E- Waste Management

(21EC755)

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 Introduction
• Fastest growing waste stream in the developed world as a result of advancing
technology that leaves behind old computers, laptops, televisions, and other
electronic devices that require specialized methods of recycling because of toxic
by-products.

• Products that are unwanted, not working, and nearing or at the end of their “useful
life.”

• Major concern regarding end-of-life products (EOL) is environmental

contamination and seepage into the food chain.

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 Most accepted definitions of E-Waste:
• An e-product becomes e-waste when its owner discards the whole product or its parts without an
intention to reuse it.

OR

• Anything with a plug, electric cord or battery (including EEE) that has reached the end of its life, as
well as the components that make up these end-of-life products.

• Electronic waste is the term for discarded electrical and electronic equipment that is no longer in use.

• E- waste Management is the process of collecting , transporting, recycling, refurbishing and disposing
of e-waste in an environmental friendly way.

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Home Appliances Electronic Utilities
•Microwaves •Massage Chairs
•Home Entertainment Devices •Heating Pads
•Electric cookers •Remote Controls
•Heaters •Television
•Fans Remotes Office and Medical Equipment
•Electrical Cords •Copiers/Printers
Communications and •Lamps •IT Server Racks
Information Technology •Smart Lights •IT Servers
Devices •Night Lights •Cords and Cables
•Cell phones •Treadmills •WiFi Dongles
•Smartphones •FitBits •Dialysis Machines
•Desktop Computers •Smart Watches •Imaging Equipment
•Computer Monitors •Heart Monitors •Phone & PBX systems
•Laptops •Diabetic Testing •Audio & Video Equipment
•Circuit boards Home Entertainment Devices Equipment •Network Hardware (i.e. servers,
•Hard Drives •DVDs switches, hubs, etc.)
•Blu Ray Players •Power Strips & Power Supplies
•Stereos Uninterrupted Power Supplies (UPS
•Televisions Systems)
•Video Game Systems •Power Distribution Systems (PDU’s)
•Fax machines •Autoclave
•Copiers •Defibrillator
•Printers 8
E-waste, also known more technically as WEEE (Waste Electrical and Electronic Equipment)
or EEE (electrical and electronic equipment) for short, can be defined as “any discarded
product that has a battery and/or plug, contains hazardous substances, and can pose a severe
risk to human health and the environment .

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 Module 1

Sustainable development and e-waste management

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Importance of electrical and electronic equipment in a nation’s development
and e-waste as toxic companion of digital era
• A country’s development or any modern society is often epitomised with the
communication revolution of 1980s and the digital revolution since the 1990s. The
communication revolution has brought enormous changes in the way we organise our
lives, our economies, industries, and institutions.
• The revolution is observed in form of development, comfort, technological advancement
and ever-increasing sale of these products. The digital technology facilitates
transformation of information, communication, transportation, energy supply, health, and
security systems, making a country more productive and developed.
• E-Waste Recyclers India (EWRI) was founded by Mrs. Sunita Arora in 2010, a Graduate
from Delhi University with a background of working with several NGOs and Social
Activists.
• E–Parisaraa Pvt. Ltd.(Peenya, Bengaluru), estd. In 2004 is India's first Government
approved Electronic Waste recycling company approved by both Central Pollution
Control Board and Karnataka State Pollution Control Board.
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Global e-Waste Monitor 2024:

The United Nations Institute for Training and Research (UNITAR) has released the Global
E-waste Monitor 2024, which states that the world's generation of electronic waste is
rising five times faster than documented e-waste recycling.

Global Ranking: India is currently ranked third globally among the largest e-waste
generators, following China and the United States.

The report foresees a drop in the documented collection and recycling rate from 22.3% in
2022 to 20% by 2030 due to the widening difference in recycling efforts relative to the
staggering growth of e-waste generation worldwide

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• In Global E-waste Monitors (GEM) 2017, 44.7 Mt e-waste described as equivalent to 4,500
Eiffel Towers (Baldé et al. 2017: 4).

• The PACE (Platform for accelerating the circular economy) and WEF (World Economic Forum)
report (2019: 9) describes that about 50 million tonnes of e-waste is produced every year,
which is equivalent to the mass of 125,000 Jumbo Jet aircrafts.

• The latest, GEM 2020, informed that in 2019, the world generated 53.6 million metric tonnes
(Mt) (7.3 kg/inh2), of this, 17.4% was officially documented as properly collected and recycled.

• In 2016, the world generated 44.7 million metric tonnes (Mt) e-waste or an equivalent of 6.1
kilogram per inhabitant (kg/inh) annually;

• In 2014, 41.8 Mt/5.8 kg/inh e-waste was generated.

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 Contd….
➢A record 62 million tonnes (Mt) of e-waste was produced in 2022, Up 82% from
2010

➢On track to rise another 32%, to 82 million tonnes, in 2030

➢Billions of dollars worth of strategically-valuable resources squandered, dumped →

Just 1% of rare earth element demand is met by e-waste recycling (aluminum,
platinum, rare element like neodymium)

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Global Scenario for E-waste
• Worldwide, the annual generation of e-waste is rising by 2.6 million tonnes annually, on track to
reach 82 million tonnes by 2030, a further 33% increase from the 2022.

• Municipal solid waste generation is predicted to grow from 2.1 billion tonnes in 2023 to 3.8
billion tonnes by 2050.

• E-waste is the fastest growing solid waste stream in the world. In 2019, an estimated 53.6 million
tonnes of e-waste were produced globally, but only 17.4% was documented as formally
collected and recycled.

• In India, among top ten cities, Mumbai ranks first in generating e-waste followed by Delhi,
Bangalore, Chennai, Kolkata, Ahmedabad, Hyderabad, Pune, Surat and Nagpur. The 65 cities
generate more than 60% of the total generated e- waste, whereas, 10 states generate 70% of the
total e-waste.
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 1. Let’s understand e-Waste
Life cycle of an e-product

Lifespan of any e-product could be increased with repair and refurbishing(renovate,

restoration), and could be brought to reuse
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The Essential Role of Raw Materials in Electronics

Silicon (Si) (Silicon, widely utilized in semiconductors, serves as a key element in microchips and
integrated circuits. Its abundance, cost-effectiveness, and amenability to doping with other elements
facilitate the creation of diverse transistors for switching, amplification, or signal storage.
Copper (Cu)
Copper (Cuprum), renowned for its conductivity, ductility, and corrosion resistance, takes center stage in
manufacturing electrical wires and traces. These components play a vital role in connecting different
elements and transmitting electrical currents.
Gold (Au)
Gold (Aurum) assumes a pivotal role in crafting electrical contacts and connectors, ensuring stable
connections between components and printed circuit boards (PCBs) due to its conductivity, inert nature, and
durability under various conditions.
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Silver (Ag)
Silver (Argentum), with its reflective, efficient, and versatile properties, is widely used in creating LEDs,
contributing to light production and image display.

Tin (Sn)
Tin (Stannum), prized for its low melting point, malleability, and compatibility with other metals, emerges as
the preferred material for solder, facilitating robust bonding between components and PCBs.

Tantalum (Ta)
Tantalum finds its prominence in capacitor manufacturing, offering high capacitance, stability, and resistance
to heat and corrosion. It excels in storing and releasing electrical charges within small dimensions.

Cobalt (Co)
Cobalt, electrochemically active and durable, plays a crucial role in crafting lithium-ion batteries, enhancing
energy density, safety, and lifespan.

Lithium (Li)
Lithium, being light, reactive, and abundant, takes center stage in the electrolyte of lithium-ion batteries,
enabling the flow of ions between electrodes and providing high voltage, capacity, and efficiency.
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Disposal Methods
Incineration: Electronic equipment, appliances, and devices have components that traditional recycling can't
recover. These items may be suitable for incineration. High-temperature controlled burning breaks down the
combustible parts of e-waste, so they take up less space in landfills.

Landfilling. This refers to the practice of essentially digging a massive hole in the ground, filling it with waste
and then covering it back up with soil.

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WEEE is different from any other waste (solid, liquid, bio-medical, and construction waste) on two counts:
1. E-waste contains hazardous waste..Toxicity of hazardous substance get leached to soil and water and
contaminate, which can cause serious environmental and health problems
2. WEEE is a complex waste flow in terms of variety of products, composed of different materials and
components, contents in hazardous substances and growth pattern.
• Materials used in e-products can be classified into 4 main groups: metals, rare earth elements, plastics
and other petroleum-based materials, minerals and non-metallic materials 23
• Other than proper disposal by the users, treatment, and management of WEEE in Environmentally Sound
Manner (ESM) is stressed upon
• ESM refers to scientific methods for resource recovery, doing away from largely prevalent rudimentary
methods of recycling of e-waste, such as, acid bath, open burning of wires and cables, etc. and manual
scrapping/dismantling to certain extent. Different care aspects against improper recycling and disposal
processes used for treating e-waste pose serious threats to human health (failure of organs, diseases, and
adverse impact on skin and other parts of human body), and environment in order to prevent health hazards are
critical
• Municipal solid waste (MSW) management considers the framework of 3Rs – reduce, reuse, recycle; its
recycling is associated with energy generation and other by-products related benefits.
• E-waste requires additional considerations in this existing framework of waste management, mainly because
of presence of hazardous substances, metals, glass, plastics and other elements.
• 6R framework for e-waste :
reduce, reuse, recycle, repair, refurbish, resource recovery
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 E-waste management thinking across the globe
• Until 2010, e-waste was closely associated with safe environment and human health through legislation or
its management under the EPR as a strategy, adopting waste management framework.
• In the last 5 years or so, 2 more aspects:
❖ first, the consumer is the purchaser of electronics as well as the generator of e-waste; and
❖ second, in the digital era, e-products are epitome of development, efficiency, and comfort and
transforming entire production and market system of various products as well as activities in various
sectors and hence consumption of electronic gadgets is likely to increase multiple folds, and in turn
increase in e-waste generation.
• Higher rates of e-waste generation = shorter life cycles of e-products + fewer repair options.
• Thus, introducing resource recovery, resource efficiency (REs) and circular economy (CE) link with
recycling/ treating e-waste.
• Spreading awareness among users of e-products, user roles in minimizing e-waste, and contribution to tax
regime/fees for recycling also have become the agenda of e-waste management. 26
Components of e-waste management

* Restriction on Hazardous Substances(RoHS)

* Resource Efficiency(RE)
* Circular Economy(CE)
* Extended Producer Responsibility(EPR) 27
 Evolution of legal definitions of e-waste
• Until 2007, there was no globally accepted standard definition of e-waste

• With evolution of legal frameworks, e-waste has been defined based on its characteristics, such as use of hazardous
elements, chemicals, and organic persistent pollution; and therefore, transboundary movements of e-waste have been
under vigil through regulations.

• Internationally, 3 sets of legislation/regulatory frameworks exist mainly for management of e-waste:

• (i) EU (European Union) legislations applicable to EU countries, such as Restriction on Hazardous Substances (RoHS)
Directive and WEEE Directive – and a regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH)

• (ii) Multi-lateral environmental agreements including The Basel Convention on the Control of Transboundary
Movements of Hazardous Wastes and their Disposal (henceforth Basel Convention), Rotterdam Convention on the Prior
Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade (1998), and
Stockholm Convention on Persistent Organic Pollutants (2001);

• iii) Strategic Approach to International Chemicals Management (SAICM).

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The definition of e-waste as per the WEEE Directive :
“Electrical or electronic equipment which is waste including all components, subassemblies and
consumables, which are part of the product at the time of discarding.”

• The Directive 75/442/EEC, Article 1(a) defines “waste” as “any substance or object which the
holder disposes of or is required to dispose of pursuant to the provisions of national law in
force.”

• (a) ‘electrical and electronic equipment’ or ‘EEE’ means equipment which is dependent on
electrical currents or electromagnetic fields in order to work properly and equipment for the
generation, transfer and measurement of such current and fields falling under the categories set
out in Annex IA to Directive 2002/96/EC (WEEE) and designed for use with a voltage rating not
exceeding 1,000 volts for alternating current and 1,500 volts for direct current.

• The Basel Convention covers all discarded/disposed materials that possess hazardous characteristics
as well as all wastes considered hazardous on a national basis. 29
• The Solving the E-waste Problem (StEP) initiative in its White Paper (UNU/ StEP 2014: 4) establishes importance of
definition of e-waste, mentioning that “There is global inconsistency in the understanding and application of the term
“e-waste” in both legislation and everyday use. This has resulted in many definitions contained within e-waste regulations,
policies and guidelines”…To provide a foundation to support the definition of e-waste, it is necessary to first define
electrical and electronic equipment (EEE). The StEP definition of EEE is:

‘E-Waste is a term used to cover items of all types of electrical and electronic equipment (EEE) and its parts that
have been discarded by the owner as waste without the intention of reuse.’

• Three terms are explained as part of the definition in StEP White Paper (2014: 5):

• As there is no room for regional variance or preference in a global definition; the fact that the item in question meets
the definition “with circuitry or electrical components with power or battery supply” qualifies it for inclusion.
The inclusion of “parts” within the definition refers to parts that have been removed from EEE by disassembly
and are electrical or electronic in nature…The use of the term “discarded” meaning to throw away or get rid of as
useless. The term implies that the item in question is considered excess or waste by the owner. It is the critical point
at which the potential nature of the item changes from a useful product to that of waste.
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• The recast of the WEEE Directive comprise of 6 categories of e-waste were
evolved; at present these categories are followed in the GEMs – 2014, 2017 and
2020. They are:

❖ temperature exchange equipment;

❖ screens and monitors;

❖ lamps;

❖ large equipment;

❖ small equipment; and

❖ small IT and telecommunication equipment

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 II E-waste statistics: quantities, collection and recycling

• GEM published by the UNU (United Nations University) in 2014, 2017 and 2020 are the most important

documents that capture e-waste statistics from all the countries across the world since 2009 and

considered to be the only authentic source for quantity of e-waste.

• At present, 54 EEE product categories are grouped into six general categories that correspond closely

to their waste management categories.

• Based on these categories, e-waste generation, collection, recycling, intrinsic value, number of countries

having e-waste legislations, etc. statistics are generated and harmonised across the world.

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E-waste categories and harmonizing statistics

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• The difference of e-waste generated in developed versus developing countries is quite large. The richest
country in the world in 2016 generated an average of 19.6 kg/inhabitant, whereas the poorest generated
only 0.6 kg/inhabitant (MeitY & NITI Aayog 2019: 29).

• Africa region:

• Total 2.9 Mt e-waste generated– 5% of total e-waste generated in the world

• Highest e-waste generation per inhabitant is Southern African countries with 6.9 kg/inh(inhabitant).

• South Africa, Morocco, Egypt, Namibia and Rwanda have some facilities in place for e-waste
recycling

• Nigeria, Ghana and Kenya are reliant on informal recycling.

• Of 53 countries in Africa, 13 countries have a national legislation, regulation or policy in place

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Americas (north and south) region

• Total e-waste generation was 13.1 Mt in 2019, which is almost 25% of total e-waste generated in the world.

• Of this, almost half of it is generated by America (6.9 Mt), 20.9 kg/inh in North America followed by Brazil (2.1 Mt);

• Jamaica is the least e-waste generating country with 18 kt (kilo tons).

• 1.2 Mt is documented to be collected and recycled, mostly coming from North America

• Of 34 countries in America, 10 countries have a national legislation/ regulation/policy in place.

Asia region

• Total e-waste generation was 24.9 Mt (5.6 kg/inh) from 46 countries with 4.45 billion population in 2019

• Three countries generating the highest e-waste in Asia are: China (10.1 Mt), India (3.2 Mt, Japan (2.6 Mt), and
Indonesia (1.6 Mt) while Kyrgyzstan produces the least (10 kt).
• Of 46 countries, 17 countries have a national legislation, regulation or policy in place.

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Europe region
• Total e-waste generation was 12.0 Mt from 39 countries in 2019; little more than one-fourth of the total e-waste generated in
the world

• Total 5.1 Mt (42.5%) documented to be collected and recycled e-waste.

• Germany generated 1.6 Mt the highest quantity of e-waste in Europe, followed by Great Britain (1.6 Mt), and Italy (1.0 Mt)

• Europe, Switzerland, Norway and Sweden show the most advanced e-waste management practices across the globe.

• Of 39 countries, 37 countries have a national legislation, regulation or policy in place

Oceania region

• Total e-waste generation was 0.7 Mt from 13 countries

• 0.06 Mt was documented to collected and recycled

• Top country with the highest e-waste generation in absolute quantities is Australia (0.55 Mt, 21.3 kg/inh) followed by New
Zealand with 96 kt.

• Of 12 countries, one country has a national legislation, regulation or policy in place 36

• Australian government implemented its National Television and Computer Recycling Scheme in 2011.

• Official data shows that only 7.5% of the e-waste generated in Australia is documented to be collected and recycled while in New Zealand
and the rest of Oceania, the official collection rate is NIL. The e-waste is now mostly landfilled.

• Across the Pacific Island countries, e-waste management practices are predominantly informal. The Pacific Island sub-region, consisting of
22 countries and territories (PICTs) faces unique challenges due to their geographical spread regarding e-waste collection and recycling

• Data from undocumented flows of e-wastes revealed substantial emission of CO2 and BFRs(Brominated flame retardants), and
deposition of mercury.

• The link between emission of CO2 and global warming leading to climate change is well-established.

• Mercury is persistent and bio-accumulative in the environment and retained in organisms.

• Most of the mercury found in the environment is inorganic mercury, primarily entering the environment through emissions to the air from
several sources.

• Suggestions given by GEM 2020: implementation of EPR, strengthen monitoring for legal compliance, creating favorable investment
conditions for recyclers, incentivizing informal sector to give away e-waste to formal recyclers, evolving financing models (upfront fee
by the producers, making consumers responsible for disposal of e-waste, and adopting market share approach for financing operational
costs), and so on
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 *GHG: Greenhouse Gas
Emissions

• Associations between exposure to informal e-waste recycling and health problems, such as, adverse birth outcomes
(stillbirth, premature birth, lower gestational age, lower birth weight and length, and lower APGAR scores), increased
or decreased growth, altered neurodevelopment, adverse learning and behavioral outcomes, immune system function,
lung function and DNA damage, changes in gene expression, cardiovascular regulatory changes, rapid onset of blood
coagulation, hearing loss, and olfactory memory are reported
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 E-waste flow and data on transboundary movements
• Transboundary movement is considered to be a way of dumping waste / e-waste from one country to
another.

• Important observations about transboundary movements of e-waste wherein 4 aspects or phenomena are
described:
(i) illegal trade which has intensified corporate, or white collar crime;
(ii) use of ‘second hand goods’ label – to disguise mislabel containers and mix waste with legitimate
consignment, and lack of reliable data on illegal waste activity;
(iii) recent emergent field of ‘green criminology’ – e-waste trade as an example, which poses
environmental risk and expected to be compliant to regulatory norms, though not criminalized as
such
(iv) security implications – more research is needed in order to find out more about the networks behind
the illegal export that is taking place
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Creating and updating statistics, datasets: opportunities and challenges
• Macro level data have begun to emerge and throw light on different aspects and trends of e-waste management, namely,
standard definition of e-waste, quantity of e-waste generated and treated, methodology, flow of e-waste including
transboundary movements, and initiatives towards achieving 2030 Development Agenda.

• Three GEMs (2014, 2017 and 2020) at the regular interval of three years is considered to be trendsetting and
promising initiative for statistics and exploring existing e-waste scenario. Advantages and disadvantages of every
method are elaborated, challenges of creating and updating data are also articulated – gaps are identified, processes
that lead to misinformation or wrong labelling and misleading data are identified.

• GEM 2020 has begun build up data on 3 important aspects of e-waste management –

› Circular Economy(CE), toxicity and Impact on children and workers

• As more countries are adopting e-waste legislation/regulatory policy, it is important to provide data that facilitate the
complexities of decision-making, for example, whether to treat e-waste domestically or through export, issues that
are of environmental, political, economic and ethical nature and how to address them by legal framework.
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 III. An overview on status of e-waste related legislation across the globe

• The legislation largely focusses on regulating guidelines for collection, reuse and recycling of e-waste, except New

York city of USA which has introduced landfill bans of scrap.

• Other initiatives include setting up take-back channel, initiating programmes for collection and recycling and

appointing private companies for recycling, or regulating e-waste through a directive or administrative

regulation.

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 Year Countries covered under legislation

2014 61

2017 67

2019 78

• In many countries, government control of e-waste sector is minimal, and infrastructure for recycling is non-existent

or grossly mixed; overall the informal sector is dominant in collection, refurbishing and repairing e-waste.

• Regarding recycling and legislation, Patil and Ramakrishna (2020) observed that, as there is no uniformity in e-

waste legislation across all the countries, it is difficult to monitor e-waste recycling on a global scale

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• The economic condition of the countries influences their domestic e-waste production and management.
In East-Asia, the official collection rate is close to 25% but in Central and South Asia, it is still nil
(informal sector).

• China levies penalty on non-compliance of the administration of e-waste.

• Overall, not many countries reported more than 25% of e-waste collection and recycling across the
world

• In the case of Africa, particularly western Africa (e.g. Ghana and Nigeria) as a dumping yard destination
for e-waste from various regions of the world is discussed in the context of legal framework, and two
concerns are highlighted:
➢ First: illegal import of e-waste, and
➢ Second: recycling activities carried out in informal basis and the residues are landfilled,
impacting the health of recycling workers and local environment.

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Relevance of international legislative frameworks across the globe:
trends and challenges

• Internationally, mainly three sets of legislation/regulatory frameworks exist for management of e-

waste:

(i) EU legislations applicable to EU countries

(ii) multilateral environmental agreements (MEA)

(iii) SAICM (strategic approach to international chemicals management)

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 (i) EU legislations applicable to EU countries
• Applicable to EU and its member states

• The regulatory framework of EU, especially WEEE Directives, have followed the terminology of

product life cycle thinking by encouraging producers to prevent waste generation in the first instance…By
following this principle, the member states are expected to adhere the following:

“prevention of waste, preparation of waste for reuse, recycle waste, other recovery (e.g. energy), and disposal”

• EU legislation includes the following regulatory frameworks –

(i) RoHS Directive (2002/95/EC – RoHS1) by EU) in 2003 and subsequent amendments in 2011 (2011/65/EU – RoHS2),
2017 (amending Annex II of RoHS2), and Directive (EU) 2015/863 – RoHS3;29

(ii) WEEE Directive (2002/96/EC), 2003 and WEEE 2 (Directive 2012/19/EU), 2014; and

(iii) The regulation on REACH (Registration, Evaluation, Authorization, and Restrictions of Chemical Substances)

(EC1907/2006).
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 WEEE directives
• WEEE directive is set out over 19 articles, among them the important ones are:

scope (Article 2–10 categories of WEEE), definitions (Article 3), product design (Article 4), separate

collection (Article 5), treatment (Article 6), recovery (Article7)

• Other Articles provide details on responsibilities of different stakeholders include registration and
reporting to national authorities on volumes of EEE placed on their market; organizing and/or
financing the collection, treatment, recycling, and recovery of WEEE and providing specific
information to recycling companies; and labelling products with the crossed-out wheelie bin symbol to
allow for correct disposal by end-users.

• WEEE Directive sets out the financial responsibilities; and mandates the treatment, recovery, and
recycling of EEE by every producer; and encourages the design of electronic products that
ensures environmentally safe recycling and recovery.

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• All applicable products in the EU market after 13 August 2006 must pass WEEE compliance and carry the
wheelie bin sticker. The WEEE Directive covers collection and recycling of waste from a broad range of EEE
at their EoL solutions.

• 5 areas of e-waste management are addressed under the EPR, namely:

(i) production, including improved product design

(ii) distribution

(iii) consumption (by domestic and business consumers) and separate collection of e- waste

with targets specified for recovery, reuse, and recycling of different classes of WEEE (creating take-back

channel by the producer)

(iv) e-waste handling – reuse, recycling, and recovery

(v) e-waste treatment and disposal including specifications for exporting e-waste for treatment
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 RoHS(Restriction of Hazardous Substances)
• RoHS Directive is enacted by Article 95 of the Treaty establishing the European Community
(Treaty Amsterdam 1997), which has much less flexibility that those enacted by article 175 such as
the WEEE Directive

• RoHS Directive is set out in 10 articles and an associated annex and should be read in tandem with
its sister legislation – the WEEE Directive.

• RoHS1 required that any product in scope should not contain any of the six restricted substances
(Lead, Mercury, Cadmium, Hexavalent Chromium and Flame Retardants – Poly Brominated
Biphenyls (PBB) or PBDE) and its weight; the company (manufacturer, importer, or distributor)
placing the product on the EU market should maintain records to show compliance; and these
restricted substances need to be substituted by safer alternatives

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• RoHS2 requires additional compliance, that is, recordkeeping from everyone in the supply
chain at least for ten years (including a conformity assessment, CE marking, maintenance of
compliance throughout production, and self-reporting of non-compliance).

• RoHS3, or the Directive 2015/863, adds four additional restricted substances (phthalates) to the
original list of six substances, as cited under the REACH regulation;

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 REACH (registration, evaluation, authorisation and restriction of chemicals)
• Released in 2006 and entered into force on June 1, 2007
• Adopted by EU to improve the protection of human health and the environment through the better and
earlier identification of the intrinsic properties of chemical substances, deals with 197 Substances of Very
High Concern (SVHC).
• This regulation impacts almost every product made in or imported into the European Economic Area (EEA).
This is done by the four processes of REACH, namely the registration, evaluation, authorisation and
restriction of chemicals and places the burden of proof on companies.
• Regulation affects the use and sale of a vast array of items, ranging from industrial goods to cleaning
products, clothing, furniture and appliances.
• REACH places responsibility on the manufacturer/producer for ensuring that any chemicals they put
on the market are properly assessed and managed in terms of their risks.
• REACH also aims to enhance innovation and competitiveness of the EU chemicals industry
• Manufacturers and importers of EEE are required to gather information on the properties of their
chemical substances, which will allow their safe handling, and to register the information in a central
database in the European Chemicals Agency (ECHA) in Helsinki.
• REACH manages the databases necessary to operate the system, co-ordinates the in-depth evaluation of
suspicious chemicals and is building up a public database in which consumers and professionals can find
hazard information 51
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 Link between RoHS, WEEE and REACH
• These are the 3 key pieces of legislation relating to EEE and WEEE
• All 3 frameworks lay out results that must be achieved by the European countries, but each country is free to
choose the means of achieving those results when transposing European rules into national laws
• WEEE and RoHS Directives deal with complex sets of WEEE (both apply to the same range of products with
some differences)
• RoHS regulates the hazardous substances (wiring, components, circuit boards, displays, subassemblies, cabling)
used in the manufacture of EEE while WEEE regulates the disposal of this same equipment; REACH controls all
chemicals (enclosures, brackets, coatings, paints, solvents, etc.) and that might be used to manufacture EEE.
• All the RoHS restricted substances (identified as being carcinogenic, mutagenic, reprotoxic, bio-accumulative and
toxic, or as endocrine disruptors) are also on the REACH restricted list.
• RoHS compliance unites into WEEE by reducing the amount of hazardous chemicals used in electronics
manufacture
• EPR is a common feature/framework in these legislations; much more responsibility is put on producers to deal
more effectively with the e-waste and e-products they produce.
• Producers are tasked with extensive reporting and monitoring procedures to demonstrate compliance with the
regulation. The waste hierarchy has been extended and prioritised as prevention, reuse, recycle, recovery and,
as a last resort, disposal of waste.
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(ii) Multi-lateral environmental agreements (MEA)

3 important international conventions seeking to control the shipping of waste; after these, various

regional conventions have been signed to regulate hazardous waste movements. They are:

(i) Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their

Disposal (1989);

(ii) Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals

and Pesticides in International Trade(1998);

(iii) Stockholm Convention on Persistent Organic Pollutants (2001)

54
55
56
57
 The Basel Convention
• Initiative of UNEP(United Nations Environment Programme), which focuses on controlling
transboundary movements of hazardous wastes and its disposal
• First adopted on 22 March 1989 by the Conference of Plenipotentiaries in Basel, Switzerland, in
response to public outcry following the discovery about toxic waste flowing to Africa and other parts of
developing world, in the 1980s.
• Convention came into force in May 1992, and started working on e-waste in 2002, with later addendums
in 2006 (Nairobi Declaration) and 2011 (Cartagena Decisions).
• In 2006, the EU transposed the Basel Convention and the OECD(Organization for Economic Co-
operation and Development) Council Decision into European regulation with the European Waste
Shipment Regulation (WSR).
• WSR implements the international obligations of the two regulations and includes the
internationally agreed upon objective that wastes shall be disposed of in an environmentally sound
manner.
• Regulatory system under the Basel Convention includes prior informed consent for export and import;
and the intended movement is possible only after receiving written consent from both the concerned
state authorities. 58
The Basel Convention continued…
4 important aims of the Convention related to e-waste, as follow:
❑ Prevention – to reduce hazardous waste generation at its source;
❑ Reduction to promote and ensure the environmentally sound management of
hazardous waste;
❑ Resource recovery – to promote the proximity principle, advocating disposal as close
to the source as possible; and
❑ Final disposal – to regulate and monitor the remaining transboundary movements of
hazardous waste.
Under Article 6 of the Convention, the hazardous waste shipment must undergo the prior
informed consent (PIC) procedure – this system requires exporters to notify the
destination country, any intermediary countries, of its intent to conduct trade in hazardous
waste, through a notification of consent prior to the transboundary movement.
59
The Basel Convention continued…
• To combat illegal traffic of e-waste, the Convention provides for the development of tools and training
activities through the Green Customs Initiative (GCI)
• Basel Convention started to address e-waste issues in 2002 through the adoption of The Mobile Phone
Partnership Initiative (MPPI). After which the Nairobi Declaration (during COP842) was adopted which gave
a mandate to the Secretariat to implement the environmentally sound management of e-waste.
Importance of the Basel Convention:
• If properly implemented and enforced, negative impacts of treating waste at the importing state could be
prevented
• Procedures for legal cross-border movements have set up mechanisms for avoiding ecological disasters and
maintaining a high level of protection of workers and the public.
• The shipment can only take place if the state of transit and the state of import give their written consent.
Moreover, a confirmation is required of a contract between the exporter and the disposer specifying ESM.
Synergies among the Basel, Rotterdam, and Stockholm conventions are:
• Promote a life cycle approach to chemicals management as each convention targets different stages of a
chemical’s life cycle; and developing programmatic cooperation and support for the implementation of the
three conventions in areas of common concern, such as e-waste
60
(iii) The strategic approach to international chemicals management(SAICM)

• Is an international policy framework to promote chemical safety, adopted by the First International
Conference on Chemicals Management (ICCM1) at Dubai, on 6 February 2006, with the overall objective of
achieving sound management of chemicals throughout their life cycle.
• ICCM2, agreed to initiate a project on chemicals in e-products with a multi-stakeholder and multi-sectoral
character .
• This approach aims at minimising the way chemicals are produced and used in ways which by 2020, in order
to minimise significant adverse impacts on environment and human health. Its objectives are grouped under
five themes:
✓ risk reduction
✓ knowledge and information
✓ governance
✓ capacity building
✓ technical cooperation
✓ illegal international traffic
61
 SAICM continued..
• This policy framework is closely linked to three regulatory frameworks, they are:

(i) London Guidelines for the Exchange of Information on Chemicals in International Trade (1989)

(ii) Montreal Protocol

(iii) The Minamata Convention on Mercury, 2013.

• Complementing international and regional conventions, international organizations also have an important role to play, for
example, in monitoring the transport of toxic substances and running programmes to reduce the impact of e-waste on
human health and the environment.

• The Basel Convention, WEEE Directives, MEA and national legislative framework, shows that the WEEE Directives
seemed to be most comprehensive in nature since they have defined e-waste and introduced EPR. Cumulatively, these
regulatory frameworks have impacted three strategic points of e-waste management in India –

❑ first, acceptance and implementation of EPR

❑ second, recover resources and enhancing CE

❑ third, improvement in environment and human health.

62
• The existing regulatory frameworks have promoted institutional mechanism, guidelines for
implementation of legal provisions, widening net of stakeholders and defining their
responsibilities, and spreading awareness about use of chemicals (hazardous and non-hazardous)
and their impact on environment and human health.

63
 Increasing thrust on circular economy
• CE approach intends for restorative economy and to create a regenerative system of handling e-waste by handling
them in closed loops through which optimal reuse, renovation, remanufacturing, and recycling of products and
efficient recovery of materials could be ensured.

• For efficient resource recovery, it focuses on product design, e-waste collection and disposal practices and
mechanism, recycling technology, reuse, etc., and closing resource loops by employing reverse supply chain and the
reverse logistics strategies/frameworks.

• By improving e-waste collection and recycling practices worldwide, a considerable amount of secondary raw materials
– precious, critical and non-critical – could be made readily available to re-enter the manufacturing process while
reducing the continuous extraction of new materials.

• This entire loop including proper EoL services, and reuse of EoL products, facilitated by specific government’s
regulations, has generated new economic markets, and new entrepreneurial activities, which has great economic
potentials across the world. This way, CE is gaining greater relevance in academic research and policy making agenda.
In this context, reverse logistic processes of collection, recycling and reuse of e-waste plays a critical role for different
reasons; also, can be regarded as a business strategy in which recovery activities are imposed for the purpose of increasing
sustainability 64
 Increasing thrust on circular economy (continued….)
• CE as a concept employs REs, resource recovery and re-using resources; making suitable shift to 6Rs
framework (repair, reuse, refurbish, responsibly disposed, recycle and resource recovery) from the existing 3Rs
framework (reduce, recycle and reuse), making management of secondary materials an integral part of e-waste
management.
• The RE considerations are now being advocated in the design products and increase in productivity other than
electrical and electronic sector, especially in the communications, construction and engineering sectors. The CE
and RE are stressed upon in the context of dominant presence of informal sector in several countries, from e-
waste collection to recycling, and final disposal.

65
 IV: UN initiatives for e-waste management: creating partnerships
and achieving Agenda 2030
• A number of global agencies have formed ‘Global E-waste Statistics Partnership’ (GESP) in 2017
to address e-waste challenges by improving e-waste data.
• As part of a range of initiatives : forming a group or an agency, initiating a programme or
intervention is noteworthy
• For example, co-ordinating with the Environment Management Group (EMG); the ‘Solving the E-
waste Problem’ (StEP) initiative; the Sustainable Cycles (SCYCLE) programme; and UNU-ViE
SCYCLE.(The Sustainable Cycles (SCYCLE) Programme is hosted by the United Nations University
Vice Rectorate (UNU ViE) in Europe in Bonn, Germany.)
• The partnership has achieved the result by publishing the second edition of the GEM 2017 and
building a website (www.globalewaste.org) to publicly visualise the most relevant e-waste
indicators. Other initiatives include training of people from 60 countries for internationally
adopted methodology for building statistics

66
SDGS: Sustainable Development
Goals

67
• The e-waste sub-indicator in SDG 12.5.1 has been defined as follow:

• Where the ‘Total e-waste recycled’ is equivalent to the ‘e-waste formally collected’ is divided by
the ‘e-waste generated’
• This method could be employed to examine extent of hazardous waste created in each country
every year.
• Sustainability and CE are two sides of a coin. The depletion of mineral deposits, declining metal
recoveries and grades, the concentration of strategic minerals in politically unstable regions and
general risks associated with primary mining
• The UNEMG report (2017) has documented UN systems’ response 154 initiatives covering ten
focus areas, and 12 types of interventions, and their focuses, types and performance across
different regions; along with various partnerships and collaborative efforts put in by the UN
systems in 14 years (between 2004 to 2017) by the 23 entities associated with UN systems.

68
• Taking cognisance of the existing informal e-waste system in different countries, of 154 initiatives by UN, 63 related to
recycling and ESM of e-waste, and 12 initiatives are Education/Employment/Health related, which indicate need for
addressing problems of recycling, health and environment.
• Of a total of 63 initiatives,
(i) 3 are related to acquisition of raw materials;
(ii) 4 are linked to design;
(iii) 5 each for production, transportation/delivery, repair;
(iv) 7 each for consumer use and reuse; and
(v) 12 each for EoL treatment, and final disposal.
• Types of initiatives undertaken by the UN are:
(i) one for standardisation; (ii) two for policies; (iii) three for programmes; (iv) six for working groups and workshops; (v) seven
each for glossaries and compilations, and trainings and learnings; (vi) 11 for partnerships; (vii) 13 for networks and consortiums;
(viii) quantitative assessments; (ix) 23 are studies and reports related; (x) 28 for projects; and (xii) 30 for preparing manuals and
guidelines.
• Total 139 collaborations and partnerships by UN provide an idea of various aspects of e-waste management and need for
addressing requirements on different counts. The characteristics of existing collaborations for e-waste management are:
• 68 (49%) collaborations are UN and public;
• 50 (36%) collaborations are UN and private; and
• 21 (15%) collaborations are UN-only 69
 V: Indian scenario: e-waste generation, collection and recycling
• India ranks third in the world with waste generation of 3,230 kt or 3.2 Mt in 2019 (2.0 Mt in 2016), 2.4 kg/inh followed by China (10,129 kt or
10.1 Mt, 7.2 kg/inh), and USA (6,918 kt or 6.9 Mt, 21 kg/inh).
• India moved up to third rank (in 2019) in three years from fifth in 2016, leaving Japan (2.1 Mt in 2016) and Germany (1.9 Mt in 2016) behind in
2019
• India collected and recycled 30 kt (0.030 Mt) in 2019,which is less than 0.036 Mt of its e-waste in 2016–2017. This reveals that the e-waste
generation in India is almost 60% higher in three years, as against its recycling capacity
• Some 95% of e-waste is managed by the informal sector in India including collection, transportation, dismantling, recycling, and selling of
secondary/recovered materials in the market.
• The informal sector broadly refers to existence, material and financial flows – it characterises an informal existence and setup (it may not be
registered as a dismantling or recycling unit) and follow a disorganised way of functioning, with an informal economy including cash
transactions, inadequate tools and safety measures, inadequate wages to labour, and often employing semi-skilled labourers or even
children, lack of social security for labour, etc; informal channels for e-waste collection, transportation and informal way (rudimentary
techniques) of treating e-waste; insufficient resource recovery; getting rid of e-waste residues; and remaining out of legal frameworks in
some ways. In the absence of a database, the number of jobs, levels of remuneration, and conditions of employment in e-waste management
remain largely unknown.
• E-waste in India is majorly processed using inefficient technologies, inadequate infrastructures, and improper and unhealthy eco-system.
• Despite being highly effective in collecting WEEE, its recycling techniques yield low extraction rates and result in large scale environmental
pollution, which negatively affects the physical wellbeing of thousands of people.
• In 2017, over 200 manufacturers of electronic goods, including some e-giants, were served notices by the Central Pollution Control Board
(CPCB) for not complying with e-waste procurement norms.
70
Historical, domestic e-waste in India: generation and composition
• GTZ and BIRD studies in 2007 calculated ‘the total annual e-waste generated in India in the year 2007 is
382,979 metric tonnes (MT),58 including 50,000 MT of imports in India…the amount available for recycling
was 144,143 MT but due to the presence of considerable refurbishment market only 19,000 MT of e-waste
has been recycled

71
 Historical, domestic e-waste in India: generation and composition
(continued….)
• Main sources of e-waste in India are the government, public and private industrial sectors, which
account for almost 70% of total e-Waste generation.
• An Indian Market Research Bureau (IMRB) survey of ‘e-waste generation at source’ in 2009 found
that out of the total e-waste volume in India, televisions and desktops including servers comprised
68% and 27% respectively. Imports and mobile phones comprised of 2% and 1% respectively.
• Large household appliances like washing machines and refrigerators in the overall e-waste stream
composition is not that significant but not disposing them (more than 50% stored quantities) reflect
disposal behaviours of consumers in India.
• Of a total of 2.0 Mt e-waste generated in India in 2016, 1.58 Mt (79% of the total) from unorganised
manner while 0.42 (21% of the total) Mt was from organised sector. Of the e-waste collected,
computers accounted for almost 70% of e-waste, followed by telecommunication equipment-
phones (12%), electrical equipment (8%) and medical equipment (7%) with the remainder
consisting of household e-waste .

72
 Historical, domestic e-waste in India: generation and composition
(continued….)
Imported e-waste in India
• It is estimated that approx. 80% originates from the USA, while the remaining 20% is predominantly
imported from the EU. As such, the import of e-waste is regulated with recent legislation in India, but until
2016 its import was illegal.
• The main global sources of e-waste are the United States, the EU, Australia, Japan and the Republic of
Korea, and the main recipients of e-waste are China and India, followed by Mexico, Brazil, the Eastern
European countries, and African countries, including Egypt, Ghana and Nigeria, among others.
• The E-waste Management Rules, 2016 tasks the state pollution control boards (SPCB) to make the estimates
of imported e-waste based on inventory prepared.
Futuristic projections for e-waste in India
• By 2020, the demand for e-products in India is expected to reach nearly $400 billion with a CAGR
(Compound Annual Growth Rate) of 41% during 2016–2020 (MeitY and NITI Aayog, 2019: 14).
• As a result, e-waste is likely to be increased by 30% during 2018–2020. Out of the 67.8 billion tonnes of
global material use, India’s share was about 7.1% amounting to 4.83 billion tonnes.
• With rising population and at the current high growth rates, India’s material use is expected to triple by
2030. According to GEM 2017, the estimated value of raw materials which can be mined from e-waste stood
at €55 billion, of which mobile phones alone constituted €9.5 billion
73
 Essentials of e-waste cohesive management thinking in India
• Employing EPR as management and enforcement strategy for various aspects of e-waste management
along with increasing thrust on RE and CE. Under the existing legal framework, i.e. the E-waste
Management Rules, 2016 and E-waste Management (Amendment) Rules, 2018 (henceforth ‘Amended
Rules, 2018’), effective implementation of EPR occupies centre stage.
• The producers or the producer responsibility organisation (PRO) is expected to establish collection
channel, segregation, safe transportation and ensure recycling of e-waste.
• The e-waste items are specified in the rules, and proportion of e-waste collection and recycling is also
specified for every consecutive year after 2016. The responsibilities of consumer and ‘bulk consumers’
are also specified in the rules.
• MeitY and NITI Aayog, Government of India has launched a document, titled, Strategy on REs in
EEE sector in January 2019. The strategy paper presents that RE would lead to CE, a key element to
sustainable development as well as the solutions to possible conflicts which can arise from socio-
economic, socio-political and politico-economic inter-relationships which are caused due to the scarcity
of resources. It also envisages linking of three missions – Make in India, Digital India, and Clean India
(Swachh Bharat) for effective e-waste management
• When essentials of e-waste management in India are thought of and enlisted, the need for material flow
analysis (MFA) is identified, which elaborates a list of essentials for cohesive e-waste management
thinking in India, as presented in the following chart
74
LCIA: Life Cycle Impact Assessment
MFA: Material flow analysis

75
 Essentials of e-waste cohesive management thinking in India(continued…)

• The management incorporates user’s behavior; technology (design product and sector-based growth);
business; inventorisation (e-waste generation, target collection and treatment to e-waste, shipment (if
applicable – transboundary movements), stages from collection to recycling including role of actors in
value chain, and logistics and its cost, EoL solutions, resource recovery and losses); and
implementation of policies.
• The impacts include environmental concerns – toxicity and pollutants (harmful chemicals), and
pollution of soil, water, and air; energy use during e-product production, consumption and disposal;
human health hazard due to exposure to e-waste containing toxins, natural resource (water, land,
energy) use and recovery; and clean and green technological solutions.
• The MFA for e-waste management works as a tool for comprehensive under standing on why, how,
where, and what of e-waste at different levels / with a certain categorization (e.g. national-level
assessment, regional-level assessment, product-level assessment, element-level assessment).
• The MFA helps in what supports a material balancing, conservation flow that brings in multiple axes –
e-waste generation estimation, material flow and stock estimation, potential material recovery, socio-
technical structure of WEEE management, economic sustainability of e-waste management system,
product substitution effects due to technology transition, product and element characterization, etc.

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Informal e-waste trade chain in India

• As per the rules of 2016, the EEE manufacturers and users (consumers, bulk consumers) are the generators of domestic
e-waste; the inflow of imported e-waste is observed, though legally banned.
• This is the first layer in this sequence of e-waste disposal and collection. The individual consumers are disposing e-
waste – either give away for reuse to individuals and institutions or sell it to the kabaadiwala. The bulk consumers either
auctioned off, sold to scrap dealers, or given away to PROs. The manufacturers dispose of e-scrap to scrap dealers, and
the imported e-waste is directly entering the trade by dealing with scrap dealers.
• The second level – e-waste collection introduces three actors – first level of kabaadiwala, scrap dealer/scrap trader/
government agency (MSTC) that trades in metal scrap/PRO, and scrap dealer/scrap trader who may or may not
refurbish the e-waste.
• In the third layer of dealing with e-waste, mainly the local kabaadiwala sell the e-scrap to city level waste aggregators.
• Before the e-waste steps to large-scale aggregators in the fourth layer, most e-waste is reported to be sorted, dismantled
and/or cannibalised.
• The last layer is of large-scale waste aggregators who may be informal recyclers; if not, they sell off e-waste to the
formal and informal recyclers. The e-scrap dealer/trader sells e-waste to the formal/informal recyclers while the PROs
pass on the e-waste to the formal/authorised recyclers for legal compliance. In this layer, leakage of e-waste is reported,
and thus, the e-waste (sorted, dismantled, cannibalised) come back to the market for resale. The last layer is of sale of
secondary material in the market for reuse/in the supply chain
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78
 Informal e-waste trade chain in India(continued…)

• In this trade value chain, the collection to recycling trade provides livelihoods to a
significant number of urban poor. Moreover, recovery of materials from this waste
and ploughing them back into the supply chain process are some of the advantages of
the sector. The flipside of the recycling sector is the hazardous practices and
processes.
• In this context, building up partnership of formal-informal players has been
considered as a strategic action for larger legal compliance and cohesive e-waste
management.

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 Opportunities and challenges of e-waste management in India
• Mainly 3 opportunities are seen in e-waste
• very high value material, especially gold, silver and platinum group metals;
• harvesting e-waste would lead to produce lesser CO2 emission compared to mining in earth’s crust, and in turn reduce global warming;
• and extending the life of products (revised product design, repair, refurbish) and re-using components brings even larger economic benefits.
Opportunities
• Proper separation of different elements from WEEE, recovering of the elements of economic value, and prevention of environmental pollution of
hazardous components depend on dismantling and recycling technologies
• For India, the FICCI CE Report, 2017 estimated,
“the business opportunity for extracting gold from e-waste is to the tune of $0.7–$1 billion (approx. 70–75 crore INR). Furthermore, one ton of ore has an
extractable reserve of about 1.4 grams of gold while a ton of mobile phone PCBs can produce about 1.5 kg”
• Contributing to methods for collecting data and creating reliable database is looked upon as an opportunity. Better e-waste data will eventually
contribute to minimising e-waste generation, prevent illegal dumping and improper treatment of e-waste, promote recycling, and create jobs in the
refurbishment and recycling sector.
• The GoI considers creating awareness about e-waste management among users, which would in turn help in effective implementation of existing legal
framework and producers’ of EEE and their pro-activeness for operationalising EPR are also seen as opportunities
• With the introduction and implementation of the rules in 2016, a few noteworthy opportunities were created, such as the possibility of creating database
statistics, the use of data for effective enforcement (monitoring and evaluation of achieving targets and compliance) and legal compliance, and
movement towards formal economy could begin (dealing with informal sector with competitive spirit and business activities) for domestic e-waste.
With this shift towards formal economy, more jobs would be created. Specific data on imports of e-waste would be useful in identifying transboundary
movement of e-waste and take necessary action for proper treatment of e-waste, may that be repaired and reused or recycled in ESM and EoL

80
 Challenges
• Practitioners of e-waste management have shared challenges, such as, establishing logistics and transportation
cost for collection of e-waste; recycling technology, economics and viability of recycling ventures; dealing with
informal sector and informal economy and how make a shift to formal economy through e-waste
management; and role of citizens and producers of EEE in effective implementation of the legal framework
and EPR respectively.

• The leakage of e-waste and resale of leaked e-waste being resold – from one vendor to another vendor or recycler
and returning to the market again, is a major problem reported. Such circulation of e-waste, without getting treated,
may show as ‘treated e-waste’ on paper for legal compliance is reported as a challenge.This is a challenge for
effective enforcement of the existing regulatory framework.

• Further, regarding technology, innovation and advancement including design of the product (planned
obsolescence, inability to repair, or software compatibility issues) and materials used, and sector-based growth are
closely linked; these aspects have remained peripheral issues, least talked about, least enforced under the broad
canopy of EPR

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 Challenges (continued…)
• On the other hand, the semi-formal or informal sector actors employ rudimentary techniques for recovery of materials, which
are risky and earning lower income compared to advance technology of recycling. Thus, as against the opportunity of
creating of jobs or livelihood for the workers, the informal sector in India creates challenges for e-waste management.
• Challenges of e-waste management in India, which are presently guided by complex dynamics. They are:
(i) producers have been tasked with ensuring collection of EoL material, and parallelly the informal sector has been handling
WEEE (from collection to recycling) through its wide network for the last few decades;
(ii) EEE is diverse Sustainable development and complex with respect to the materials and components used and, waste
streams from the manufacturing and recycling processes;
(iii) characteristics of e-waste is of paramount importance for developing a resource efficient, economically viable and
environmentally sound recycling system – high cost of setting up recycling facility and making it sustainable;
(iv) accurate and updated data on e-waste generation, flow, collection and treatment, and trends are also difficult to ascertain;
(v) mapping of documentation of the entire value chain is difficult, as there are several human actors involves, each with
different set of functions and responsibilities;
(vi) establishing linkage amongst stakeholders and preparing them with win–win situations through various incentives,
awareness measures, penalties, etc. is a challenge in itself;
(vii) little awareness amongst different sectors about the rules of 2016; and
(viii) strong implementation of legislation across the whole country, wherein exist.
82