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- The Indian government introduced the first set of rules pertaining to the safe disposal of electronic waste in 2011, and revised them in 2016 and 2018.
- But almost a decade later, the Comptroller and Auditor General of India that found only 5% of the country’s e-waste was being processed formally.
- Policymakers of the previous decade assumed that collection targets and mandatory formal recycling would drive resource recovery. They didn’t.
- As we aim to become a fully digital nation, we must bear in mind that the resources required to meet these aspirations are limited, non-renewable and often toxic.
- In this article, the authors present five regulatory mechanisms to set us on the path to reducing the amount of e-waste we generate.
With India’s growing per capita income, waste generation per person has also seen a steady increase. Waste collection and disposal have been in focus through programs like ‘Swachh Bharat’ and ‘Swachh Survekshan’.
However, as we start collecting more waste, an even bigger challenge has emerged, that of processing and disposal. Government and other stakeholders are quickly realising that to manage waste, the tap has to be closed. This can be done through better-designed products, improved repairability and institutionalising reuse so less waste needs to be recycled or disposed.
Regulations such as the recent Plastic Waste Management Amendment Rules 2022, bring in such a nuanced approach to managing plastic waste. The rules go beyond waste collection and make an important distinction between two types of processing: recycling and energy recovery, and prioritise the former.
Additionally, the Government of India is also phasing out some single-use plastic items with low utility and high littering potential by 2022 (under the Plastic Waste Management Amendment Rules 2021).
These recent regulations establish waste reduction as a key strategy to manage plastic waste. Waste reduction and resource recovery are also important from the resource sufficiency perspective. Local resource availability is a clear competitive advantage in this era of global supply-chain disruptions.
The industry often resists waste reduction as a strategy because it perceives reduced material consumption to be hurting the top line. But this is a misconception. Waste reduction is not just about bans; instead, it is about the servitisation of products: i.e. where the same product serves multiple users and/or serves for longer in a shared economy, through reuse, repair, refurbishment and remanufacturing.
Multiple service layers get added onto a product thus increasing the per product revenue while overall material consumption is reduced. This also leads to local job creation at the point of consumption instead of being concentrated at the point of manufacturing.
Waste reduction and resource recovery are particularly important for categories like electronic waste, a.k.a. e-waste. Most electrical and electronic equipment contain some precious, rare-Earth metals whose efficient recovery is essential because their supply is limited. Such equipment also contains some toxic elements that must be extracted and disposed safely.
Also read: New Indore Bio-CNG Plant Is Likely To Succeed Where Others Haven’t. Here’s Why.
A decade apart
The government introduced the first set of rules pertaining to these activities in 2011, followed by revisions in 2016 and 2018. Their key objective was to collect and formalise e-waste processing through the ‘extended producer responsibility’ (EPR) mechanism. Informal recycling is unsafe and inefficient at recovering resources, and causes serious health and environmental hazards.
According to a 2019-2020 report of the Comptroller and Auditor General, only 5% of India’s approximately 1 million tonnes of e-waste was being processed formally, with the informal sector managing the rest. Clearly, policymakers assumed that collection targets and mandatory formal recycling would drive resource recovery; they didn’t.
One key issue is poor implementation, even in developed nations with better compliance. Studies have shown that EPR implemented using collection targets is not able to reduce waste generation. Instead, collection targets only improve waste collection. For waste reduction, the products need to have a long life, and should be amenable to repair and reuse after. Simply setting up collection targets or asking companies to pay for the cost of collection doesn’t change the product design.
Typically, as the whole industry needs to bear the costs of implementing EPR, it simply passes them on to consumers. This is especially true for products whose demand stays high irrespective of fluctuations in its price.
So it is important for policymakers to set specific targets for product lifespan, reuse, repair and resource recovery – as the Plastic Waste Management Rules do.
Here, we suggest five regulatory mechanisms to set us on the path to reducing the amount of e-waste we generate:
1. Digital passports
Information is an important tool with which to drive waste reduction.
Buyers need to know the quality and performance, the average lifespan, warranty, the location of repair centres, etc. The repair and refurbishment technician needs to know how to repair and/or dismantle the product, and should also know whether spare parts are available. The recycler needs to know the product’s material composition. The disposal facility needs to be aware of the presence of various toxic substances.
All this information can be included with every product using printed barcodes, and can stay with it for its entire life cycle, for different stakeholders to access it. Ease of access will reduce the information gap that exists in the entire supply chain right now.
A unique digital passport in the form of a barcode should in fact become mandatory for electronic products. This can be done with high-value products for starters.
2. Track lifespan
We should question whether the electronic devices we use are part of manufacturers’ planned obsolescence strategies. Here, the manufacturer designs and makes the product in a way that it reaches its end of life in a certain period, forcing the consumer to purchase another unit of the product. This leads to significant waste generation and loss of resources.
We must be able to review and track the lifespan of products. The digital passports of the first point can help with this exercise. The passport can include the date on which the retailer sold the product, as well as dates of repairs and final disposal, to be logged by the authorised repair and disposal facilities.
This data can be used to analyse the average product lifespan for different brands. And if the average turns out to be significantly lower than a standard life span, the brands must be penalised.
3. Repair Targets
Research has shown that tech companies, including smartphone makers, impose restrictions on self-repairs and third-party repairs. They also render such fixes to be costlier and more time-consuming than they should be, such as by limiting the supply of spare parts. Earlier, retailers played an important role in repair and servicing but that system today stands almost completely dismantled.
To counter this, policymakers must bring in specific targets to ensure products are repaired. We could start by stipulating that at least 5% of a certain product must be repaired in the first year 1, and ramp up from there.
Even if we take baby steps, we must keep moving in the direction of circularity and zero waste. This would signal to the industry that it should imbibe product circularity as well as invest in the repair and recycling ecosystem right from the start.
Waste reduction will then become a core strategy, not an afterthought. Mainstreaming repair and refurbishment will also help to further integrate the informal sector, which currently dismantles and recycles most of e-waste.
Also read: Why the Plastic Waste Amendment Rules 2022 Is a Paper Tiger
3. Product part reuse targets
Recycling entails separating all the metal and plastic parts and melting them down to generate new raw material. However, typically, the raw material is of poor quality and gets down-cycled due to contamination by other materials, coating, etc. that are hard to isolate.
Recycling targets don’t drive-waste reduction nor do they help in a meaningful way with recovering resources. This is because, after two or three cycles, the recycled items have to be junked, especially those made of plastic. And while recycling is better than dumping or burning, it is still polluting and hence less preferred compared to waste reduction overall.
A more sustainable approach would be to replace some parts of a product and remanufacture the rest in order to extend the product’s lifespan. As with repair, policymakers can set targets at the product-category level for part reuse, either through refurbishment or remanufacturing.
4. Product rating
If we want our products to last long, and to be repairable and reusable, the first step is to rate them for these attributes. Together with experts and industry bodies, policymakers need to evolve frameworks for rating products based on the expected life-cycle and ease of repair, reuse, refurbishment, remanufacturing and recycling.
This requires significant efforts, so we can begin with high-value products first, like laptops, TVs and smartphones. The consumer also benefits when these particular products last for more time and are also repairable.
The EU has already initiated work on a ‘Product Environmental Footprint’ that has a mechanism to rate products on durability, reusability, repairability, refurbishment potential, recycled content and full-cycle environmental footprint. The bloc has identified information and communication technology and electronic goods, textiles and furniture as priority sectors to develop this framework.
Product rating and labelling will help sensitise consumers and nudge them towards more sustainable products and services. India’s Union and state governments could also set an example by adopting green public procurement practices, where product sustainability is a key purchase parameter.
Finally, strict enforcement is as important as better regulations. India’s state and Central Pollution Control Boards are responsible for a plethora of environmental regulations, but are woefully understaffed, poorly equipped and rather toothless.
In this situation, the rules become another tool for corruption while industry gets by with managing officials and the political class instead of addressing the core issues around environment sustainability
As we aim to become a fully digital nation, we must bear in mind that the resources required to meet these aspirations are limited, non-renewable and often toxic. The COVID-19 pandemic and Russia’s invasion of Ukraine have also reminded us that the global supply chain remains vulnerable.
In this scenario, resource recovery from e-waste can be an important path to self-reliance and local production.
Meghana Vodapalli is consultant and Divya Tiwari is principal scientist and advisor – both at Saahas.