A proposed framework by the Centre for regulating e-waste in India has upset a key link of India’s electronic waste collection system and threatens the livelihood of thousands of people.
Electronic waste, or electronic goods that are past their productive life and old parts, is largely handled by India’s vast informal sector.
Spent goods are dismantled and viable working parts refurbished, with the rest making their way into chemical dismantling units. Many of these units are run out of unregulated sweatshops that employ child labour and hazardous extraction techniques. This electronic detritus contaminates soil and aggravates plastic pollution.
To address all of this, the Environment Ministry brought the E-waste (Management) Rules, 2016, which introduced a system of Extended Producer Responsibility (EPR) compelling makers of electronic goods to ensure a proportion of the goods they sold every year was recycled. They are expected to maintain records annually demonstrating this. Most companies however did not maintain an in-house unit in charge of recycling and this gave rise to a network of government-registered companies, called producer responsibility organisations (PRO) which acted as an intermediary between manufacturers of electronic goods and formal recycling units and were technologically equipped to recycle end-of-life electronic goods safely and efficiently.
Certified proof
The PROs typically bid for contracts from companies and arrange for specified quantities of goods to be recycled and provide companies certified proof of recycling that they then maintain as part of their records. Several PROs work on consumer awareness and enable a supply chain for recycled goods.
As of March, the Central Pollution Control Board (CPCB) has registered 74 PROs and 468 authorised dismantlers, which have a collective recycling capacity of about 1.3 million tonnes.
The Ministry estimated 7.7 lakh tonnes of e-waste to have been generated in 2018-19 and around one million tonnes in 2019-20 of which only a fifth (about 22% in both years) has been confirmed to be “dismantled and recycled”.
This May, the Ministry issued a draft notification that does away with the PROs and dismantlers and vests all responsibility of recycling with authorised recyclers, only a handful of which exist in India.
Recyclers will source a quantity of waste, recycle them and generate electronic certificates.
Companies can buy these certificates equivalent to their annual committed target and thus do not have to be involved with engaging the PROs and dismantlers. This update to the 2016 e-waste rules is in draft mode and open to public comment until July 31.
Several PROs have mailed their objections to the Ministry arguing that dismantling a fledgling system was detrimental to the future of e-waste management in India.
“On the one hand, the number of categories of e-waste has been increased from 21 to 95 and on the other, PROs and dismantlers have been done away with. Nobody knows what is the trigger for such a move,” said Shobha Raghavan, Chief Operating Officer, SAAHAS Zero Waste, a Bengaluru-based PRO.
Under the new rules, recyclers will likely establish their own supply chains, and companies will no longer bear any responsibility for ensuring that their product is recycled.
Five years of investing and putting in place a system to collect and channel waste were under threat as 25,000 to 30,000 people were employed in this sector, Ms. Raghavan said.
“The PROs provide checks and balances and this is necessary because in the current system, there is a lot of unauthorised recycling and we are an important element in the chain to ensure verifiable recycling,” said Pranshu Singhal of Karo Sambhav, a Delhi-based PRO.
The Centre has not explained its rationale for dismantling the existing system in its draft notification. Calls to officials in the Ministry were not returned. However, one person in the Ministry, familiar with e-waste policy, on condition of anonymity, told The Hindu that a final policy was yet to emerge.
‘Improve accountability’
The new rules, he said, would improve accountability because it would rely on an electronic management system that would track the material that went in for recycling with the output claimed by a recycler when they claimed GST (Goods and Services Tax) input credit. “Currently, the entire system is not remunerative for recyclers, which actually do the job of recycling. This current system incentivises them to invest in a dependable supply chain that will collect and recycle waste,” he added. “The current system managed by PRO isn’t always reliable as there have been several instances of double-counting (where the same articles recycled once for one company are credited into the account for multiple companies). He said that the CPCB was still testing such a system though it wouldn’t automatically solve the problem of routing all electronic waste from informal channels to formal channels.
Mr. Singhal added that the proposed rules shifted responsibility for controlling e-waste away from producers of goods to recyclers. There were too few recyclers across India and predominant in the big cities and in the absence of dismantlers, goods would now have to travel greater distances to be recycled. “All over the world e-waste system recycling works because of the PRO and dismantler network. In the absence of a system to encourage consumers to recycle, the true cost of collecting and recycling waste is hidden and even more, will accumulate within informal channels,” said Mr. Singhal.
