Ashok Lavasa: Address the missing link in e-waste recycling

EPR places primary responsibility on producers, alongside consumers and municipalities, to build a financially sustainable recycling ecosystem. Yet, many stakeholders struggle with EPR certification due to inadequate planning. EPR must be integrated into company accounting to meet mandated goals and enable a viable e-waste system in India. It is also a key part of corporate ESG mandates.

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Our growing burden of e-waste: India’s rapid digitalization, urbanization and use of electronics have led to a surge in e-waste. In 2023-24, we generated around 3-4 million tonnes of it, making India the world’s third-largest producer. This could rise to 14-15 million tonnes by 2030. 

Yet, less than 30% is formally recycled; most is handled by the informal sector using hazardous methods like open-air burning and acid leaching, releasing toxins like lead, mercury and brominated flame retardants. 

These practices pollute air, water and soil, while severely impacting the health and life expectancy of informal workers. Estimates suggest India loses more than ₹80,000 crore every year in critical metal value due to the use of rudimentary extraction techniques in informal recycling. Almost an equal amount is estimated to be lost annually in tax revenue, as most informal recycling is cash-based.

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First introduced in 2011 through the E-Waste Management and Handling Rules of 2011, the concept of EPR was strengthened by rules notified in 2016, which set more stringent targets for collecting end-of-life products, simplified the EPR authorization process and extended the idea to plastic waste. 

The 2022 revision has set clear obligations for producers. It requires producers to recycle a proportion of the electronic and electrical equipment they produce, starting at 60% in 2023-24 and increasing to 80% by 2027-28. Compliance requires buying EPR certificates from registered recyclers through an online portal managed by the Central Pollution Control Board. 

These certificates verify the volume of e-waste processed. Producers can also earn refurbishing certificates for efforts to extend product lifespans, reducing future recycling targets.

Failure to meet EPR obligations can result in fines, licence suspensions, import restrictions or market bans. Beyond regulatory penalties, non-compliance stalls the growth of formal recycling infrastructure and sustains reliance on the informal sector, with the attendant worries of improper waste handling. Beyond exposing workers to unsafe conditions, it derails circular economy goals and increases India’s dependence on virgin materials, including critical minerals.

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The challenges: Apart from the dominance of the informal sector and all its health and environmental hazards, many producers remain unaware of their EPR responsibilities or see compliance as a cost rather than a duty, leading some to skirt their obligations. Small and medium enterprises (SMEs) face particular difficulties, as limited awareness may leave them unprepared for EPR costs, straining their finances.

A vital yet often overlooked aspect of EPR is the need to make financial provisions for recycling. The 2022 Rules set a minimum recycling fee of ₹22 per kg. This floor price helps formal recyclers operate safely, adopt advanced technologies and scale up. Delays or underpayments can stall projects, deter investment and push recyclers into informal-sector practices. 

Underfunded EPR schemes at companies also risk fraud and missed targets, weakening the system. While producers face penalties for non-compliance, the broad impact includes threats to public health and the environment. Adequate funding, however, supports the shift that India needs.

Auditors play a critical role in ensuring EPR compliance. The EPR fee provisioning should be treated as a statutory liability, with audits verifying adherence to minimum pricing norms and flagging shortfalls for immediate action. Regulators are enhancing oversight through real-time digital tracking, third-party audits and tougher penalties. These measures aim to close loopholes, ensuring that producers fully meet their obligations and support a robust recycling ecosystem. Failure to make provisions for EPR fees violates statutory requirements and misrepresents the producer’s financial position.

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Cycling forward: The EPR idea is an extension of the ‘polluter pays’ principle because the waste that needs recycling has been produced for use and it is both unjust and unsustainable for the producer not to share the burden of proper collection and re-use. Producers must treat EPR fee provisioning as an essential part of their financial plans, adhering to minimum pricing norms.

Strengthening formal recycling infrastructure and integrating informal recyclers into the formal system could improve compliance and environmental outcomes. Public awareness campaigns aimed at producers and consumers could clarify EPR responsibilities and promote proper e-waste disposal. By blending regulatory enforcement, financial discipline and stakeholder collaboration, India can address the missing link in e-waste recycling and pave the way for a sustainable circular sub-economy.

The author is former finance secretary and former secretary for environment & climate change, Government of India.