March 26, 2023, Sunday

12 noon – 1 pm

• India is the third largest generator of e-waste after China and USA.
• The new e-Waste Rules which came into existence in 2022 will be implemented from 1^st April 2023.
• The rules have surprisingly been revised just within 6 years. The environment policy, which was made in 2006 is yet to be revised even after 16 years.
• Our sequence has not been right. We should have policy first then law & then its implementation. Instead, we started with the law and then its implementation and after some decades came up with a policy.  
• Segregation and then proper collection are very important & has to be taken through. Very often, batteries are thrown along with the municipal waste as a dry waste. The waste must be then cleverly segregated further.
• There should be a manual or guidance as to how various useful things can be recovered from the e-waste. Agencies naturally may be interested firstly in what they know and secondly what can be done at minimum cost for maximum profit and not bother with the rest. 
• The net residue will be much lower in the present situation where knowledge & guidance about such matter is lacking.
• There are some gaps in the policy, which need to be filled. 
• The Rules say that the Central Pollution Control Board (CPCB) will oversee that the consumption of hazardous. However, this is not in their domain. For this R&D institutions/industry must be involved.
• CPCB, SPCB, local urban bodies, bulk consumers have been involved. But the individual consumer is the biggest bulk consumer. Until any buyback scheme or incentive is given to them, they will not be tempted to give to a registered recycler or collector. 
• In the collection process, RWAs are more important than urban local bodies. They need to be involved more. Urban local bodies along with RWAs should try to target individual consumers.
• Ministry of Environment should create a separate department for this rather than putting all the responsibility on CPCB. 
• Instead of “Rules”, the word “Guidelines” should be used so that people accept them easily and try to adopt it. However, there is a risk of guidelines not being taken as seriously as rules are.
• There cannot be a single collection strategy throughout India. Different strategies and approaches are needed especially in the low-income group and economic weaker section colonies. There should be a robust mechanism for addressing this issue.
• Recycling targets are given for various manufacturers. There should be some checks & balances in place to ensure that the recycling targets are met with in-situ waste that is generated in India or generated from the products of that manufacturer.
• Right to repair strategy needs to be incorporated in electrical and electronic gadgets by putting a mandatory clause for the manufacturer. This is very essential. Sustainable, long-lasting spares and components should be used. 
• A collection chain mechanism needs to be established for the household generator. 
• There should be different strategy for urban, semi urban, rural areas similar to that for municipal solid waste. 
• In India we have economy mostly dominated in unorganized sector. Different strategies should be there to address waste management from the unorganized sector and rural areas.

• The rules should also cover the unauthorized manufacturers and generators.
• It should be responsibility of the generator i.e., individual or bulk generators like offices. There should be proper collection & processing system of e-waste.
• The definition of generator or bulk generator should be added in the new rules. They should have their responsibilities defined. 
• e-waste is also included in the domestic hazardous waste. But there is no linkage between them, which leads to confusion. 
• Only three municipalities are disposing their hazardous domestic waste: Indore, New Mumbai & Chandigarh.
• The manufacturer also becomes a generator, if there is no quality control in e products. The old products become e waste. 
• Control with rationalization is required. 
• Capacity building is important. We do not have the capacity to collect e-waste; only 25% is being collected. The government should be a role model for citizens. 
• All stake holders should be involved in formulating rules.
• Legislation is important and welcome, but practicality is missing in the new rules.
• Unlike the 2016 rules, the 2022 rules expressly introduced provisions related to environment compensation and prosecution under section 15 of the Environment Protection Act (EPA) 1986. Environment compensation can also be imposed on an entity which aids or abets the violation of the 2022 rules. This widens the scope of imposing environment compensation. 
• For creating vibrant recycling market, the possibility of regulating the role of e-waste collection centres, producer responsibility organization and dealers under Rule 2022 may also have been explored since they also, play a significant role.
• Large scale e-waste recycling is still in its infancy stage. Most of the recycling of valuable material is carried out within the informal sector using inefficient and unsafe technologies.
• The existing formal and informal players would have to play a crucial role in recycling. Considering this, a silence of draft on regulating registered collectors, dismantlers, and producer responsibility organisations is puzzling.
• Informal sector accounts for a vast majority of e-waste processed in India. 
• Most e-waste policy debates have centered around the integration of the informal into the formal systems. The proposed regulations place the responsibility of integration on the state governments without specifying what the incentives are for them to do this.
• There is lack of representation in the Steering Committee. The Rules propose the chairman of the CPCB as the chairperson of the committee, which would include representatives of the environment ministry, electronics and IT Ministry, and the associations of producers and recyclers. But it is surprising that representation from science/academia and civil society organisations is not deemed appropriate.
• At a time when the technical feasibility and commercial viability of different recycling technologies and approaches for e-waste components is being worked upon in India, a target to recycle 60% of the e-waste generated in 2022-23 appears too optimistic. 
• If the Ministry and the Central Pollution Control Board (CPCB) decide to go ahead with recycling targets, they should come up with guidelines on how the regulated entities must demonstrate compliance with the targets.
• Experience from European countries suggests that recycling targets would likely be much more difficult for the regulators to monitor and enforce compared to collection targets. 
• To capture the global value of materials in e-waste and create global circular value chains, use new technology to create service business models, better product tracking and manufacturer or retailer take-back programmes.
• The environment compensation system, which has been brought into the picture. However, the law of natural justice has not been followed when incorporating EC. 
• Further modifications of the new Rules may still be needed. 
• e-waste has valuable components so it’s not finding its way to landfills compared to other solid waste.
• Recycling of e-waste should be done in a very scientific way. This is possible only if there are technically qualified recyclers. So that it does not pollute the environment. 

Participants

Mr Paritosh Tyagi

Dr Anil Kumar

Dr SK Gupta

Dr M Dwarakanath

Mr RN Jindal

Mr Pradeep Khandelwal

Mr Neeraj Tyagi

Mr Lovekesh Chandra

Dr S Sharma