MODULE 5

• This chapter is consolidated on four domains of the e-waste

management as illustrated, they are:
MOVING TOWARDS HORIZONS • legal and judicial domain;
• economic concerns;
• recycling culture/ society; and
• environment concerns

I: Legal and judicial domain

• As the e-waste and its management is largely law/regulation driven with
EPR as a strategy, it is very important to comprehend the architecture of
the regulation
• how it offers opportunities and identifies challenges for its enforcement
through institutional mechanism, processes, and action by the
stakeholders
• role of monitoring ensuring legal compliance; what happens in case of
non-compliance
• understanding jurisprudence;
• how regulatory body plays its role – in monitoring, enforcement, and
legal compliance after the Court/Tribunals’ order.
Architecture of the regulation, EPR, and outcomes Contd..
• The architecture of the regulation shows clear equation, in line with • This domain covers mainly the following aspects that have created opportunities
EPR, as follows: and challenges:
• (i) statistics related
• classification of the e-waste according to its various components and
compositions • (ii) legal compliance by producer, through PRO
• (iii) regulatory body related
• emphasising on preparing inventory,
• (iv) monitoring import of e-waste;
• role of stakeholders defined including collection to treatment mechanism
creating awareness raising, reporting, and filing annual returns, etc., • (v) awareness raising among various stakeholders related
• (vi) coordination with/among different ministries/government agencies/missions
• This would lead in increase in e-waste collection and recycling, and thus
a step forward for the resource recovery, resource efficiency, and the CE.
• The CE is important, especially in terms of making life longer of e-
products, reducing quantum of e-waste, and contributing to economy.

Contd
Role and scope of statistics and data driven actions • Whether authorised units could employ skilled labour or the unauthorised
• Almost all countries have expressed concerns for either not having database or difficulties in creating units/informally operating units for dismantling/recycling e-waste earning livelihood
database, mainly due to absence of standards methods for calculating e-waste – generation, collection, – such broader concern of unemployment/development agenda would remain largely
flow, treatment and/or recycling data on resource recovery based formal economy unanswered
• With mandate for all the stakeholders of maintaining records and updating time to time, and filing • Data may be collected on collection, dismantling, and recycling
annual returns, have created a huge opportunity and a possibility of a strong database, inventory of the
e-waste. • but in absence of due processing the collected data, the monitoring by regulatory
authority may not take place or remain weaker.
• every stakeholder’s performance could be monitored and evaluated, as and when required, based on
the available database. • For example, data on ‘awareness measures taken by producers and its impacts’ may
not be available in form of whether awareness led to the desired extent of disposal of
• these reporting items on e-waste are limited, some essential data would not be created/available on
other important aspects of e-waste management, such as, extent of resource recovery and improvement
e-waste.
in efficiency, secondary market scenario, jobs/employment created and other economic benefits, • If awareness of consumers/bulk consumers, and other stakeholders leads to some
• How the CE is enhanced, impacts on human health, and impact on environment cost saving through positive environmental impacts (reduction in toxicity, use of energy, reduction in
refurbishing of EEE. emission, etc.), the desired/required statistics may not get generated/available due to
greater emphasis on EPR enforcement strategy.
• refurbishers are key players as per the Rules, 2016, their contribution to e-waste management, in terms
of repair and reuse of EEE, also may remain undocumented.
 Legal compliance by producer, through PRO
contd..
• Under EPR, producers pay for entire reverse supply chain, clarity on funding
mechanism is required.
• Building up ecosystem aims to collaborate and develop partnerships with all the
• If producer cannot implement all the responsibilities mandated under the Rules, concerned stakeholders from the entire value chain for varied tasks – large number
performing these duties through an authorised PRO is an opportunity to achieve of informal waste pickers and aggregators from various locations, ‘bulk
consumers’ including central and state government authorities, civil society actors
objectives of the Rules, as it sets up entire value chain (from collection to recycling and organisations, research and academic institutions, and so on.
e-waste)/ecosystem.
• PRO’s varied tasks include quality of e-waste collected, ensuring safety measures
• Though the concept of PRO as an entity is an integral part of EPR, which is for storage and transportation, fair pricing, recycling and recovery, etc.
mainstreamed across the world; Indian stakeholders covered under these Rules are • Creating and maintaining database for such varied tasks and activities become
still not well aware of it. necessary for a PRO which demands commitment and efficiency.
• The partnership between a PRO and a producer is critically based on principle of • reduction in illegal e-waste collection and recycling requires due diligence in such
long-term processes. Usually, a producer engages a PRO on annual, contractual
cooperation, on long term basis; basis.
• A couple of PROs, dealing with e-waste in the country have started sharing their • This situation creates a sort of gap between the two entities on the count of
work experiences, and are articulating challenges based on their work experience. commitment – the process-oriented targets become physical target on short term
basis.
• A PRO has to build a holistic system/ecosystem that goes beyond ‘compliance’ in its
simplistic form.

Contd.. Regulatory body – institutional mechanism, capacity, and effectiveness

• This situation creates potential scope for ‘paper trading, malpractices,2 multiple accounting • CPCB and SPCBs perform several functions,
practices,3 misreporting’
• assessment of pollution – air, waste, soil;
• age-old problem of leakage of e-waste – from a PRO/ recycler to informally functioning recycling
unit, back to the waste aggregators and again marketed as e-waste to be recycled. • monitoring of source specific pollution of air, water, soil; monitoring of ambient air and water quality;
development and enforcement of standards;
• Though such problems defeat the objectives of these Rules, they have not been taken into
consideration. • hazardous waste management and dissemination of information;

• to enhance e-waste collection, it is important that bulk consumers dispose their e-waste and legally • conducting mass-awareness programmes
comply by filing annual returns. • improving quality of air and water, disposal of different types of wastes (hazardous, electronic, bio-medical,
municipal solid, etc.).
• Most bulk consumers are not aware of PROs and their role in e-waste management;
• These bodies have been engaged in monitoring of pollution levels, contamination, etc.
• those who are aware about PROs, have not started disposing e-waste through PROs,
• there exists very thin mechanism for enforcement at the CPCB and SPCB, with a staff small in number.
• Because of lack of coordination and gap of communication between government entities.
• This creates huge challenges for their effective functioning, especially monitoring, reporting noncompliance,
• For example, a platform like Metal Scrap Trading Corporation (MSTC) which is used for selling taking necessary punitive actions as per the legal provisions, ensuring compliance ordered by the
scrap material, including e-waste, by most public institutions. Court/Tribunal, and so on.
• At present, MSTC does not allow PROs to use its platform. On one hand, the CPCB authorises the • The Centre for Science and Environment (CSE) has shared their experiences regarding regulating e-waste as
PROs, and the government run unit like MSTC does not recognise the authorised entity like PRO, an environmental policy issue, its report highlights that the approach of regulatory agency is geared towards
on the other hand. giving multiple clearances, consents and authorisations, and with poor monitoring and enforcement
 contd.. contd....
• The Centre for Science and Environment (CSE) has shared their experiences • A couple of suggestions5 for improvements in performance of SPCBs in
regarding regulating e-waste as an environmental policy issue, its report highlights dearth of human resources and multiple functioning are under
that the approach of regulatory agency is geared towards giving multiple clearances, consideration by the CPCB.
consents and authorisations, and with poor monitoring and enforcement • The process of maintaining records for compliance with the regulation’s
requirements would be expensive in addition to the administrative costs to every key
• By giving an example, the report reinstated that most SPCBs suffer from severe player.
deficit of man_x0002_power, infrastructure, and competence in addition to the • The authorised producers and dismantlers/recyclers are already struggling to
challenge of transparency and accountability. compete with informal sector players.
• Describing MPCB in 2014, the report illustrated that a technical officer is • There is a likelihood of weak compliance on the count of maintaining records of
responsible for monitoring more than 250 factories; different types;
• the regulatory authority would have difficulty in monitoring with thin mechanism,
• 30% of the sanctioned posts have been filled in the Pollution Control Boards of without putting IT solution in place.
Haryana, Andhra Pradesh, and Odisha states. • An e-portal for monitoring by the CPCB has been in process, as mandated by the
• As such, the formalisation (registration, authorisation, and monitoring) of NGT. However, it is argued that instead of centralised database, the process needs to
pro_x0002_ducers and dismantlers/recyclers may be effective under EPR, yet be state-centric for better performance at state level.
several loop holes and implementation related challenges are highlighted by the
practitioners of e-waste management.

contd.... contd..
• In light of dearth of human resources, it is suggested that third party audit and • Regarding leakage and e-waste entering grey market, revision in the existing provision is required as well as role
verification of local/state data of vendors, aggregators, recyclers, etc. could be done of municipal corporations/urban local bodies (ULBs) to be operationalised.
by the IT solutions, in place of every SPCB office. • For example, every waste collector needs to be registered with an authorised recycler.
• At present, every authorised recycler is required to recycle a maintain a minimum quantum of (300–500 tonnes e-
• Thus, human burden could be reduced, and monitoring could be effective with waste) per annum.
technology enabled solutions. • Instead, if small scale recycling/dismantling units are authorised, the informal sector units could be formalised this
• One of the ways to deal with this problem is: an association of recyclers/dismantlers way, and transportation of collected e-waste would reach state-based recycler.
could be promoted so that every SPCB office deal with the association. • Tracking e-waste within a state by the regulator would be easier, small scale unit (becoming informal to formal
unit) would be able to treat e-waste in small quantities and reported, and consequently,
• At present, every SPCB deals with each authorised recycler/dismantler on one-to- • how much e-waste residues (plastic, glass, etc.) other than the metals recovered go to the landfill could be
one basis. quantified.
• If there is a platform on which common issues are discussed (e.g. auction of e-waste • Further, if market linkages are established for selling of secondary materials, landfills and con_x0002_sequent
by every bulk consumer, collection and transportation of e-waste within state, contamination could be controlled to great extent along with stoppage of leakage of e-waste.
minimum quantum of e-waste to be recycled per annum, etc.), • Thus, overall monitoring by the regulators improves at state level, in decentralised manner, along with
participation of different stakeholders.
• solutions could be sought and implemented affectively, and generalised solutions • Tracking of recovered materials needs to be done on two counts – RE and CE, and toxicity; thus, along with
rather than a piece-meal solution, by building the bridge between the different economic value of recovered materials,
stakeholders/ implementors and the regulators. • data is availed on toxic materials recovered, leading to effective environment protection.
 Monitoring import of e-waste – not duly Awareness raising responsibility of different stakeholders and their performance – producers, state
addressed governments, regulatory body

• Monitoring in India could be ‘hampered by a lack of international customs • It is believed that if consumers are aware of e-waste, its composition with
hazardous and non-hazardous substances,
codes differentiating between new computers, old computers
• its potential for resource recovery and responsible use of e-products and
• e-waste, and a large number of entry and exit points for e-waste in each disposal of e-waste could be enhanced;
country.’
• in turn strengthen the formal or circular economy.
• the states possess the main responsibility for determining methods of • Awareness can lead to behavioural changes, customers’ commitment to 6Rs
monitoring and compliance may lead to additional administrative and could be translated into practice.
compliance
• Thus, awareness is seen as a critical component of e-waste management;
• costs as well as differing degrees of enforcement…Unnecessary administrative • the Rules have mandated different stakeholders to spread awareness, which is
• costs caused by legislative and monitoring contradictions and overlaps further considered to be promising opportunity
• add to the financial burden of enforcement activities. • Toxics Link (2016) revealed that 66% of consumers (including bulk consumers)
remained unaware of e-waste and the Rules, after five years of its
implementation.

Coordination among different government agencies and missions

• Different ministries are involved in e-waste management;
• Different aspects of awareness on e-waste were discovered with studies carried out in different
• for example, MoEFCC is a nodal ministry, MeitY has taken up various measures
cities • including awareness related, resource recovery related (through C-MET),
• The state governments and ULBs are made responsible for undertaking initiatives for e-waste • role of Ministry of Science & Technology in innovation, etc.
management.
• With a special reference to Ahmedabad Municipal Corporation (AMC), a study has observed that
• The strategy paper by MeitY and NITI Aayog (2019) on resource efficiency has
most ULBs have no financial mechanism in place, which hinders e-waste collection activity. mentioned involvement of three missions
• The AMC had a tie up with an authorised recycler in 2017; • (Clean India, Digital India, and Make in India) – these are opportunities for e-waste
• the recycler did not get anticipated quantum of e-waste. management.
• ‘Ahmedabad procures around 400 tonnes of electronic waste [every month]. Of this, only 13% is • concrete actions like budget/fund allocation, launch of a specific programme for e-
recycled,’ (Patel 2017). waste management, upscaling C-MET experiment – from laboratory to commercial
• A study on Pune city reported that its solid waste management system has to bear an extra 30% scale for recycling unit, etc. awaited.
of load of e-waste not being separated, collected of recycled by the government institutions • Some cities (e.g. Ahmedabad, Pune) have entered into association with an NGO for
waste collection, including e-waste, and have created a channel from e-waste
collection to recycling.
 Scope for legal review, institutional feedback mechanism,
Contd.... grievance redressal mechanism needs to be built in
• Disposal of e-waste by bulk consumers, specifically government agencies require changes • The existing regulation is as such in form of rules and not legislation in itself,
in General Finance Rules (GFR). thus the scope for implementation is restricted.
• There are practical problems as against the Ahmedabad and Pune city is, a commissioner,
in charge of waste management, faces issues of e-waste disposal and the revenue earned. • While looking at from governance perspective, i.e. accountability, people’s
participation, and transparency, it becomes clear that it does not provide a scope
• It is observed6 that if a municipal corporation ties up with a PRO for e-waste disposal, the for institutional feedback mechanism and grievance redressal mechanism.
revenue earned and associated financial auditing ask for changes in the present set up.
• It is also observed that the District Collector asks for an Executive Order/guidelines for e- • When any regulation directly deals with industrial matters, opportunity for its
waste disposal. review is essential, as it can incorporate experience-based leaning and
modification-based performance.
• For example, the Department of Science and Technology, Government of Gujarat has
issued a notification in 2014 regarding e-waste disposal by the government agencies. • The regulation thus evolves simultaneously with industrial development.
• This notification could be considered valid even after the Rules, 2016 were enacted. • Two mechanisms – institutional and grievance redressal – provide opportunities
However, the ULBs expressed a need for specific guidelines. to plug the gaps identified during implementation of the Rules.

II Economic concerns Business opportunities

• E-waste is a value creating waste, mainly through the process of recovery of materi_x0002_als, and
• Economic concerns include opportunities for CE through the selling of recovered/secondary materials.
existing/newer business model; • Two opportunities created through the Rules –
• building up infrastructure supported with a cadre of skilled workers; • i)start-up for dismantling/recycling of e-waste;
• ii)PRO and creating ecosystem for upscaling innovative and cohesive initiatives for e-waste
• using green technology; management.
• dealing with market gaps and barriers; • There is a huge potential for job creation in the value chain of e-waste, including waste collectors,
aggregators, repair shops, refurbishers, warehouse keepers, and transportation business.
• need for employ_x0002_ment and skill building for repair and • The e-waste sector has the potential to create around 6 million jobs, perhaps in just a few years. The
refurbishing units; opportunity for a startup is linked to the legal provision –
• by fostering formal informal sector partnership. • all state governments are made responsible for facilitating e-waste management related various
activities including creating eco parks, providing infrastructure, capacity and skill building of
dismantling/recycling units, and
• workers engaged in e-waste collection and recycling for start-ups
• Financing for start-ups is a challenge. Recycling, its infrastructure, capital investment, inflow of e-
waste, circular value creation across downstream and upstream, etc. challenges have been mentioned
• Another set of challenges is whether or not a state government would be able to maintain e-waste
focus in every infrastructure created for industrial purpose is to be seen.
 Fostering formal-informal partnerships contd...
• While focusing on collection and treatment (refurbish/dismantle/recycle) of e-waste, the
• Informal sector has a very organised network for collection to recycling of e- existing regulatory framework has not taken cognisance of the informal sector in the
waste as well as selling of secondary materials. country, dealing with e-waste and controlling entire value chain – from collection to
recycling.
• This sector has flourished on market-driven requirements and strategies,
especially the entire value and trade chain, subsidising the cost of formal • As the regulation has not taken cognisance of unorganised sector, it does not entail
operations across the chain. measures for rehabilitating those persons who are engaged in the e-waste management
operations in unorganised manner.
• Studying functioning of the informal sector players, their functioning, skills, • By not recognising existence of informal sector players, these Rules are also
management abilities, infrastructure, sustaining and expanding the network of over_x0002_looking critical aspects of the objectives, ‘how informal operations –
various players in the entire value and trade chains, etc. and learning from them collection to dismantling/recycling activities would be reduced.’ Making informal sector
could be a value addition. and its range of activities for the trade chain as ‘illegal’ through regulatory measures
• This is a huge opportunity for moving towards formal economy, and away from would not deal with problem of dominance of informal sector in e-waste management
the informal economy, and making the formal and circular economy sustainable. • Consequently, not paying adequate attention to health hazards, damage to environment,
working conditions, wages, and social security of workers, etc. also would be continued
• The informal sector has been recycling e-waste, and trading the secondary until a suitable business model is developed.
materi_x0002_als for more than four decades, and expanding exponentially.
• The existing Rules also need to harmonise with Labour Laws on this regard
• Building up formal_x0002_informal partnership can bring in more transparency,
accountability, and auditability

Employment and skills related concerns III: Environment concerns

• few persistent challenges for e-waste management, ‘including but not limited to, • Environment concerns include a range of issues from design, production to
employment opportunities for youth and women, re-skilling and upskilling, recycling (lifecycle to end-of-life cycle) and resource use (e.g. of carbon, fossils,
establishing sustainable enterprises, green jobs and transitioning from water, energy, etc.);
infor_x0002_mal to the informal economy
• reduction of RoHS or totally substituting the use of hazardous substances;
• No learnings from the informal sector regarding such skills, ability to trade
recovered material in the domestic market, need for recycling infrastructure, • adopting green technology;
• related projects that can help in building up small scale industrial units, etc. are not • safe disposal and alternatives to landfilling;
taking place.
• techniques to identify and reuse components and materials (e.g. plastics, glass) as
• These are identified as barriers for moving towards formal economy, and resulting in integral part of e-waste management.
losses to the formal economy.
• Such envisioning indicates potentials for safe environment and human health.
• The Skill India promoting institutions and initiatives (such as NSDC, SWAYAM)
can play trend-setting roles in this scenario.
• With skill upgradation and job creation processes, this sector can be very promising
for economic growth, fulfilling requirements of safe environment as well as OSH,
and rights of workers.
 Adopting green technology Standardisation related
• Green technology focuses on minimisation of energy, and use of natural resources, right • Standards have a harmonising effect and can remove trade barriers and enhance
from the design stage to the recycling stage. economic growth and ensure safety of all.
• In terms of environment protection, two very important concerns – green technology and • The Rules have mandated the stakeholders to follow standards for storage,
alternatives to landfill – have remained underused in the existing regulatory framework. dismantling, recycling, and transportation;
Improvement in product design unheeded • standardisation in the entire e-waste value chain is not conceived and not
• One of most important policy principles of the EPR for e-products is to promote
mentioned in the guidelines of the Rules.
environment improvements, especially in the area of design of the products, • There is a need for developing India specific standards on the following:
pro_x0002_duction systems, and final disposal. inventorisation of e-waste data;
• The area of products includes factors such as product material, design, and expected life. • recycling and rate of resource recovery; depolluting standard – limit value for
• The product design for environment/sustainable development (DfE/DfD), for instance, con_x0002_centrations of hazardous substances during EoL treatment
reducing or totally substituting the use of hazardous substances, adopting environment processes;
friendly technology, techniques to identify smooth dismantling/recycling, and reuse • quality of secondary materials and cost.
components and materials, including plastics and measures to promote the use of recycled • These standards shall be aligned with global practices and methods, such as,
plastics in new products, etc.
• WEEELabex, E-Stewards, R2 (responsible recycling) and CENELEC – this is an
opportunity for harmonizing effect and removing trade barriers, as promoted by
various stakeholders

contd.... Recycling and disposal of residues related issues partially addressed

• a bi-lateral agency, a couple of industry actors, and a research • The Rules, 2016 assume that greater e-waste collection would lead to greater recycling and recovery of
resources
organisation have started working on standardisation;
• a couple of problems/ challenges are elaborated for low rate of recycling of e-waste in India.
• their consolidated efforts would build a step forward, encashing the • recycling charge is dependent on multiple factors including but not limited to the cost of procurement
opportunity. from multiple channels,
• It is important to monitor downstream fractions, which provides a • cost of development of channels, logistics cost, ecosystem development costs as well as returns from
recycling which could be positive or negative.
verifiable and accurate basis for the calculation of the recycling and
• 1. Material composition of electronics is changing with technological advances, over time, resulting into
recovery rates lesser amount of recovery and intrinsic value of recovered materials after recycling of e-products/e-
• it provides a clear insight into the hazardous waste streams processed by waste, thus affecting economics of recycling.
• Recyclers and producers agree that monitoring and control are essential.
downstream operators, with the state-of_x0002_art-technologies
• Recyclers want monitoring to ensure more producers are financing formal recycling, and
• there is a crackdown on informal recycling;
• producers want monitoring to ensure recyclers meet standards and are not engaged in paper trading.
 contd.... contd....
2. Recycling facility cannot be generalized, as composition of every e-product is 4) Some critical aspects of recycling/micro-management of recycling to be
different from the other.
• addressed, such as, optimising recovery and product specific method for
• Many Indian recycling units have witnessed failure, as they started recycling unit with opti_x0002_mum recovery; infrastructure and technology required for
latest technology and huge investment; product specific
• as against that, the e-waste flow and economics of recovered material was skewed.
• dismantling/recycling and capital required for a start-up; sustainability of
3. ‘Employing effective recycling technologies for e-waste may require significant a dis_x0002_mantling/recycling unit based on quality and quantum of e-
upfront capital expenditures, which may not be justified for private entities
waste received,
• in the absence of certainty around sourcing of enough quantities of e-waste.
• resources recovered, and selling of recovered/secondary material, and so
• Also, these markets suffer from information barriers.’
on.
• For example, learning from the informal sector is not taking place, low awareness and
lack of reliable information affect functioning of recycling activities.

IV: Recycling culture/recycling society Continuing enforcement of the Rules and innovative initiatives
• The recycling culture is a civil society centric concept and a requirement, beyond the
regulatory framework, wherein all the stakeholders remain the same/not distinctly • The regulation driven business initiatives have started showing results as indicative
categorised. of enforcement of the Rules, such as,
• Role of awareness in enhancement of e-waste collection, recycling, and resource • increase in number of authorised PROs and development of their ecosystems as
recovery has been well established. well as formalization of informal waste collection,
• Realisation of the 6Rs is an opportunity that can change the existing scenario of e-waste. • increase in number of dismantlers/recyclers, resulting into recycling capacity,
• Academic courses started on SWAYAM and upscaling through many more educational compliance by the bulk consumers, discussions on etc.
institutions engaging in academic courses, • These initiatives show a shift in the discourse of e-waste management, i.e. from
• research, and activities would be highly appreciative effort towards realising this WHY e-waste management to HOW e-waste management.
concept among the audience, especially students/ youngsters who believed to be in large • Newer topics of discussions have begun, such as, resource efficiency and circular
number as users of e-products
economy, newer technology, methods of recovery are tried out by the GoI at
• The present vicious cycle of ‘Consume–Collect–Recover–Dispose’ is considered as a laboratory level, infrastructure have to be set up accordingly on industrial scale,
model in practice. This is found to be inadequate based on the argument that it results in and standardisation across value chain.
unbridled accumulation of e-waste in the environment.
• The RoHS has been largely complied by the producers.
• As awareness and knowledge on the subject tends to determine their recycling behaviour
‘recycling culture’ requires deeper thinking including role of different social actors, and
how to mainstream the concept of recycling society.
• Challenges have been identified, such as, waste aggregation is not discussed much despite being an • Areas for further action and research have been identified: several micro studies are required on different
important concern, cherry picking of e-waste for recycling, paper trading and leakage of e-waste make components of e-waste management.
several players feel ‘lack of level playing field;’ • For example, to quantify the impact of e-waste
• document submission related compliance is low and how to increase it through regular monitoring; • Other ideas for action include creation of a knowledgebase, developing a strategy for raw materials and
cost of compliance for every producer and every product needs to be worked out; secondary resource, market for sale of recovered/secondary material and linkages to be developed,
• tie up of bulk consumers, producers, and PROs with government run platform like MSTC and capacity building of regulators, debate and engagement with informality,
streamlining process of metal scrap auctioning; • deepening engagement of SPCB with OEMs and formal recyclers, cross-ministry collaboration for
• need for sectoral ‘should cost analysis’ including procurement, logistics, recycling and recovery, and developing effective policies and programme on e-waste.
administrative, etc. need for initiating processes of dialogues and • The environment justice perspective draws attention on uneven distribution of economic benefits and
• networking among different stakeholders, especially the recyclers and PROs rather increasing environmental health costs. The ‘producer’ focused policy (EPR) encourages the private companies to
take profit-oriented strategies and hence leads to involvement of the formal recycling companies.
competitive and conflicting areas of interests; need for fostering informal-formal partnerships; and so
on. • This equation is the most suitable to the concept of CE, and intent of safe environment and human health
but does not enter policy debates showcasing the existing inequality, that is,
• Regarding recycling/treatment of e-waste, stan_x0002_dardisation of depollution practices is
required; along with collection of e-waste, • environmental health hazards faced by socially and economically powerless workers and local residents
or its potential root cause.
• resource recovery targets need to be specified; how to finance recycling infrastructure and
technology, and creating market access for sale of secondary materials are challenges that are to be • This set of stakeholders is yet to be engaged with and to be recognised in the policy-making in India.
addressed.