Electronic waste or E-waste is any waste that comprises of all types of electrical and electronic equipment that has or could enter the waste stream. It includes TVs, computers, mobile phones, white wares (refrigerators, air conditioners, washing machines, stoves, etc.), toys, toasters or any household or business item with circuitry or electrical components with power or battery supply. These wastes contain substances like Polychlorinated Biphenyls (PCBs), lead, mercury, cadmium, Brominated Flame Retardants (BFRs), etc., which are detrimental to human health and environment. Laws to manage e-waste have been in place in India since 2011, mandating that only authorised dismantlers and recyclers collect e-waste.
However, majority of the e-waste (90%) generated in the country ends up in the informal sector which recycles and dismantles the electronics flouting all the regulations and standards on environmental safety and human health. The problem of E-waste in India is also compounded by the illegal dumping from developed countries.
The most recent amendment is the Draft E-waste Management Rules, 2022 which shall come into effect in 2023. The following challenges can be seen with these rules:
- 1.The first challenge is the introduction of E-waste market that appears to be unrealistic. The rules introduce a market for e-waste recycling certificates. The draft rules state that producers of e-goods have to ensure that at least 60% of their produced e-waste is recycled by 2023. This shift from collection rate targets (which set targets for the collection of e-waste as a percentage of the quantity of products sold by weight in the market in the previous year) in the current Rules to recycling rate targets in the proposed Rules appears unrealistic.
- 2.Based on European experience, the regulators face more difficulties in monitoring and enforcing recycling targets than the collection targets. But the present draft is silent on whether the rules will apply to the aggregate weight of e-waste or to every component of an e-product.
- 3.Large-scale recycling of e-waste is still in its infancy in India. Most of the recycling of valuable material is carried out within the informal sector using inefficient and unsafe technologies. Also, the technical feasibility and commercial viability of different recycling technologies and approaches for e-waste components is being worked upon in India. Hence, a target to recycle 60% of the e-waste generated in 2022-23 appears too optimistic.
- 4. The government has to focus on existing formal and informal players if it wants to create better recycling facilities. But the draft rules are silent on regulating registered collectors, dismantlers, and producer responsibility organizations.
- 5. The proposed regulations do not specify the incentives for State governments for carrying out the integration of the informal sector into the formal systems. B
- 6. The other major change is the introduction of a Steering Committee to oversee the “overall implementation, monitoring, and supervision” of the regulations. This Committee, for example, has the power to decide on the product-wise “conversion factor” that determines the value of the recycling certificate, specify how the environmental compensation fund could be utilised, resolve disputes, and “remove any difficulty in smooth implementation of these regulations.” While such an institutional mechanism could provide more certainty in implementation, there is lack of representation in the Committee. For instance, there is no representation from science/academia and civil society organisations.
The need of the hour is a proper implementation of the Rules which ensures sustainable production, environmental safety, resource conservation and incorporates all the stakeholders concerned in efficient and sound management of e-waste.