;
*those who are aware about PROs, have not started disposing e-waste through
PROs,
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*Because of lack of coordination and gap of communication between

government entities.
Regulatory body – institutional mechanism, capacity, and effectiveness
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*CPCB and SPCBs perform several functions, assessment of pollution – air,

waste, soil; monitoring of source specific pollution of air, water, soil;
monitoring of ambient air and water quality; development and enforcement of
standards; hazardous waste management and dissemination of information;
conducting mass-awareness programmes improving quality of air and water,
disposal of different types of wastes (hazardous, electronic, bio-medical,
municipal solid, etc.).
*These bodies have been engaged in monitoring of pollution levels,
contamination, etc.
*there exists very thin mechanism for enforcement at the CPCB and SPCB,
with a staff small in number.
*This creates huge challenges for their effective functioning, especially
monitoring, reporting noncompliance, taking necessary punitive actions as per
the legal provisions, ensuring compliance ordered by the Court/Tribunal, and so
on.
*The process of maintaining records for compliance with the regulation’s
requirements would be expensive in addition to the administrative costs to every
key player.

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*The authorised producers and dismantlers/recyclers are already struggling to
compete with informal sector players.
*There is a likelihood of weak compliance on the count of maintaining records
of different types;
*the regulatory authority would have difficulty in monitoring with thin
mechanism, without putting IT solution in place.
*An e-portal for monitoring by the CPCB has been in process, as mandated by
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the NGT. However, it is argued that instead of centralised database, the process
needs to be state-centric for better performance at state level.
*At present, every authorised recycler is required to recycle a maintain a
minimum quantum of (300–500 tonnes e-waste) per annum.
Instead, if small scale recycling/dismantling units are authorised, the informal
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sector units could be formalised this way, and transportation of collected e-
waste would reach state-based recycler.
*Tracking e-waste within a state by the regulator would be easier, small scale
unit (becoming informal to formal unit) would be able to treat e-waste in small
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quantities and reported, and consequently,

*how much e-waste residues (plastic, glass, etc.) other than the metals
recovered go to the landfill could be quantified.
*At present, every authorised recycler is required to recycle a maintain a
minimum quantum of (300–500 tonnes e-waste) per annum.
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*Instead, if small scale recycling/dismantling units are authorised, the informal

sector units could be formalised this way, and transportation of collected e-
waste would reach state-based recycler.
*Tracking e-waste within a state by the regulator would be easier, small scale
unit (becoming informal to formal unit) would be able to treat e-waste in small
quantities and reported, and consequently,
*how much e-waste residues (plastic, glass, etc.) other than the metals
recovered go to the landfill could be quantified.
Awareness raising responsibility of different stakeholders and their
performance – producers, state governments, regulatory body

*Different aspects of awareness on e-waste were discovered with studies carried

out in different cities
*The state governments and ULBs are made responsible for undertaking
initiatives for e-waste management.
*With a special reference to Ahmedabad Municipal Corporation (AMC), a
study has observed that most ULBs have no financial mechanism in place,

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which hinders e-waste collection activity.
*The AMC had a tie up with an authorised recycler in 2017;
the recycler did not get anticipated quantum of e-waste.
‘Ahmedabad procures around 400 tonnes of electronic waste [every month]. Of
this, only 13% is recycled,’ (Patel 2017).
*A study on Pune city reported that its solid waste management system has to
bear an extra 30% of load of e-waste not being separated, collected of recycled
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by the government institutions

Coordination among different government agencies and missions

*Different ministries are involved in e-waste management;
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for example, MoEFCC is a nodal ministry, MeitY has taken up various
measures
including awareness related, resource recovery related (through C-MET),
role of Ministry of Science & Technology in innovation, etc.
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*The strategy paper by MeitY and NITI Aayog (2019) on resource efficiency
has mentioned involvement of three missions
(Clean India, Digital India, and Make in India) – these are opportunities for e-
waste management.
*concrete actions like budget/fund allocation, launch of a specific programme
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for e-waste management, upscaling C-MET experiment – from laboratory to

commercial scale for recycling unit, etc. awaited.
*Some cities (e.g. Ahmedabad, Pune) have entered into association with an
NGO for waste collection, including e-waste, and have created a channel from
e-waste collection to recycling.
*Disposal of e-waste by bulk consumers, specifically government agencies
require changes in General Finance Rules (GFR).
*There are practical problems as against the Ahmedabad and Pune city is, a
commissioner, in charge of waste management, faces issues of e-waste disposal
and the revenue earned.
*It is observed6 that if a municipal corporation ties up with a PRO for e-waste
disposal, the revenue earned and associated financial auditing ask for changes in
the present set up.
* It is also observed that the District Collector asks for an Executive
Order/guidelines for e-waste disposal.
*For example, the Department of Science and Technology, Government of
Gujarat has issued a notification in 2014 regarding e-waste disposal by the
government agencies.
*This notification could be considered valid even after the Rules, 2016 were

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enacted. However, the ULBs expressed a need for specific guidelines.

II Economic concerns

*Economic concerns include opportunities for CE through the existing/newer

business model;
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*building up infrastructure supported with a cadre of skilled workers;
using green technology;
dealing with market gaps and barriers;
*need for employment and skill building for repair and refurbishing units;
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*by fostering formal informal sector partnership.

Business opportunities
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*E-waste is a value creating waste, mainly through the process of recovery of

materials, and selling of recovered/secondary materials.
*Two opportunities created through the Rules –
i)start-up for dismantling/recycling of e-waste;
ii)PRO and creating ecosystem for upscaling innovative and cohesive
initiatives for e-waste management.
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*There is a huge potential for job creation in the value chain of e-waste,
including waste collectors, aggregators, repair shops, refurbishers, warehouse
keepers, and transportation business.
*The e-waste sector has the potential to create around 6 million jobs, perhaps in
just a few years. The opportunity for a startup is linked to the legal provision –
all state governments are made responsible for facilitating e-waste management
related various activities including creating eco parks, providing infrastructure,
capacity and skill building of dismantling/recycling units, and
workers engaged in e-waste collection and recycling for start-ups
*Financing for start-ups is a challenge. Recycling, its infrastructure, capital
investment, inflow of e-waste, circular value creation across downstream and
upstream, etc. challenges have been mentioned
* Another set of challenges is whether or not a state government would be able
to maintain e-waste focus in every infrastructure created for industrial purpose
is to be seen.

Fostering formal-informal partnerships

*Informal sector has a very organised network for collection to recycling of e-

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waste as well as selling of secondary materials.
*This sector has flourished on market-driven requirements and strategies,
especially the entire value and trade chain, subsidising the cost of formal
operations across the chain.
*Studying functioning of the informal sector players, their functioning, skills,
management abilities, infrastructure, sustaining and expanding the network of
various players in the entire value and trade chains, etc. and learning from them
could be a value addition.
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*While focusing on collection and treatment (refurbish/dismantle/recycle) of e-
waste, the existing regulatory framework has not taken cognisance of the
informal sector in the country, dealing with e-waste and controlling entire value
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chain – from collection to recycling.
*As the regulation has not taken cognisance of unorganised sector, it does not
entail measures for rehabilitating those persons who are engaged in the e-waste
management operations in unorganised manner.
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*By not recognising existence of informal sector players, these Rules are also
overlooking critical aspects of the objectives, ‘how informal operations –
collection to dismantling/recycling activities would be reduced.’ Making
informal sector and its range of activities for the trade chain as ‘illegal’ through
regulatory measures would not deal with problem of dominance of informal
sector in e-waste management
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*Consequently, not paying adequate attention to health hazards, damage to

environment, working conditions, wages, and social security of workers, etc.
also would be continued until a suitable business model is developed.
*The existing Rules also need to harmonise with Labour Laws on this regard
While focusing on collection and treatment (refurbish/dismantle/recycle) of e-
waste, the existing regulatory framework has not taken cognisance of the
informal sector in the country, dealing with e-waste and controlling entire value
chain – from collection to recycling.
*While focusing on collection and treatment (refurbish/dismantle/recycle) of e-
waste, the existing regulatory framework has not taken cognisance of the
informal sector in the country, dealing with e-waste and controlling entire value
chain – from collection to recycling.
*As the regulation has not taken cognisance of unorganised sector, it does not
entail measures for rehabilitating those persons who are engaged in the e-waste
management operations in unorganised manner.
*By not recognising existence of informal sector players, these Rules are also
overlooking critical aspects of the objectives, ‘how informal operations –
collection to dismantling/recycling activities would be reduced.’ Making
informal sector and its range of activities for the trade chain as ‘illegal’ through

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regulatory measures would not deal with problem of dominance of informal
sector in e-waste management
*Consequently, not paying adequate attention to health hazards, damage to
environment, working conditions, wages, and social security of workers, etc.
also would be continued until a suitable business model is developed.
* The existing Rules also need to harmonise with Labour Laws on this regard
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Employment and skills related concerns

*Few persistent challenges for e-waste management, ‘including but not limited
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to, employment opportunities for youth and women, re-skilling and upskilling,
establishing sustainable enterprises, green jobs and transitioning from formal to
the informal economy
*No learnings from the informal sector regarding such skills, ability to trade
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recovered material in the domestic market, need for recycling infrastructure,

related projects that can help in building up small scale industrial units, etc. are
not taking place.
*These are identified as barriers for moving towards formal economy, and
resulting in losses to the formal economy.
*The Skill India promoting institutions and initiatives (such as NSDC,
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SWAYAM) can play trend-setting roles in this scenario.

*With skill upgradation and job creation processes, this sector can be very
promising for economic growth, fulfilling requirements of safe environment as
well as OSH, and rights of workers.

III: Environment concerns

*Environment concerns include a range of issues from design, production to recycling
(lifecycle to end-of-life cycle) and resource use (e.g. of carbon, fossils, water, energy, etc.);
reduction of RoHS or totally substituting the use of hazardous substances; adopting green
technology; safe disposal and alternatives to landfilling; techniques to identify and reuse
components and materials (e.g. plastics, glass) as integral part of e-waste management. Such
envisioning indicates potentials for safe environment and human health.

Adopting green technology

Green technology focuses on minimisation of energy, and use of natural resources, right from
the design stage to the recycling stage. In terms of environment protection, two very
important concerns – green technology and alternatives to landfill (as this is the only option
for disposal of e-waste) – have remained underused in the

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existing regulatory framework.

Improvement in product design unheeded

*One of most important policy principles of the EPR for e-products is to promote
environment improvements, especially in the area of design of the products, production
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systems, and final disposal.
*The area of products includes factors such as product material, design, and expected life.
The product design for environment/ sustainable development, for instance, reducing or
totally substituting
the use of hazardous substances, adopting environment friendly technology, techniques to
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identify smooth dismantling/recycling, and reuse components and materials, including
plastics and measures to promote the use of recycled plastics in new products, etc.
*This is an opportunity to promote improvements, if included in the regulatory framework;
eventually, varied concerns of entrepreneurship/start-ups/
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business, viable technological solutions, and benefits of capitalist economy could be

well elaborated, and their direct linkages could be established CE as well as
environment and health protection.
*The ‘E-Waste: From Toxic to Green initiative by Chintan organisation could
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serve as a model to help other countries recycle e-waste and fight poverty. This
model of handling e-waste is claimed to be highly replicable due to its low cost, it
can be adopted by other cities, and countries where e-waste involves significant risk
to workers, communities and the environment.

Recycling and disposal of residues related issues partially addressed

*Recycling capacity has been increasing through increase in number of formal units
since 2011. This is seen as an opportunity for greater resource recovery/efficiency,
building database on recycling processes, etc.
*Though the number of authorised recycling units have increased, final disposal of e-waste in
environmentally sound manner is a significant challenge for India, especially in the context of
dominant presence of informal sector for e-waste collection to the recycling, selling of sec
ondary materials, and limited availability state-of-art technology and infrastructure
for recycling (capacity of recycling), and its sustainability.
*The Rules, 2016 assume that greater e-waste collection would lead to greater

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recycling and recovery of resources; in this context, mandating ‘recycling target’ shall
be useful.
*As number of authorised recycling units have increased manifold under
the Rules, opportunity is created for scientific way of recycling, increasing resource
efficiency, reducing adverse impact on human health and environment, and so on.
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*As against this opportunity, a couple of problems/ challenges are elaborated for low
rate of recycling of e-waste in India.
*recycling charge is dependent on multiple factors including but not limited
to the cost of procurement from multiple channels, cost of development of
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channels, logistics cost, ecosystem development costs as well as returns from
recycling which could be positive or negative.
*Such situations mostly results into ‘cherry picking – whereby only the positive
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value fractions are recycled – is rife. Negative value fractions, such as CRT TVs or
lamps, are not found attractive, and therefore not accepted by many recyclers,’

1. Material composition of electronics is changing with technological advances,

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over time, resulting into lesser amount of recovery and intrinsic value of recovered materials
after recycling of e-products/e-waste, thus affecting economics
of recycling.
*Recyclers and producers agree that monitoring and control are essential.
Recyclers want monitoring to ensure more producers are financing formal
recycling, and there is a crackdown on informal recycling; producers want monitoring to
ensure recyclers meet standards and are not engaged in paper trading.
2. Recycling facility cannot be generalized, as composition of every e-product is
different from the other. Many Indian recycling units have witnessed failure,
as they started recycling unit with latest technology and huge investment;
as against that, the e-waste flow and economics of recovered material was
skewed.
3. ‘Employing effective recycling technologies for e-waste may require significant
upfront capital expenditures, which may not be justified for private entities
in the absence of certainty around sourcing of enough quantities of e-waste.
Also, these markets suffer from information barriers.’ For example, learning from the

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informal sector is not taking place, low awareness and lack of reliable information affect
functioning of recycling activities.
4. Some critical aspects of recycling/micro-management of recycling to be
addressed, such as, optimising recovery and product specific method for optimum recovery;
infrastructure and technology required for product specific dismantling/recycling and capital
required for a start-up; sustainability of a dismantling/recycling unit based on quality and
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quantum of e-waste received, resources recovered, and selling of recovered/secondary
material, and so on.
*While comparing the WEEE Directive and the Rules, 2016, has
articulated two major challenges for treating e-waste – first, rapid technological
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advances (including 3D printing) make it necessary to keep up with the fast progress
and develop constantly new recycling processes. Second, more and more chemical
processes may take over because the e-products become a more and more complex mix of
materials.
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*These points require proper guidelines, suitable infrastructure,

future planning and readiness to bring about necessary changes in different ways of
e-waste management.
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IV: Recycling culture/recycling society

*The recycling culture is a civil society centric concept and a requirement, beyond
the regulatory framework, wherein all the stakeholders remain the same/not distinctly
categorised.
*Role of awareness in enhancement of e-waste collection, recycling, and resource recovery
has been well established. Realisation of the 6Rs is an opportunity that can change the
existing scenario of e-waste. Academic courses started on SWAYAM and upscaling through
many more educational institutions engaging in academic courses, research, and activities
would be highly appreciative effort towards realising this concept among the audience,
especially students/ youngsters who believed to be in large number as users of e-products.
*The present vicious cycle of ‘Consume–Collect–Recover–Dispose’ is considered
as a model in practice. This is found to be inadequate based on the argument that it results in
unbridled accumulation of e-waste in the environment.
*As awareness and knowledge on the subject tends to determine their recycling behaviour
‘recycling culture’ requires deeper thinking including role of different social factors, and how
to mainstream the concept of recycling society.

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