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E-waste management (MT) in India: Challenges and Opportunities

The booming electrical and electronics market coupled with increased consumerism and rapid technological obsolescence has made India the third-largest producer of e-waste. Safe management of e-waste, which has huge negative impacts on public health and the environment, is a great challenge. The issue is further complicated by ambiguous legislations, dominant informal sector, poor infrastructure, lack of technology-based operations, and technically skilled human resources. However, there is flip side that despite being hazardous, e-waste offers an opportunity for extracting precious materials through urban mining. There exist opportunities of creating business value by deploying new technologies with zero effluent for e-waste management. This article presents an overview of the current status, challenges, and possible solutions for e-waste management in India.

Technological advancements and scalability in electronics, communication, information technologies, and consumers’ affordability have made EEE (Electrical and electronic equipment) an indispensable component of modern living. The waste arising from end-of-life electronic and electric products referred to as waste from EEE (WEEE) or simply e-waste, is one of the fastest-growing waste streams in the world today. As a result, e-waste management has started gaining considerable attention in recent times, rendering it a major challenge of the modern era. The Global e-waste Monitor 2020 has estimated 53.6 million tonnes (MT) of e-waste generated globally in 2019 with a growth of 21 in the last 5 years, of which only 17.4 was recycled . This report stated that Asia generated the highest quantity of e-waste in 2019 at 24.9 MT, followed by the Americas (13.1 MT) and Europe (12 MT), while Africa and Oceania generated 2.9 MT and 0.7 MT, respectively. The electronics industry in India is expected to grow at a CGAR of 16.6 , from the US billion USD 215 in FY19 to a whooping US billion USD 540 in FY25; making India one of the fastest-growing markets for electronics and the third-largest electronic waste generator in the world after China and the USA. The amount of e-waste generated in India in the past few years is depicted in the table

Year wise production of e-waste in India

Year

E-waste generation (MT)
2015 1.97
2016 2.22
2017 2.53
2018 2.86
2019 3.23

E-waste management in our country, as is the case in most Southeast Asian countries, is dominated by the informal sector with estimates of more than 90 of the waste being processed in this sector. The disposal of end-of-life (EoL) EEE products has negative externalities in terms of impact on human health and the environment. The Ministry of Environment and Climate Change (MoEFF&CC) had informed the National Green Tribunal (NGT) that in the year 2016, 95 of e-waste in India is recycled by the informal sector and scrap dealers who unscientifically dispose it. Booming electronics market, growing degrees of e-waste from all sectors of the economy, low collection rates, environmentally risky disposal/remedy techniques, and large informal recycling industry, pose a serious challenge to e-waste management eco-system in India.

E-waste legislation in India
The genesis of e-waste legislation is not very old in India. The Environmental Protection Act introduced in 1986, had no specific mention of e-waste. Subsequently, the management of WEEE, was included under the Hazardous Waste Act 1989, 2000, and 2003. Finally, e-waste management and handling rules (2011) were enacted and came into force in May 2012. In the act a concept of Extended Producer Responsibility (EPR) has been introduced, which is a widely used policy approach for waste management across the world. India’s e-waste (Management & Handling) rules, 2011, use EPR as the underlying framework. Thereafter, e-waste (Management) rules, 2016 and recently e-waste (Management) Amendment rules, 2018 have been introduced by MoEFF&CC. These rules have further strengthened the existing rules. Schedule-I of these rules includes 21 products. The collection, storage, transportation, segregation, refurbishment, dismantling, recycling, and disposal of e-waste are governed as per these guidelines.

In pursuance of these rules, many companies got registered with Central (CPCB) and State Pollution Control Boards (SPCB) for the collection, dismantling, and recycling of e-waste in the country. As per the CPCB data of December 2021, there are 468 registered e-waste recyclers/dismantlers spread throughout the country with their total capacity of approximately 1385932 MTA. Although the number of registered recyclers/collectors has mushroomed throughout the country, the major portion of e-waste is still flowing to the informal sector.

Key stakeholders in an e-waste management system
The e-waste management system is contrastingly different from other waste streams due to the wide range of players involved in the entire value chain. The complexity of the stakeholders’ base is also a major challenge because of their overlapping roles. The e-waste value chain can be categorized into three broad stages- e-waste generation, e-waste collection, e-waste treatment, recovery and final disposal. A list of major stakeholders of the value chain are government bodies, producers , manufacturers, retailers, consumers, ULBs, informal waste collectors, recyclers, refurbishers, dismantlers, etc. with their responsibilities is as shown in the table:

Major stakeholders in the e-waste ecosystem and their responsibilities

Stakeholder Roles/Responsibilities
Government Agencies

(Central and State )

The Government lays the regulatory framework for e-waste management. The implementation of these regulations is also handled by the Government agencies.
Producers, Manufacturers Under EPR-based legislation, they organize, finance and operate e-waste take-back system, either individually or collectively, through PROs.
Producer Responsibility Organisations (PROs) Operate e-waste take-back systems on behalf of producers/OEMs and ensure collected e-waste is transported to appropriate treatment centres and properly treated.
Retailers Retailers seldom participate in colletion of e-waste. They might have a take-back scheme for some EoL products.
Consumers Individual and bulk consumers (Government and businesses) are the main determining factor in the fate and route of e-waste management. Disposal behaviour is widely dependent on level of awareness and availability of infrastructure and systems.
Waste collectors and aggregators (Kabari-walas, scrap dealers) The informal collectors dominate the e-waste market in India. They are responsible for collection of waste the collection (door-to-door, municipal dumpsite).
Recyclers

Both formal and informal recyclers are present. They have the responsibility of recycling and recovery of fraction.

Formal recyclers: Industrial Recyclers are often capital intensive, operating mechanized shredding and sorting or largescale material recovery facilities.

Informal Recyclers: They carry out pre-processing and rudimentary material recycling. Inefficient techniques used by them contribute to the adverse effect in human health and the environment.

Refurbishers Refurbishers operate in the second-hand markets. They process the reusable items for secondary use and thus play an important role for a sound waste management.
Civil Society and development organisations They play an important role in bringing awareness about the e-waste issue. They help in knowledge-transfer, stakeholder interaction, etc. to tackle the overall e-waste problem.

Challenges in e-waste management
The e-waste management ecosystem that is currently flourishing in India, is replete with challenges at levels of policy and regulation, health and environment safeguards, operational issues, dominance of informal sector, financial constraints, supply chain logistics and others. There are several inadequacies and mismatch between regulatory regime, operational aspects and the ground realities which need immediate attention to be appropriately plugged.

Some notable issues demanding immediate attention are highlighted here:

Discrepancies in estimates of e-waste. The per capita generation of e-waste is lower in India, in comparison to the developed countries. With economic growth, purchasing power will increase and owing to its large population and illegal waste dumps, our country could face a crisis very soon . There are multiple sources of e-waste: individual households; bulk consumers; commercial establishments; manufacturers; retailers etc. The e-waste (Management) rules of 2016, define e-waste as electrical and electronic equipment (EEE), whole or in part, discarded as waste by consumers (individual or bulk) as well as rejects from manufacturing, refurbishment, and repair processes (ref). Schedule I of the e-waste Management rules, 2016 has divided WEEE into two broad categories, the waste from Information, technology, and communication (ITEW) and the waste from Consumer electrical and electronics (CEEW). Though there are multiple types of EEE waste, currently only 21 subcategories of EEE are classified under the legislation. Internationally the e-waste Monitor accounts for 54 different categories of e-waste.

Besides issues in classification, the data collection and data management related to e-waste generated each year, is also problematic. Such discrepancy is a major reason due to which the accountabilities of producers under EPR scheme is not completely enforced. Also, Indian estimates are based on the producers who are registered by CPCB under extended producer responsibility authorization (EPRA), which is far less than the actual numbers; the data from imports is also not recorded. Therefore, the actual figures of e-waste generation are likely to be far higher than the current estimates.

Lack of awareness in different players across the e-waste value chain. There is lack of awareness in the most of the stakeholders regarding the potential hazards, proper disposal mechanisms and regulatory framework for managing e-waste. Most consumers are either completely unaware or have less knowledge about the hazardous nature of e-waste components or the penalties for improper disposal. The EPR mandates the producers to raise awareness about e-waste, however they are mostly reluctant to take on such responsibility. The role of urban local bodies is also not very clear in the existing policy that leads to shrugging of responsibilities by ULBs in the urban localities. Very few cities have dedicated collection depots, or drop-off points set up by the ULBs. Bulk consumers usually follow the route of auction without proper checks on the end fate of the waste being disposed. The institutional consumers often do not maintain a record of the end-of-life equipment that is being disposed. The informal sector overlooks the environmental and health safety and indulges in highly inefficient methods to extract valuables from e-waste.

The general incognisance about health and environmental hazards, role of each stakeholder in the e-waste ecosystem, provisions of e-waste rules and responsibility of the producers must be checked to strengthen the complete ecosystem of e-waste management.

The dominance of the informal sector. It is a well-known that currently e-waste, like other waste streams, are being aggregated and handled predominantly by informal sector. Reasons such as lack of awareness about the hazardous nature of e-waste, non-availability of suitable formal collection mechanisms, traditional practices of not separating waste streams etc., further complicate the matter. As a result, more than 95 of this waste are being managed in the unorganized markets by the informal sector. Recycling establishments in the informal recycling sector are not located in industrial areas and typically have a scrap yard setup, where workers handle toxic e-waste components under hazardous working conditions. Their abysmal investment in infrastructure or safety measures allows for having a high-profit margin for informal employers. The low-cost operations are the major force for a thriving informal sector.

Dominance of informal sector in the complete value chain of e-waste.

The Informal sector is not recognized in the current regulatory framework, despite their exceptional reach and access to waste. They are able to pay more competitive prices for e-waste collection as they have negligible capital investment in safe disposal of e-waste. As a result, large volumes of waste leaks into the informal markets and consequently, due to scarcity in available EEE waste items, making the formal e-waste recycling business viable and profitable is a big challenge.

The weak formal recycling industry. Multiple studies and report indicate that India’s recycling facilities are majorly underutilized due to poor channelization of waste to formal sector (ref). The existing collection and take-back mechanisms are prone to leakage. The initial cost of setting up a recycling facility is often high, and it is a great challenge to make a business successful with high-end investments in superior technologies. As a result, except for a few, professional recycling enterprises in India are limited to pre-processing of e-waste, with crushed e-waste containing precious metals being shipped to smelting refineries outside of India. Many of the registered formal recyclers are in fact just dismantlers. The non-availability of low cost technologies for recycling, difficulties in sourcing sufficient quantities of e-waste and lack of technical training are some of the major challenges of the formal sector. The government should support research towards the development of technologies for WEEE management, environmental monitoring, and final disposal methods.

Future directions

Adoption of technologies for e-waste recycling. E-waste is comprises of a variety of materials, including structural metals, engineering plastics polymers, and parts containing precious metals like copper, gold, silver, nickel, cobalt and Lithium and rare earth elements. For example, Printed Circuit Boards (PCB) contain a variety of precious metal resources, such as gold, silver, palladium, and copper, which must be recovered in an environmentally appropriate recycling method. Presently, due to rudimentary recycling methods, only a fraction of such metals are recovered in India. Extraction of other valuable components requiring high-end technology are being exported to foreign smelters. Some Indian recyclers have attempted to import expensive foreign technologies and plant machinery; however, they could not sustain due to a high running cost, low volume of input materials, and the inability of the technologies to address local needs.

Development of indigenous technology can provide efficient, cost-effective, and simple-to-implement solutions. Several R&D projects have been initiated at national institutions in India. Public R&D labs such as Centre for Materials for Electronic Technologies (CMET), National Metallurgical Laboratory (NML), Bhabha Atomic Research Centre (BARC), Central Institute of Petrochemical Engineering and Technology (CIPET), National Environmental Engineering and Research Institute (NEERI) and several others have developed technologies for processing of PCBs, Li-ion batteries, EoL CFLs, EoL silicon solar cells, hard disk drive magnet/ NdFeB magnetic scrap, knocked off plastic from e-waste and many other components of WEEE. Technologies developed and demonstrated at an industrial scale by Indian R&D organizations on recycling of PCBs, plastics, lithium-ion, rare earth metal recovery should be made available to the entrepreneurs in the formal sector to create a sustainable eco-system of the recycling business. The government may promote and provide financial support to organizations that are investing heavily in the research and development and generation of Intellectual Property in technologies for managing WEEE. Co-creation of technologies, wherein government, startups, producers, and PROs can jointly develop technologies and recover the cost through technology transfers. Government schemes may be introduced for the commercialization of the indigenous technologies to the recycling industry, for which Government can pay some cost of the capital equipment and do a low cost transfer of technology, to promote such indigenous technologies and affordable processing plants in the country.

Technology intervention can help in bringing e-waste to formal markets.

Identification of e-waste recycling as industry. Metal stocks are perpetually depleting and are not able to keep pace with ever growing demands arising due to economic developments. Being mindful of the future shortage of metals and environmental concerns, large economies have now started adopting circular economy approach which facilitates resource re-utilization through recycling and protecting the overall environmental ecosystem. Extraction of metals, from EoL products, widely known as urban mining, provides the opportunity to ensure access to materials at a far lower cost. To ensure such self-reliance, it is necessary that e-waste recycling is employed at industrial scale. All benefits provided to an industry through various policy interventions on manufacturing, tax benefits, SEZ etc. should also be provided to e-waste recycling units. Policy incentivization such as tax/GST benefits on output from Electronics or Lithium-Ion battery recycling especially for critical metals and materials – like cobalt, lithium carbonate, graphite, nickel, copper, etc. should be provided to recyclers. The recently launched scheme for Promotion of Manufacturing of Electronic Components and Semiconductors (SPECS) by MeitY also proposes a financial incentive to boost domestic manufacturing of electronics and attract large investments in the electronics value chain. This scheme can be useful for recyclers who are working towards reclamation of electronic components including e-waste.

Integrating the informal sector. The informal sector has a distinct advantage over the new players in the market. But owing to the risky operations, there is a need to revamp the role of this sector. The informal sector has much better and easier access to the material because of their wide network spread across the country and thus the flow of materials occurs freely between different parts/regions. A large population derives their livelihood from this sector, which requires zero or minimum investment but can ensure economic sustainability in urban spaces. However, as evident, this carries with itself a socio-economic and ecological impact. Considering the role they play currently, it is advantageous as well as practical to think of an emerging system that will be inclusive and will define the role of this sector, but eliminate the hazards of their operations. This will help in keeping the collection and pre-processing costs at a minimum but ensure optimal recycling efficiency.

With concerted efforts of government and other stakeholders, integration of informal sector with formalized e-waste recycling and creating a sustainable system is very much needed. Appropriate policy /rules mechanism, low-cost technology transfer, adequate skilling and training to use that technology can empower the informal workers to put their expertise of waste collection to better and safer use. The concept of eco-park which will be based on shared space and infrastructure would be very useful, as the waste aggregation can be done at a designated space and the formal entities like PROs and recyclers can seek services of the informal workers. The strengthening of the repair and reuse market will also be important for efficient management of e-waste and circular economy.

Inventorisation of e-waste. Globally it is recognized that there is a lack of reliable data on the generation, collection, import, and export of e-waste, and management schemes for handling it. Environmental issues and trade associated with e-waste at local, transboundary, and international levels have driven many countries, particularly developing countries, to introduce control mechanisms.

Hazardous and Other Wastes (Management and Transboundary Movement) rules, 2016 (HOWM Rule, 2016), stipulates provisions for maintaining records and filing annual returns on hazardous waste generation and their management. In 2019, CPCB issued the “Guidelines for Preparation of Inventories on Hazardous and Other Waste Generation and their Management”, for reliable incentivization of hazardous and other waste which would aid in planning and designing waste management policies and programs in the country. These guidelines also concur with the directions of the Hon’ble National Green Tribunal and include standard guidelines and protocols based on scientific fundamentals for the preparation of the inventory. There is a prescribed reporting mechanism to CPCB through State Pollution Control Boards (SPCB)/Pollution Control Committees (PCC). However, several gaps were identified in the 2019 report such as underreporting, a mismatch between the quantities reported for recycling/utilization/disposal of HW (inter-state movement of HW) by the sender and receiving states/UTs, the difference in details of recyclers/utilizers, improper utilization of the prescribed format and others.

There is impending need to create Pan-India technology driven inventory management system to ensure that a product is tracked end-to-end from its manufacturing /imports to final EoL collection and recycling.

Such inventory management would be helpful in enforcing EPR regulation, e-waste credit system, technology based recycling and circular economy.

Strengthening the policy framework. The policy framework guiding the management of WEEE should be strengthened to address all issues ranging from production, trade, recycling to final disposal. The lack of separation between e-waste and secondhand items is a result of the Harmonized System (HS) codes used in product importation. Because the HS codes for waste and second-hand equipment are the same, stopping the flow of e-waste entering the country is nearly difficult. Therefore, it is critical that ‘used’ material, which is freely imported, be regulated and that information is provided via HS codes so that this material can be tracked in terms of quantity, places of use, and disposal. The existing e-waste policy enforcement mechanism needs to be reviewed for course correction.

Public policy may have a greater role to play than the current e-waste regulations, in enabling better markets for e-waste. ‘Right to Repair’ rules should be introduced for legal backing for the consumers to avert ‘forced obsolesces of products’. The repair economy that could function synergistically with the new products market will help in increasing the life of used goods and diverting them from the waste stream. Original Equipment Manufacturers (OEMs) to embrace secondary material seamlessly in the primary production line. Manufacturers should also be encouraged to introduce refurbished products, in the market. The demand for refurbished products in tier 2 and tier 3 cities is significant. Secondary products developed after refurbishing can tap this huge potential market. Creating clusters of refurbishing, dismantling and segregation facilities in various ‘hot spots’ in the country could be helpful.

Mainstreaming e-waste management in urban planning and development. The robust collection of WEEE from various sources is probably the most important component in the e-waste value chain. Formalization and integration of e-waste collection system in urban planning and management is very important. Special collection drives and awareness campaigns can be conducted in each district jointly by Producers, retailers, PROs and district administration to ensure safe collection and channelization of e-waste to recycling units.

Eco-friendly recycling parks may be established in public private partnership model to ensure technology driven eco-friendly recycling. e-waste auction by the bulk user should channelizes the waste to recycling parks to ensure its processing by authorized dismantlers and recyclers. The informal sector with intense networks of the collection can be optimally utilized for collecting e-waste under one roof. These parks can serve as plug-and –play models for formal recyclers. Such settings can be very useful for collaboration of the formal and informal sectors, where they can work together for seeking better revenue from the collected WEEE. The recovery of precious materials from such facilities, would ensure the financial viability of the recycling industry. The central and state govt can extend their support to eco-parks, till they become financially viable.

E-waste management is a massive challenge for developing countries such as India. This is becoming a huge public health and environment degradation issue, and is exponentially increasing by the day. It is a complex ecosystem with multiple stakeholders and daunting challenges. Manufacturers, producers, consumers, policy-makers, refurbishers, dismantlers, collection centers, and recyclers with roles to play in waste reduction, value retention, increasing life expectancy of a product and its ability to be repaired, reused and recycled. E-waste recycling presents enormous opportunities, in terms of monetary benefit and resource efficiency. By assuring efficient and cost-effective recycling, landfills can be minimized and emissions can be substantially reduced.

The recycling industry need to be positioned as a profit-making industrial activity. It is important to note that if the monetary benefits of e-waste recycling are communicated appropriately, it would encourage many enterprises to enter this space and adopt suitable technologies, not only for the environment and health benefits but also for a profitable business.

The policy instruments and action plan should be designed by factoring all the life stages of EOL products and e-waste; and by careful consideration of the economic aspirations, social benefits, and environmental challenges of the country.

The article is co-authored by Dr Nidhi Thakur, technical consultant at the Office of the Principal Scientific Adviser.

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