Analysis of Draft E-waste Management Rules

In Context 

The core changes proposed by the Draft E-waste Management Rules require careful deliberation with all the relevant stakeholders before the Rules are finalised.

• Last month marked a decade since the E-waste (Management and Handling) Rules came into effect in India.

Major proposed changes 

•  Recycling certificates  :
  • One major change is the introduction of a market for e-waste recycling certificates.
• Targets 
  • 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. 

• Steering Committee powers

• Introduction of a Steering Committee to oversee the “overall implementation, monitoring, and supervision” of the regulations.
  • It 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.” 

• Other positive changes 
  • Expanding the definition of e-waste, more clearly specifying the penalties for violation of rules, introducing an environmental compensation fund based on the ‘polluter pays’ principle, and recognising the informal waste workers.

Issues 

• The proposed market for e-waste recycling appears unrealistic. 
  • 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.

• If the regulatory targets were to create a vibrant market for recycling, the existing formal and informal players would have to play a crucial role. 
  • In light of this, the complete silence on regulating registered collectors, dismantlers, and producer responsibility organisations is puzzling. 

• In addition, the informal sector accounts for a vast majority of e-waste processed in India. 
  • Most e-waste policy debates have centred around the integration of the informal sector into the formal systems. 
  • The proposed regulations, however, place the responsibility of such integration on the State governments without specifying what the incentives are for them to do this.
• Steering Committee
  • There is a lack of representation in the Committee. 
    • The Rules propose the Chairman of the CPCB as the Chairperson of the Committee, which would include representatives of the Environment Ministry, the 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.

Way Forward

•  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. 
  • This is important because the technological complexity and cost could vary by component.

• We need better implementation methodologies and inclusion policies that provide accommodation and validation for the informal sector to step up and help us meet our recycling targets in an environmentally sound manner.
• Streamlining the informal sector will ensure better management practices for handling e-waste and it will also aid in environmental protection, improve the health and working conditions of labourers and provide better work opportunities to over a million people. 
• 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.

[Q] Enumerate the problems and prospects of Electronic-Waste (E-Waste )in India.