A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

India’s E-Waste Rules and Their Impact

on E-Waste Management Practices
A Case Study
Kalyan Bhaskar1 and Rama Mohana Rao Turaga2
1
XLRI-Xavier School of Management, Jamshedpur, India
2
Public Systems Group, Indian Institute of Management Ahmedabad, India

Keywords:
Summary
environmental regulation
e-waste India, like many other developed and developing countries, has adopted an extended
extended producer responsibility producer responsibility (EPR) approach for electronic waste (e-waste) management under
(EPR) its E-waste (Management and Handling) Rules, 2011. Under these rules, producers have
India been made responsible for setting up collection centers of e-waste and financing and
product take-back
organizing a system for environmentally sound management of e-waste. In this article, we
waste management
use the implementation of these rules in Ahmedabad in western India as a case study
to conduct a critical analysis of the implementation of India’s Rules. Interviews of main
Supporting information is linked stakeholder groups, including a sample of regulated commercial establishments, regulatory
to this article on the JIE website agencies enforcing the Rules, informal actors involved in waste collection and handling,
as well as publicly available information on the implementation constitute data for our
case study. Our results indicate that while there has been an increase in the formal waste
processing capacity after the implementation of the Rules, only 5% to 15% of the total waste
generated is likely channeled through formal processing facilities. While the EPR regulation
forced the producers to take action on a few relatively inexpensive aspects of the Rules,
the collection and recycling system has not been made convenient for the consumers
to deposit e-waste in formal collection and recycling centers. Based on our findings, we
argue that Indian EPR regulation should go beyond simple take-back mandates and consider
implementing other policy instruments such as a deposit-refund system. An important
implication for developing countries is the need for careful attention to instrument choice
and design within EPR regulations.

Introduction adopted or are planning to adopt EPR as a policy framework. In-

dia’s E-waste (Management & Handling) Rules, 2011 (“Rules”
Extended producer responsibility (EPR) has been a widely
from hereon), which came into force in May 2012, use EPR
used policy approach for waste management across the world
as the underlying framework. Previous research argues that in
(see Ongondo et al. 2011; Herat and Agamuthu 2012). Par-
developing countries, factors such as large informal sector in
ticularly in the context of electronic waste (e-waste), many
waste processing, illegal import of e-waste, and weak regulatory
countries, including several developing countries, have either
capacity make it difficult to implement EPR (e.g., Akenji et al.

Conflict of interest statement: The authors have no conflict to declare.

Address correspondence to: Rama Mohana Rao Turaga, Public Systems Group, Indian Institute of Management Ahmedabad, Wing 6G, IIMA Old Campus Vastrapur,
Ahmedabad, Gujarat 380015, India. Email: [email protected]; Web: https://faculty.iima.ac.in/mohant/

© 2017 by Yale University

DOI: 10.1111/jiec.12619 Editor managing review: Reid Lifset

Volume 00, Number 0

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 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

2011; Manomaivibool and Vassanadumrongdee 2011). In this Extended Producer Responsibility Design and
context, it is important to understand the implementation of Implementation in Developing Countries
India’s e-waste Rules and the impact of the Rules on e-waste
Europe’s Waste Electrical and Electronic Equipment
management practices. Although the Rules have been in force
(WEEE) Directive, which was passed in 2003, is one of the
since 2012, there is little research on the implementation (the
first legislations that used EPR as the framework for e-waste
exception being Toxics Link [2014]).
management. The 2003 WEEE Directive required producers to
This paper is an exploratory study on the implementation of
set up collection centers, either individually or collectively, to
e-waste Rules in Ahmedabad, one of the fastest growing cities
take back used electronic devices from consumers. The take-
in India. Given that India has no baseline data on even e-waste
back mandate was accompanied by collection (4 kilograms [kg]
generation quantities, any quantitative assessment of the Rules
per inhabitant per year from private households) and recovery
on outcomes, such as collection or recycling rates, is difficult.
rate targets. A revised Directive, which modified among other
We thus focus on exploring if and how the Rules are impacting
things the collection rate targets, became effective in 2014.
the e-waste management practices. Using qualitative research
Other developed economies such as Japan and some states in
methods, we answer this question by examining how three
the United States have also instituted some form of EPR reg-
central stakeholders in the implementation process—producers
ulation to manage e-waste (e.g., Ogushi and Kandlikar 2007;
of electric and electronic equipment (EEE), bulk consumers,1
Kahhat et al. 2008; Hickle 2014; Reagan 2015).
and the regulatory agency in charge of enforcing the Rules—
After Europe’s WEEE directive, a few developing Asian
are responding to the obligations assigned to them under the
countries have formulated their own EPR regulations. China
Rules.
legislated EPR through The Regulation on Management of
The paper is organized as follows. In the next section, we
the Recycling and Disposal of Waste Electrical and Electronic
review the literature on EPR in developing countries, including
Equipment, which became effective from 1 January 2011 (Wang
the concept of EPR, in the context of e-waste. The follow-
et al. 2013). Under this regulation, which is applicable to five
ing sections describe the India’s e-waste Rules of 2011, the
products (televisions, refrigerators, washing machines, air con-
methodology we followed for the study, and the findings. We
ditioners, and computers), producers, including importers, must
then discuss our findings to draw implications for EPR in India
contribute to a fund on the basis of units of product sold (Chung
as well as other developing countries.
and Zhang 2011; Wang et al. 2013). This fund is used to sub-
sidize formally licensed recyclers, who are expected to meet
certain treatment standards for e-waste. The law also speci-
Literature Review: Extended Producer fies responsibilities for a few other stakeholders—retailers and
Responsibility in Developing Countries service companies, refurbishment companies, and e-waste col-
lection companies.
Extended Producer Responsibility Framework
Preliminary analysis of China’s EPR regulation has identified
The disposal of EEE products after their useful life has neg- a few potential problems, including (1) inadequate specification
ative externalities in terms of impact on human health and of financial incentives for take-back by wholesalers and retailers,
the environment (Manomaivibool 2009; Pradhan and Kumar (2) lack of penalties for retailers and manufacturers for violating
2014). Extending the responsibility of the management of this the provisions of the law, and (3) inadequate provisions for
waste is a way to force the producers to internalize these prod- preventing recycling and treatment in informal sector (Chung
uct externalities (Sachs 2006). In the traditional model, where and Zhang 2011; Tong and Yan 2013; Reagan 2015).
the responsibility lies with the local municipalities, the man- South Korea has had some form of e-waste regulation since
agement of waste is usually financed by taxpayer money, al- 1992, under its broader umbrella of waste management regu-
though some countries instituted a fee on waste generators. By lations. Mandatory EPR came into effect around 2003 (Yoon
making the producers responsible for waste management, EPR and Jang 2006) in which ten types of electronic products were
shifts the burden to the producers and away from the local regulated, with mandates for product-wise recycling obligation
agencies. rates (as percentage by weight of the sales volume in the pre-
An EPR approach also has the potential to provide incen- ceding year) for producers. The law specifies monetary penal-
tives to the producers to incorporate waste disposal costs at the ties between 115% and 130% of the standard recycling cost
design stage (OECD 2006a). Because it costs the producers to for the missing volumes. Impact-wise, South Korea’s EPR pro-
safely dispose (including collection and recycling) products af- gram proved to be more effective than the preceding deposit
ter their useful life, it can make economic sense to reduce these refund system. The recycling rate targets were met comfort-
costs by incorporating the environmental issues at the design ably by the producers; however, the overall collection rates
stage. For example, creating products with less toxic materi- of e-waste remained well below those of the more developed
als reduces the cost of processing the toxic products after their European countries (Manomaivibool and Hong 2014). Also,
useful life. These two aspects—ensuring the internalization of the EPR regulation could not effectively control recycling ac-
product externalities and incentives for environment-friendly tivities in “junk shops” or the informal sector and the quantity
product design—are often cited as the two most important rea- of “hidden flows” continued to grow (Manomaivibool and Hong
sons for adopting EPR for e-waste (OECD 2006a). 2014).

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 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

Table 1 Estimates of e-waste generation quantities for India

Estimation E-waste quantity

year (million tonnes/year) Comments Source

International Resource
Group Systems South
Based on market penetration; includes computers, Asia Report as quoted in
2004 0.146 televisions, washing machines, and refrigerators Toxics Link (2011)

2005 0.15 Based on obsolescence rate and installed base assumptions CPCB (2008)

2007 0.383 Includes computers, mobiles, televisions, and imports GTZ-MAIT (2007)
Based on GTZ-MAIT (2007), but includes large household
0.66 appliances and others Greenpeace (2008a)
Compiled from multiple sources of data; includes
computers, printers, mobile phones, televisions,
0.439 refrigerators UNEP (2009)

2011 0.97 Projections based on GTZ-MAIT (2007) Greenpeace (2008a)

2012 0.8 Based on obsolescence rate and installed base CPCB (2008)
Uses 0.8 million tonne in 2012 as the base; projections up
to 2019 based on a cumulative annual growth rate of 27%
2014 1.19 between 2008 and 2012 and 21% between 2014 and 2019 Frost & Sullivan (2015)
Based on the assumption of 1.3 kg per capita e-waste
1.64 generation rate Balde and colleagues
(2015)
2015 1.4 Same as reported above for 2014 Frost & Sullivan (2015)

Note: kg = kilograms.

Thailand formulated a form of EPR regulation under its Na- and recycling of e-waste in Brazil (Quariguasi Frota Neto and
tional Integrated Strategy for the Management of Waste Electri- van Wassenhove 2013).
cal and Electronic Equipment (Manomaivibool and Vassanad- To summarize, many developing Asian countries, including
umrongdee 2011). This regulation requires producers to pay a India, have adopted or are planning to adopt some form of
fixed up-front product fee with the revenues from the fee used EPR regulation over the past 5 years. Very little is known,
to fund a buy-back program that pays a subsidy to the consumers however, about the actual impact of these regulations on e-
who return their end-of-life (EoL) electronic products to col- waste quantities, flows, and management practices. Scholars
lection centers. Research on this program’s potential effective- argue that (1) the difficulty in identifying producers, (2) illegal
ness suggests that while it has the ability to induce consumers imports of e-waste, (3) the existence of a large informal sector,
to return their products to the formal recycling systems, the and (4) weak regulatory capacity pose major challenges to EPR
subsidy may not be enough to prevent the waste from flowing regulations in developing countries (e.g., Manomaivibool 2009;
into the existing informal recycling sector (Manomaivibool and Kojima et al. 2009; Skinner et al. 2010; Akenji et al. 2011).
Vassanadumrongdee 2012). Malaysia and Sri Lanka are the Our study contributes to this literature on understanding the
other developing Asian countries that are likely to adopt effectiveness of EPR regulations for e-waste management in
EPR as the primary approach to e-waste management (see developing countries through an exploratory analysis of India’s
Mallawarachchi and Karunasena 2012; Agamuthu and Vic- EPR regulations.
tor 2011). Vietnam is another developing Asian country that
has instituted EPR for e-waste management recently (Tran and
Salhofer 2016). India’s E-Waste Status
Among the other emerging economies, Brazil does not have India is one of the fastest growing markets for electronics
a specific e-waste regulation; however, e-waste is one of the cat- in the world. Some projections predict a fivefold increase in
egories of waste regulated under its solid waste laws. These laws e-waste from old computers and 18-fold increase from mobile
require mandatory take-back by producers. Lack of operational- phones between 2007 and 2020 (UNEP 2009). India, however,
ization of the take-back requirements and poor enforcement of never conducted an inventory of e-waste and no official esti-
these laws make them ineffective in improving the collection mates of e-waste generation quantities are available. Estimates

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 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

are available from other sources (see table 1), but refer to dif- to maintain records of e-waste handled and file returns with
ferent years and vary for the same year because of the varying the SPCBs. The rules also contain a suggested timeline be-
assumptions and variation in the number of electronic items yond which e-waste cannot be stored by producers, collection
included in the estimation. Based on these estimates, it is likely centers, dismantlers, or recyclers. For both household and bulk
that India generated approximately 1.5 million metric tonnes consumers, the Rules require channeling of waste to registered
in 2015. facilities. The bulk consumer should also maintain records of
Like many other developing countries, most e-waste is col- the e-waste generated in a specific format. Finally, the urban
lected and recycled in the informal sector (e.g., Wath et al. local bodies (ULBs) are given the responsibility of safe disposal
2011; Rajya Sabha 2011); according to some estimates, this of orphaned e-waste, defined as unbranded e-waste.
amounts to close to 95% of generated e-waste (e.g., GTZ-MAIT Following the promulgation of the Rules, the CPCB devel-
2007). The hazardous nature of e-waste and the unscientific oped implementation guidelines (CPCB n.d.) for various actors
practices employed by the semiskilled and unskilled workers regulated under the Rules, including producers, collection cen-
in the informal sector pose serious risk to human health and ters, dismantlers, recyclers, SPCBs, and ULBs. In our study,
the environment (e.g., Bandyopadhyay 2008; Manomaivibool we focus on three central actors: the producers of EEE, who
2009; Bandyopadhyay 2010; Pradhan and Kumar 2014). are made responsible for EoL management of their products,
The e-waste Rules introduced in 2011 is a response to the the bulk consumers, who generate close to three quarters of
growing problem of e-waste management.2 Prior to the intro- the total e-waste generated in India (Manomaivibool 2009),
duction of the 2011 Rules, e-waste was included in Schedule and the SPCB, which is the main agency responsible for the
IV of the Hazardous Waste (Management, Handling, & Trans- enforcement of the Rules.
boundary Movement) Rules, 2008 (MoEF 2010), making it
mandatory for recyclers handling e-waste to legally register with
the Central Pollution Control Board (CPCB).3 According to Methodology
the data obtained from the CPCB through our personal commu-
Data Collection
nication, in 2010, there were 23 e-waste recycling/reprocessing
units registered throughout the country under the Schedule We collected most of our data in Ahmedabad, which is
IV of the Hazardous Waste Rules. As a prelude to the 2011 the fifth largest city in India in terms of population (around 6
Rules, CPCB also released “Guidelines for Environmentally million) and the largest city in the state of Gujarat in west-
Sound Management of E-waste” in 2008 (CPCB 2008), which ern India. It is also the commercial capital of Gujarat (the
provided information on recycling and treatment options for administrative capital Gandhinagar is 20 kilometers [km] from
e-waste management. Ahmedabad) with a land area of 464 square km and boasts of
several chemical, pharmaceuticals, dyes and paints, electronic
appliances and equipment, and machine component industries.
E-Waste (Management & Handling) Rules, 2011
We adopted different strategies for collecting data on our
The Rules apply to every producer, consumer, or bulk con- three stakeholders. With regards to producers, we first identi-
sumer involved in the manufacture, sale, purchase, and pro- fied the top five producers of EEE in each of the three cate-
cessing of EEE or components, including collection centers, gories: mobile phones, computers, and household appliances.
dismantlers, and recyclers of e-waste. The Rules, however, are We ended up with a list of 22 producers, some producers being
not applicable to micro and small enterprises and batteries. common across product categories (see table 2 for details). We
The Rules define extended producer responsibility as “the initially collected data from publicly available information on
responsibility of any producer of electrical or electronic equip- the websites of producers (see table S1 of the supporting in-
ment, for their products beyond manufacturing, until the envi- formation available on the Journal’s website for the details on
ronmentally sound management of their end-of-life products” the nature of data we collected from the websites). In order to
(MoEF 2011, 28). The producers are made responsible for col- verify the extent to which the producers implement what they
lection of e-waste generated either during the manufacturing promise on their websites, we have sent questionnaires for more
process or from the EoL use of the product by consumers. The information on their practices in response to the Rules. In spite
producers are also made responsible for setting up collection of two reminders, we did not receive a single response from
centers and financing and organizing a system for environ- the producers to our questionnaires. In addition, we called the
mentally sound management of e-waste.4 The Rules, however, collection/recycling phone numbers provided on the websites,
give producers the choice of either preparing such a system on posing as customers wishing to deposit their products.
their own or by joining a collective scheme involving other For bulk consumers, we conducted face-to-face interviews
producers. with representatives of banks, educational institutions (both
The Rules also contain specific responsibilities for collection colleges and schools included), private sector firms (industries
centers, dismantlers, and recyclers involved in e-waste manage- from Vatva industrial area in Ahmedabad), and government
ment. All these entities are required to register with the SPCBs and semigovernment firms. In the case of regulatory agencies,
of the states in which they operate and ensure proper handling our data consist of two interviews with the officials of the
and disposal of e-waste. In addition, these entities are required Gujarat Pollution Control Board (GPCB): one is an informal

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Table 2 Top electrical and electronic equipment producers in terms of market share

Market share of
Category Products Top five brands top five brands

Mobile phones Mobile phones and accessories Samsung, Nokia, Micromax, Karbonn, Lava 59%

Personal computers Laptops, desktops, tablets HP, Lenovo, Dell, Acer, HCL 71%

Household appliances Washing machines LG, Samsung, Videocon, Whirlpool 75%

Televisions LG, Samsung, Videocon, Sony, Panasonic 90%

Air conditioners Bluestar, Voltas, LG, Godrej 50%

Refrigerators LG, Samsung, Videocon, Godrej, Whirlpool 86.5%

Vacuum Cleaners Eureka Forbes, Panasonic, LG, Gryphon, Philips 95%

Source: Compiled by the authors from a variety of sources, including news reports and market research databases such as Market Line and Emerging
Markets Information System.
Note: The market share numbers are for the year 2013.

unstructured conversation with a lower-level official involved general principles of data analysis for case study research (Yin
in the implementation of the Rules and the other with the per- 2013). The first set of themes that we identify is the mandated
son in-charge of the implementation of e-waste Rules in the responsibilities assigned to each of the three stakeholders. We
Head Office of the GPCB in the capital city of Gandhinagar. use the Rules as the source of data to interpret the mandated
We also interviewed one official from the CPCB involved in responsibilities. The second set of themes we use is the actual
the development and implementation of the Rules nationally. response of the stakeholders to their mandates. We organize
To supplement these data, we conducted face-to-face inter- the data that we collected from multiple sources to analyze the
views with three scrap dealers5 in Ahmedabad (there is no esti- actual response to mandates. We then analyze the gaps, if any,
mate of the total number of such scrap dealers in the city) and between the mandated responsibilities and the actual response
telephonic interviews (as well as questionnaire surveys) with to draw broader implications for the implementation of e-waste
all the seven dismantling/recycling units registered in Gujarat. Rules in India. Wherever possible, we use data triangulation in
In addition to the interviews and data from producer websites, which we verify the claims made by some stakeholders using
we have collected extensive information on the Rules and their data generated from other stakeholders.
implementation from a variety of publicly available sources—
nonprofits, government agencies, international organizations,
and industry associations. Table S2 of the supporting informa- Findings
tion on the Web provides more details on the data collection We begin this section with the findings on the impact of
methodology. Rules on the collection and recycling infrastructure. We orga-
nize the rest of the discussion around our three key stakeholders
Interview Methodology of interest, with a focus on understanding the practices that are
attributable to the implementation of e-waste Rules.
All the interviews with various stakeholders are conducted
using semistructured questionnaires. Our interviews with bulk
consumers and scrap dealers largely focused on understanding Impact on Overall E-Waste Collection and Recycling
their awareness of the e-waste Rules and their past and current Prior to the 2011 Rules, recycling units processing e-waste
e-waste management practices. The authors of the study were were required to register with the CPCB under the Haz-
assisted by a team of three trained interviewers. None of the ardous Waste Rules, 2008. Data obtained from the CPCB6
interviews was recorded because of the general reluctance of indicate that as of September 2010, 23 recycling/reprocessing
the interviewees. The interviewers took notes, which are used units across the country were granted registration under the
as the basis for data analysis. Hazardous Waste Rules. Gujarat had one registered unit—
Jhagadia Copper Limited, with a 12,000 metric tonne/annum
Data Analysis capacity to process shredded printed circuit boards and mother
boards. Gujarat currently has seven registered units and Jhaga-
We analyze our data to generate evidence for our central dia Copper Limited is not among them. This unit was closed
question: if and how the three stakeholders of interest (i.e., down around 2012. Table S3 of the supporting information on
producers, bulk consumers, and regulator) are responding to the the Web presents details on the likely year of establishment of
provisions of the e-waste Rules in Ahmedabad? We follow the the seven registered units, the Rules under which these units

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 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

Table 3 Trend of registered e-waste recycling units in India units are registered under the E-waste Rules. As we have seen
in the case of Gujarat, it is likely that some of these units may
September November September
have been registered under HWM Rules, 2008. Overall, it is
2010 2014 2015
clear though that since the notification of the e-waste Rules,
No. of registered 23 138 148 there has been a substantial increase in the number of registered
units
e-waste processing units.
Total capacity 89,177 394,154 455,058 We have conducted further analysis of the amount of waste
(metric ton/year) that is being channeled through formal e-waste processing facil-
Source: Compiled by authors based on data obtained from the Central ities (table 4). Assuming that the country generated 1.5 million
Pollution Control Board.6 metric tonnes of e-waste (based on estimates in table 1) in 2015,
Note: E-waste (Management and Handling) Rules, 2011 were notified in we estimated the percentage of e-waste that might be handled
May 2011 and became effective in May 2012. All the 23 units registered in
through registered facilities under three different capacity uti-
2010 continue to operate in 2014 and 2015, except for three.
lization assumptions: full utilization, 50% utilization, and 20%
utilization. As table 4 shows, even under the most optimistic
scenario of full capacity utilization, formal facilities would pro-
are established, the dates on which the units registered with
cess around 30% of the total e-waste generated. Our interviews
pollution control board to process e-waste, and the nature of
with dismantling/recycling units in Gujarat and officials in the
e-waste processing for which they received authorization.
regulatory agencies indicate that the capacity utilization is quite
Four units were registered under the Hazardous Waste Man-
low and is likely in the range of 20% to 50%. If this assump-
agement (HWM) Rules in January 2012, which is before the
tion is correct, then approximately 6% to 15% of the waste is
e-waste Rules became effective (i.e., May 2012), but after the
channelized through formal e-waste processors.
Rules were notified (i.e., May 2011). The remaining three have
been established after the e-waste Rules became effective and
are registered under the e-waste Rules. Our analysis thus suggests Impact on Producer Practices
that in Gujarat, 40% of the currently available formal (regis- We assess the producers with respect to their broad responsi-
tered) e-waste processing capacity (in addition to the capacity bilities mandated under the Rules (see table S1 of the supporting
to process 160,000 printer cartridges per year) has been added information on the Web for the details on our producer anal-
after the e-waste Rules became effective. We cannot be certain ysis and table 5 for a summary). One question we attempt to
that the rest of the capacity came into existence in response to address, wherever possible, is the extent to which the observed
the e-waste Rules. e-waste practices of the producers are potentially attributable
At the national level, 148 dismantler/recycler units to the implementation of the Rules.
with a total e-waste processing capacity of 455,059 metric
tonnes/annum are registered as on September 2015 (see table 3 Information Provision
for the trend in the number of registered units). Our analysis Most producers (more than 70%) explicitly mention the
shows that 20 out of the 23 dismantlers/recyclers operating in Rules and their commitment to comply with the Rules. Even
2010 are part of this list of 148. This means that 128 disman- among the six producers who do not explicitly mention the
tlers/recyclers have registered after 2010. We do not, however, Rules, four of them provide information on collection and re-
have details of the exact date of establishment of these 128 cycling. This suggests that there is at least a general aware-
registered dismantlers/recyclers nor details on whether all these ness of the existence of the Rules among most producers. Only

Table 4 Estimation of e-waste diverted to formal recycling units

Total E-waste
generation in 2015 Waste processed through registered recyclers (as on
Assumption about capacity
(tonnes/year)a September 2015)
utilization in the formal
sector Waste (tonnes/year) Percent waste (%)

1,500,000

100% 455,058 30

50% 227,529 15

20% 91,011.6 6

Source: Calculated by authors based on the available estimates.

Note: Capacity utilization represents the amount of waste that is actually processed by the registered recycling units relative to their total available
capacity.
a Assumed based on the available estimates of total e-waste generation in the country.

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Table 5 Summary of findings on producer compliance with e-waste mechanisms (publications, advertisements, and posters are the
rules other modes of communication that the Rules suggest) through
which producers create awareness on e-waste.
No. of sample firms
complying
Producer responsibility (percentage) Collection and Recycling Practices
All the firms in our sample, except for two, provide some
Mention the rules on website 16 (72) level of information on how to deposit their products after the
Information on e-waste hazards on 22 (100) end of useful life (table 5). A majority of our sample firms (close
to 60%) claim to have tied up with a third-party provider for
website
collection and recycling. All the third-party firms tied up with
Information on collection centers the producers in our sample are registered with some state pol-
on website lution control board in the country, but none with the GPCB.
Third-party tie-ups for collection 13 (59) Approximately one quarter of our sample firms provide just a
Own stores 2 (9) phone number or some other basic guidance on how to drop
No specific information except 5 (23) off e-waste. Only one brand (LG) claims to provide monetary
phone number to call for incentive for depositing the equipment after its use. A third-
collection of waste party firm registered with LG picks up the waste and pays the
No information 2 (9) consumer after assessing its value.
Has there been any influence of the Rules on the producers’
Response to phone calls for
take-back practices? Referring to the Greenpeace study again,
collectiona close to half of the electronic manufacturers had no take-back
No response/phone not working 8 (36) policy in 2008 (Greenpeace 2008b). Among those with take-
back policy mentioned on the website, only three manufactur-
Must exchange with a new 2 (9)
ers had a functioning take-back system. A comparison between
product Greenpeace study and our study shows that five producers, who
Connected to third party 5 (23) had no take-back policy in 2008, have a take-back policy now.
Clearly, there is some evidence that the Rules may have influ-
No information on recycling 2 (9)
enced the collection and recycling practices of the producers,
Referred to local service center 3 (14) at least in our sample of producers.
Our phone calls posing as customers provided interesting in-
Only e-mail contact 2 (9)
sights on the actual practices (as opposed to what they promise
Producer authorization in at least 16b (72) on their websites) (table 5). Only in two cases, we received
one state any concrete response that explains how to deposit the waste.
Total number of firms sampled 22 In these two cases, the phone got connected to a third-party
recycler,8 who gave information on the location where the
a Based on calls to phone numbers available on producer websites for e-waste
waste can be dropped. In the rest of the cases, from the in-
collection information.
b Based formation provided, it would be quite difficult for a consumer
on authorization data from only three states—Delhi, Maharashtra,
and Karnataka. to understand how the waste can be deposited at an authorized
collection/recycling center. In the case of eight producers, there
is no response on the phone in spite of multiple attempts, and in
two producers provide no information on anything related to another two cases, the respondent had no idea about collection
e-waste. or recycling of e-waste.
Although the details vary, almost all the producers pro- Overall, our analysis suggests that while the Rules might
vide information on the hazardous nature of e-waste and the have incentivized the producers to engage in some e-waste
consequences of mixing e-waste with municipal solid waste. management practices that they would not have engaged in
This is part of the awareness generation mandates of the Rules. otherwise, the implementation on the ground has been less
Clearly, the Rules had an impact on this aspect. According than satisfactory.
to a study conducted by Greenpeace in 2008, none of the
20 producers7 that their study evaluated had provided any infor- Compliance with Authorization Requirements
mation on the hazardous nature of e-waste (Greenpeace 2008b). Rule 9 of the Rules requires that producers obtain an autho-
Although we have no data on exactly when this information rization from the SPCB “concerned as the case maybe” (MoEF
is uploaded on the manufacturer websites (post-2008), it is still 2011, 32), meaning that the authorization should be obtained
reasonable to infer that the mandates under the Rules had some from an appropriate SPCB. The implementation guidelines
influence in the manufacturers’ decision to provide this infor- (CPCB n.d.) related to the Rules are then supposed to de-
mation. Providing information on websites though is relatively fine the appropriate SPCB from which the producers should
cheap, and we cannot infer anything from our data on the other obtain the authorization. About three quarters of our sample

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Table 6 Summary of findings on e-waste disposal practices of select vendors registered with the banks or through take-back agree-
bulk consumers in Ahmedabad ments with the dealers of EEE, especially that of computers. In
Banks the take-back system, the banks enter into a contract with the
r Auction to e-waste vendors
dealer to take back the old equipment when they replace it with
r Exchange contracts with equipment dealers
new equipment and offer discounts on the new products. We
r Sell to informal e-waste dealers
do not know how the dealer processes the returned electronic
r Store waste
equipment. Other practices of banks include selling the waste
to informal dealers or simply storing the waste.
Industries and educational institutions What does this tell us about the influence of the e-waste
r “Gift” old equipment to employees Rules on e-waste practices of banks? Clearly, some banks con-
r Sell to scrap dealers tinue to sell their waste in the informal markets, even after
r Exchange for new products with discounts from dealers being aware of the Rules. On the other hand, our interviews
Government agencies reveal that after the introduction of the Rules, the banks that
r Sell to empaneled recyclers registered with state
take the auction route are insisting that the vendors that bid
for their e-waste obtain necessary government authorizations
pollution control board under a fixed-rate contract
under the Rules to qualify for participation in the auction. This
is perhaps the most significant change prompted by the Rules.
producers have registrations in at least one of the three states— It is also interesting to note that the banks have a system
Maharashtra, Karnataka, and Delhi—but none in Gujarat, al- of record keeping of e-waste generation even before the im-
though all the producers sell their products in Gujarat. This plementation of the Rules. This is apparently because of the
is surprising given that most producers explicitly mention the requirements under the annual financial audit that banks must
Rules on their websites. The answer, however, lies in the detail undergo. Under this auditing process, computer and other elec-
regarding the SPCB that has the jurisdiction over the producers. tronic equipment that banks purchase are considered as physical
According to the guidelines on the implementation of the assets that banks must account for in their annual statements. In
Rules (CPCB n.d.), the concerned SPCB from which the pro- this process, the banks must maintain a record of the disposal of
ducers must obtain authorization is the SPCB of the state in e-waste. Thus, it is not possible to attribute the record keeping
which the producers’ manufacturing facilities and corporate practice of banks to the implementation of e-waste Rules.
head offices are located.9 None of the producers in our sam-
ple has their corporate offices located in Gujarat (see table S1 Schools and Medium and Small Industrial Units
of the supporting information on the Web for the details). This In the case of the other two types of bulk consumers in
explains why most of our sample firms have authorizations from our sample—educational institutions and industrial units—the
these three states and not from Gujarat.10 The implication is awareness regarding the Rules is very low. Only one educational
that although most producers sell their products throughout the institution out of the seven and only two industrial units out
country, the regulatory control entirely lies within the SPCB of of 12 that we interviewed report any knowledge of e-waste
the state in which the producers have their manufacturing oper- Rules. Not surprisingly, very few of them claim to maintain (one
ations and/or corporate head offices. In addition, the guidelines quarter of the 12 industrial units and two out of seven schools)
on implementation also suggest that the producers make their a record of e-waste generation required under the Rules.
authorization information available on their websites. The pro- Regarding their practice of disposing of waste, our interviews
ducers’ websites, however, have not provided any details on the suggest that these entities have no established policy. The mode
authorizations that they might have obtained from the SPCBs, of disposal of e-waste ranges from “gifting” the equipment to
and we did not receive any response for our questionnaire sent the employees after the useful life, selling to scrap dealers, and
to all the 22 producers. exchanging the old products for the new products from their
dealers to receive discounts on the new products.
Impact on Practices of Bulk Consumers
Other Bulk Consumers
The general findings of our analysis on the current disposal While we did not interview other groups of bulk consumers,
practices of the sampled bulk consumers are described below our interviews with the GPCB officials reveal an initiative by
and summarized in table 6. the Gujarat state government. State government offices are
defined as bulk consumers under the e-waste Rules. In Decem-
Banks ber 2014, Gujarat Informatics Limited (GIL), a state agency
All the nine banks in our sample reported being aware of charged with procuring computers and other EEE for state agen-
their responsibility under the Rules. All of them maintain a cies, had released its policy for disposal of e-waste in accordance
record of e-waste generated and channeled through dismantlers with the e-waste Rules. This policy provides guidelines for all
and/or recyclers, as required by the Rules. In terms of e-waste the state departments and agencies on the procedures to be
management practices, most banks (five out of nine in our sam- adopted for disposing EoL electronic equipment (Government
ple) channel their e-waste either by auctioning the e-waste to of Gujarat 2014). It specifically requires the agencies to first

8 Journal of Industrial Ecology

 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

determine whether an equipment requires disposal (e.g., any is a general sense that 2 years is a relatively short time for the
computer that is more than 5 years old automatically quali- regulated entities to respond effectively to the Rules. For ex-
fies for disposal, if the users wish to dispose it) and then dis- ample, the officials cited the implementation of the Municipal
pose them through a recycler registered with the GPCB and Solid Waste Management Rules for which it took them more
empaneled by GIL. This could potentially be a useful model for than 10 years to effectively enforce the Rules. The officials also
other state agencies as well in which one state agency is made repeatedly emphasized a need to “sensitize” both the producers
responsible for managing the e-waste generated across all the and the consumers regarding the requirements of the Rules be-
government agencies. fore enforcement actions are initiated on the offenders. Second,
The final piece of evidence regarding the potential influ- the sanctions for violation of Rules involve initiating a judicial
ence of e-waste Rules on the practices of bulk consumers comes process, which is a time-consuming process. Also, in the larger
from our interviews with the scrap dealers. Only one of the scheme of things within the GPCB, implementation of e-waste
three scrap dealers report any knowledge of the e-waste Rules. Rules does not appear to be a top priority, partly because of
However, two out of the three dealers noted that there has the lack of manpower. The official in-charge of e-waste Rules
been a decline in the waste they receive through the informal implementation is also responsible for the implementation of
channels over the past 2 years, which coincides with the imple- the HWM Rules, which require monitoring and enforcement
mentation of the Rules. They attribute this to the (1) increasing of a large number of industries in the state.
practice of auctioning the e-waste by industrial units and gov- Finally, the GPCB believes that the awareness of the Rules
ernment establishments and (2) longer time intervals of product is generally low among the consumers, especially the household
replacement by industries. Although it is not possible to make consumers. They view this as a big challenge in the effective
any definitive statement, this evidence reinforces the findings implementation of the Rules. In particular, the question is how
from our interviews with banks that there is a change in prac- to induce the household consumers to channelize their waste
tice prompted by the Rules in which the banks are increasingly through authorized channels, given that selling the waste to
channeling their waste to registered dismantlers/recyclers. informal scrap dealers fetches them money.

Assessment of Regulatory Response to Implementation Discussion and Implications

The GPCB has so far authorized seven e-waste collec- Extended Producer Responsibility and Formalization
tion/dismantling centers in various parts of the state (see of E-Waste Management
table S3 of the supporting information on the Web). Four out
A constant theme in the discussion on EPR in develop-
of these seven are registered under HWM Rules, 2008 while the
ing countries is the presence of a large informal sector (e.g.,
other three are registered under the e-waste Rules. In our in-
Manomaivibool 2009; Kojima et al. 2009; Skinner et al. 2010;
terviews, the GPCB official insisted that e-waste is dismantled
Akenji et al. 2011). Given that more than 95% of e-waste was
in India and recyclable material is exported to other countries
processed in the informal sector before the notification of e-
for material recovery—no recycling is carried out in India by
waste Rules in India, one question that we must address is the
formal recyclers. Part of the explanation is that the amount of
impact of Rules on formalization of e-waste processing. The
e-waste collected in the formal recycling sector is so low that
positive side, according to our analysis, is that within the first
it is not economically viable to set up recycling processes in
3 years of implementation of e-waste Rules, there has been
India. We could not independently verify this claim. Accord-
a considerable rise (from 23 in 2010 to 148 in 2015) in the
ing to another lower-level GPCB official we interviewed, the
number of registered e-waste processing units. Several major
authorized collection centers in Gujarat have not been able
producers have also reported tying up with the registered recy-
to collect enough waste because, according to him, the waste
cling units and some types of bulk consumers may be shifting
is mostly still passing through the informal channels. As part
toward disposing their waste through formal channels.
of GPCB’s obligations to conduct an inventory of e-waste in
Several problems remain, however. In spite of the increase in
Gujarat, the task has been assigned to Gujarat Environmental
the number of registered units, our study suggests that many of
Management Institute, an agency of Gujarat government.
these units might not be receiving adequate amounts of e-waste
The third activity that the GPCB has initiated under the
for processing, indicating that significant amounts of e-waste
Rules is notifying various bulk consumers of their responsi-
is still likely diverted toward informal channels. Our estimates
bilities under the provisions of the Rules. Although the copy
reveal that somewhere between 5% and 15% of the e-waste
of the letter sent to the bulk consumers was not shared with
is likely processed through formal channels; even under full
us, the officials indicated that the letter informs the bulk
utilization of the current capacity, only less than one third of
consumers on their responsibilities to channel their e-waste
the total e-waste is likely channeled through formal processing.
through authorized entities and provides the list of seven col-
What does our study suggest are the likely reasons for the
lectors/dismantlers that the GPCB authorized in the state.
low utilization of formal processing units? First, the collection
In terms of enforcement for violation of provisions of the
and recycling systems for which the producers are responsi-
Rules, our interviews suggest a general reluctance to take en-
ble are inadequate and it is not easy for consumers to deposit
forcement actions and there are at least two reasons. First, there

Bhaskar and Turaga., India’s E-Waste Rules 9

 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

their waste in formal collection centers. Second, our study indi- the consumer or the producer) at the point of purchase and use
cates that consumers lack sufficient incentives to channel their the revenues to fund collection and recycling activities, includ-
waste to the authorized collection centers/recyclers. Our inter- ing providing subsidies to consumers. This instrument places
views with a section of bulk consumers clearly indicate that the only the financial responsibility on the producers, leaving the
practice of disposal to informal sector continues because of the physical responsibility of managing the waste to governments
monetary benefits. At the same time, except for one producer, and other actors.
none of the producers in our sample offer monetary incen- Another instrument is the deposit-refund system in which
tives to consumers—bulk as well as individual. Research on a deposit is charged to the consumer at the time of the sale of
the behavior of bulk consumers such as information and tech- the product and a refund is issued when the product is returned
nology (IT) companies (Subramanian et al. 2012) shows that after its useful life. In theory, this system can create financial
irrespective of the size of the organization, bulk consumers at- incentives to consumers to return the products after their useful
tach a monetary value to their e-waste. The implication is life. A number of studies consider deposit-refund systems to be
that the bulk consumers are likely unwilling to channel the economically efficient for waste management (e.g., Palmer and
e-waste to formal waste processors in the absence of financial Walls 1997; Lavee 2010). India’s amended e-waste Rules, which
incentives. became effective in October 2016, require producers to set up
Finally, lack of adequate awareness among consumers might a deposit-refund system.
be an impediment for greater diversion of waste to formal sec-
tor. As our analysis shows, the producers provide information Implications for Extended Producer Responsibility
on their websites, which is cheap. The awareness generation, in Developing Countries
however, should go beyond websites because many bulk con-
sumers, including industrial units, need increased awareness The main implication of our study is that EPR policies in
on their obligations under the Rules, the need for systematic developing countries are unlikely to succeed in the absence
management of e-waste, and the options available to them for of (1) careful attention to policy instruments—their choice as
recycling. While we have not studied the awareness among the well as design—within the broad EPR framework, (2) political
household consumers, one would expect the awareness to be will and clarity in the enforcement of EPR, and (3) concerted
even lower among households, which is corroborated by one efforts to generate awareness among stakeholders on e-waste
recent study (Kwatra et al. 2014). management in general, and EPR in particular.
As discussed extensively earlier, India’s e-waste Rules, by
mandating take-back by producers without any targets for col-
Role of Producers
lection and/or recycling, did not create enough incentives for
Our study shows that the producers, who are the central producers to take their responsibilities seriously. On the im-
stakeholders in EPR programs, have not responded adequately plementation side, the unwillingness on the part of the regu-
to the challenges of e-waste management in India. This, in our latory agencies to enforce the EPR regulations and the issue
view, points to potential problems in both the design and im- of lack of clarity in regulatory enforcement that our analysis
plementation of EPR in India’s Rules. EPR programs across the demonstrates could potentially reduce the effectiveness of the
world vary in their design—particularly in terms of the nature of regulation by providing an excuse for producers to not comply
obligations that they place on the producers. In general, manda- (e.g., Quariguasi Frota Neto and van Wassenhove 2013). This
tory take-back requirements such as those adopted by India are is particularly pertinent in a developing country such as India
accompanied by targets for collection and/or recycling as in the because of the already weak regulatory structure with regards to
case of Europe’s WEEE directive as well as South Korea’s EPR enforcement of environmental regulations (e.g., Priyadarshini
program for e-waste. Failure to achieve these targets typically and Gupta 2003; Prasad 2006; OECD 2006b).
invites significant monetary penalties. This creates stronger in- Our analysis also shows that the informal sector, which has
centives for producers to set up robust collection and recycling a huge presence in developing countries, is likely to thrive
systems than a simple take-back mandate would (Palmer and even in the presence of EPR regulations unless (1) the formal
Walls 1999). India’s e-waste Rules of 2011 just require sim- systems make it easier for consumers to deposit their waste,
ple take-back mandates with no accompanying targets of any (2) the producers and/or formal waste processors are willing
kind. The Rules do not specify any monetary penalties for the to provide monetary incentives for consumers to deposit their
failure of the producers to fulfil their responsibilities under the waste at the authorized collection centers, and (3) efforts are
Rules.11 made to improve the awareness on e-waste management. This
What is the way forward for EPR in India? Our study in- is consistent with past research in developing countries (e.g.,
dicates a need to go beyond simple take-back mandates. If Yu et al. 2010).
take-back is used as the primary instrument within the EPR
framework, the mandate should be accompanied by targets for
collection and/or recycling. Many other policy instruments are Conclusions
also compatible with EPR framework (OECD 2006a). Some We studied the response of three major stakeholders in the
countries charge an advance fee on the products (either on implementation of India’s e-waste management Rules using

10 Journal of Industrial Ecology

 A P P L I C AT I O N S A N D I M P L E M E N TAT I O N

the case of implementation in Ahmedabad city in the west- Biomedical Waste (Management & Handling) Rules, 1998; (3)
ern state of Gujarat. Four years since the Rules have come into The Recycled Plastics (Manufacture and Usage) Rules, 1999; (4)
effect, our analysis suggests that the awareness of the Rules is The Municipal Solid Waste (Handling and Management) Rules,
still low among the institutional consumers, the Rules do not 2000; (5) The Batteries (Handling and Management) Rules, 2001;
appear to be high on the agenda of the regulators, and not all and (6) Plastic Waste (Management and Handling) Rules, 2011.
3. The CPCB is a statutory organization under India’s Ministry of
producers have clear plans in terms of the mechanisms for col-
Environment Forests and Climate Change (MoEFCC). The CPCB
lection and recycling. On the positive side, a number of formal
was established in 1974 and provides technical services to the
dismantling/recycling units are being set up to cater to the de- MoEFCC and advisory and technical assistance/guidance to the
mands of the Rules and these formal units are partnering with Government of India and state pollution control boards (SPCBs).
some major producers to comply with the requirements of the 4. Another producer responsibility, which is not central to our
Rules. study, is the reduction in the use of hazardous substances. Within
Our results, however, are largely based on a case study of 2 years of the implementation of the Rules, the EEE producers are
one city and one must be cautious in making generalizations. prohibited from using certain hazardous materials, such as lead,
Even within our case study, our analysis is based on a small sam- mercury, hexavalent chromium, and polybrominated phenyls, in
ple of bulk consumers, producers, and regulators. In addition, the manufacturing of new equipment.
our results cannot illuminate how the Rules are working on 5. The term scrap dealer appearing in the text refers to an individual
who procures or purchases e-waste and sells it to recycling units
the ground in ensuring that e-waste is managed in an environ-
and/or dismantlers. Some scrap dealers also extract materials such
mentally sound manner. For example, although the producers
as copper from wires in e-waste before selling it to recycling units
are partnering with registered waste processors (collection cen- and/or dismantlers.
ters, dismantlers, and/or recyclers), we do not know to what 6. This information is not publicly available at this point, but we
extent the registered waste processors are subject to monitor- obtained it from the CPCB through personal communication. The
ing and enforcement by the regulatory agency to ensure safe details of all the 23 centers are available on request.
handling of e-waste (see Kandhari and Sood [2010] for the con- 7. Thirteen producers are common between our study and Green-
troversy surrounding one of the registered recyclers). Also, the peace study.
amendments brought to the 2011 EPR Rules brought in sev- 8. This recycler is the same recycler that the producer listed on their
eral changes, discussion of which is beyond the scope of this website.
paper. Future research, however, should analyze the extent to 9. It is important to note that the amended e-waste Rules (www.
moef.gov.in/sites/default/files/EWM%20Rules%202016%20
which the amended Rules address the issues we raise through
english%2023.03.2016.pdf, last accessed on 13 May 2016), which
this study.
were notified in March 2016 and will come into effect in October
2016, address this issue by requiring that all producers seek
authorization from the CPCB, which will forward the details of
Acknowledgments
the authorization to SPCBs for monitoring.
We gratefully acknowledge Mr Anand Kumar from Central 10. This also partly explains why, as per CPCB data, of the 150 pro-
Pollution Control Board (CPCB) for his insights and help dur- ducers (including importers) that have been granted authorization
ing data collection and analysis for this paper. We are grateful so far in 11 states, more than 80% (123) are registered in these
to officials from Gujarat Pollution Control Board for their vital three states. Gujarat has authorized three producers (the names
are available with us upon request), but none from our sample of
inputs and Self Employed Women’s Association, Ahmedabad
22 producers.
for their assistance during data collection phase.
11. The Rules give the power to the SPCBs to cancel the authorization
provided to the producers for violation of any provisions of the
Rules.
Notes
1. India’s e-waste management Rules differentiate between “con-
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Supporting Information
Supporting information is linked to this article on the JIE website:
Supporting Information S1: This supporting information provides three supporting tables to the main article: Table S1
shows producer responses to e-waste rules, based on information on websites; table S2 gives a summary of data collection
methodology; and table S3 presents the status of registered e-waste recycling units in Gujarat.

Bhaskar and Turaga., India’s E-Waste Rules 13