Академический Документы
Профессиональный Документы
Культура Документы
Table of Contents
1 Introduction..............................................................................................................................3
1.1 Background ......................................................................................................................3
1.2 Sources of e-Waste in India .............................................................................................3
1.3 Current Practice ...............................................................................................................3
1.4 Objective: Implementation of an e-Waste Management System for India......................4
2 Necessary Building Blocks ......................................................................................................6
2.1 Legal Framework .............................................................................................................6
2.1.1 Extended Producer’s Responsibility (EPR) ......................................................................6
2.1.2 All stakeholder participation and coordination.................................................................7
2.2 Secure Financing: what needs to be financed? ................................................................8
2.3 Awareness and education:................................................................................................9
3 Individual and Collective Producer Responsibility: 2 Pillars of e-Waste Management..........9
3.1 Proposed Individual Producer Responsibility Model ......................................................9
3.2 Proposed Collective Producer Responsibility Model ....................................................12
3.3 Involving the Informal Sector........................................................................................15
4 Feedback from Stakeholders..................................................................................................16
1 Introduction
1.1 Background
The electronics industry is the world’s largest and fastest growing industry and is
recognised as one of the engines of economic development in India. The last decade
has seen tremendous growth in the field of information technology all over the world,
especially in developing countries like India. This growth, combined with rapidly
increasing product obsolescence and consumer choices, has brought in a new kind of
waste – electronic waste or e-waste. This ever-increasing waste has very complex
characteristics and requires an equally complex set of efficient technology and
processes to deal with it.
Management of electronic waste is a much more formidable challenge in developing
countries on account of lack of proper infrastructure, poor legislation and awareness
among citizens. Also at stake are the livelihoods of a large number of urban poor
involved in processing and recycling of e-waste. India today generates a huge quantity
of electronic waste - rough estimate suggest 145,000 tonnes annually - which is
handled across many cities in India, mainly in the informal sector, exposing poor
workers to environment and occupational health risks.
The import of e-waste, which is illegal, is another major source and preliminary
estimates do point that the quantity being brought in is very significant. This takes
place both in a legal as well as quasi-legal way, since e-waste is either misclassified as
‘metal scrap’ or imported as second hand or ‘end-of-life’ goods, which soon become
waste.
These operations are well connected to the supply chain processes of sourcing the raw
material to finding markets for the recovered materials during post-recycling
operation. The actual processing is carried out in small clusters, behind closed doors,
often located on the periphery of the city. Some of the processes include open burning
of Poly Vinyl Chloride (PVC) wires, acid bath, use of toxic chemicals such as
Mercury and Cyanide, heating of lead solders, etc. These processes are highly toxic
impacting both environment and human health.
Some of the immediate and long-term impacts of the current practices are as follows:
Though the existing e-waste recyclers are often blamed for the dramatic environmental
impact generated in this sector, it is often forgotten that they played a crucial role in
preventing Indian cities from suffocating under piles of waste. This sector, which
provides livelihood to thousands of people throughout India, would render any attempt
to organise a system in parallel a failure.
A convenient collection and disposal system for large and small consumers to
return all their e-waste safely.
A mandatory system for concerned producers to care for their product beyond its
useful life.
A regulated system where all stakeholders have clearly defined roles and
responsibilities, adhering strictly to existing environmental and social legislation.
Moreover, the following challenges, related to the current situation, should be kept in
mind all along this note.
To achieve a broad consensus, where all relevant stakeholders are involved in the
design and realisation of the model.
To create a debate both at national and regional level, in order to define a successful
model
To operate accepted and effective platforms where strategies are developed
which enable 'informed and smart' decision making.
To include the informal sector, currently playing a pivotal role in e-waste
management, in any new plan for e-waste management for India.
To organise a complementary formal system additional to the existing informal
seems).
To relax the burden and capacity limits of the municipal waste management
systems in tackling e-waste which is as world-wide experience show beyond their
capabilities.
To motivate producers to lead a safe recycling and disposal of their products
through an efficient and effective waste management.
To assign roles to all stakeholders and ensure they play them well and fair
The main objective of this concept note is to create a consensus amongst all the
stakeholders in arriving at an acceptable and feasible solution for all in India. The aim
is also to raise issues that stimulate the necessary debate to fine-tune the proposed
models, paving the way towards a regulated and organised e-waste management
system in India.
The various steps in providing a new direction to WEEE management system in India
are the following:
• Conceptualising and defining the necessary building blocks for a proper e-
waste management model in India.
• Creating a broad consensus amongst the various stakeholders of WEEE
management system about the viability of the proposed EPR models.
• Implementation of the EPR model.
• Legislation based on regular monitoring and evaluation of the model.
This concept note focuses on the first step, thereby, proposing the building blocks for
an e-waste management system for India. The optimal model for India would only
emerge after necessary deliberations and dialogue over the building blocks and a broad
consensus over the roles and responsibilities of the various stakeholders. Moreover, we
also suggest that these building blocks would be essential for any suggested model be
it a Collective Responsibility or an Individual Responsibility Model. The Collective
Responsibility Model bestows the management responsibilities of the entire system to
a collective industry body referred to as the Producer Responsibility Organization. The
Individual Responsibility Model, on the other hand, suggests that individual producers
design the optimal management system for the e-waste generated by their products.
Since both models have certain disadvantages, in addition to their distinct advantages,
a combination of the two models might constitute the optimal model for India.
However, as mentioned above, the building blocks for both the models, discussed in
detail below, remain the same and are the focus of this concept note.
2 Necessary Building Blocks
Moreover, as stated above, the legal framework needs to ensure the health and safety
standards of the people involved in the operations, along with issues of emissions to
the environment and waste emerging from such operations. Several laws already
tackle down these aspects, though there are no guidelines explaining how they apply to
e-waste. A first crucial step is to look at these existing laws and define clearly their
application to e-waste recycling. A specific legislation for e-waste can then be
formulated to “fill the gaps” not covered by existing law.
Further, it is essential not only to streamline the existing set-ups but also to attract
recyclers who make the recycling process safe and efficient. Government incentives
like land, financial subsidies, etc. can go a long way in ensuring a viable collection and
recycling system. Therefore any legislation must be in line with right incentives for the
involved stakeholders.
The original motivation for EPR was twofold: first, to relieve municipalities of some
of the financial burden of waste management, especially when it comes to complex
wastes such as e-waste, and, second, to provide incentives to producers to reduce
resources, use more secondary materials, and undertake product design changes to
reduce waste (OECD, 2001).
All existing successful e-waste management models around the World are based on
the concept of EPR. However, there are as many ways of implementing EPR as there
are existing models. In Europe, the WEEE Forum (www.weee-forum.org), serves as a
network for all systems that are collective, non for profit and in operation.
The specificities of the Indian situation require developing a system that is acceptable
to all stakeholders and is viable and sustainable in the long-run. Inspiration and
support may be found in the functioning models, but the final solution will need to
adapt to the local specificities.
One of the key challenges of the formal e-waste management system will be the
integration of the informal sector. The issue of livelihoods of existing informal sector
players need to be a key component in the new model. The best option may be to
channelise this sector in the collection and storage of waste from various sources,
which is then passed onto authorized distribution channels. A skill up-gradation plan
can also enable them to be part of the dismantling process.
Recycler (doing any operations of the recycling chain, from collection to material
recovery)
Authorization of the recyclers involved in handling e-waste includes both
contractual arrangements with the PRO or individual producers for receiving the e-
waste
To upgrade skills and technologies for best practice in all steps of the recycling.
To respect all national and international environmental legislation
To obtain all licenses from the SPCB where required
To maintain proper environmental and health standards;
To maintain and produce records for inspection and verification.
Recyclers are responsible also for the proper processing of their downstream
fraction mainly the critical ones (e.g. leaded glass, brominated plastics, etc.)
Regulators/policy makers
To frame appropriate guidelines/legislation to support the model
To monitor the processes regularly
To provide incentives to entrepreneurs to set up facilities
To regulate/control the number of facilities in a geographical area
To approve technologies
To form multi-stakeholder monitoring committee
To create awareness among generators of waste
The Regulatory authorities will be required to take all initiatives and measures to
educate the community at large and all other stakeholders of responsibilities and roles
of each sector.
The Producers will also need to play their part in educating the consumers regarding
the e-waste management system, product constituents, handling precautions,
responsibility of the producers in changed situation. These can be done collectively or
individually through proper labelling in the products and other effective tools.
A producer company may practice its EPR either individually or collectively. Though
these two implementation modes may seem contradictory, they are in fact
complementary and are the two pillars of EPR. In other words, when IPR is desired, a
collective solution is also necessary. The following paragraphs explain the
mechanisms of both individual and collective models.
Producer
According to (Manomaivibool and Lindhqvist, forthcoming), IPR is an ideal type of
EPR. Since a producer is responsible for his own products, we can assume that there
would be an incentive for design improvements (in a way that a producer takes the
end-of-life into account and balance it with other considerations).
The individual producer in this model has the option of having direct contracts with
the dismantler and/or the recyclers which allows them to get back the re-usable
components from their obsolete computers. The producers can also get the data from
the collector/dismantler/ recycler about the specific composition and characteristics of
the waste generated by its products in terms of:
One of the major advantages of having access to information above is the incentive it
provides to the individual producer to design for increasing re-use as well as the
product design. The economic rationale behind the incentive to redesign is the
following: Individual producers, by redesigning their products to facilitate dismantling
and increasing re-use of certain components can then transfer the benefits to the
consumers who get better prices when they sell off their old computers to the
designated collection agency.
Collection
The collection in this model is managed by not-for-profit collection agencies which
are regulated by the appropriate authorities like the DPCC and CPCB. The individual
producers have contracts with the collection agency and on behalf of the producer; the
collection agency implements the producer take back schemes. The collection agency
also collects from retailers as well other generators of e-waste through an extensive
network of collection centres. As in the model with collective producer responsibility,
there is scope for the involvement of the informal sector in the collection and storage
of e-waste.
Financing
The financing of the Individual Producer Responsibility Model would depend,
amongst other things, on the inherent material value of the EEE. This would be the
most crucial element in determining whether another financial instrument, like an
Advanced Recycling Fee (ARF) to be levied at the point of sale, is necessary at all.
The price, inclusive of ARF, would therefore reflect the true price of the product
including the environmental cost of the product. For instance, products like computers
which have inherent material value that can cover the entire cost of recycling could
potentially be recycled by levying a nominal or even zero ARF (see the Toxics Link
paper for an example of Computers). However, products which do not have sufficient
material value at the end of useful life will need to be recycled by levying either a
visible or invisible ARF. Therefore under the individual responsibility model, there
would be a menu of ARF ranging from zero to positive amounts, depending on the
inherent material value of the end of life product. The exact amounts would depend on
the producers’ estimation of the recycling costs and the nature of contracting with the
recyclers. If Individual Responsibility is a component of a larger Collective
Responsibility Model, the proposed ARF might go down because the collective
organization would be able to take advantage of economies of scale.
Comments:
The suggested model, which is based on the concept of Individual Producer
Responsibility, has the following advantages:
• Market based mechanism: The model allows for the interplay of market forces
in determining the price of each category of e-waste generated. It also allows
individual producers to negotiate for the “appropriate” price or cost for each
category/ brand of waste.
• Eliminates free riders once legislation is introduced: The model also creates a
level playing field once appropriate legislation is introduced.
There are several factors that make a PRO deem crucial in an EPR programme:
• Small producers might not have enough capacity & power in negotiating the
contracts to carry on their responsibility alone
The producers will also enjoy a major advantage of their sales and service network to
utilise this channel to collect the waste back at the end of life of such products.
This model suggests and recommends that a part of this material value be passed on to
the generators of the waste. Part of this value (revenue) be utilised for logistical
support of collection and storage of waste. This mechanism also provides incentive to
the generators to be active participants and streamline the storage and collection
system to an authorised agency. The PRO will pay the generators for the material
collected and provide free collection system. The dynamic fee system for different
end-of-life products will be fixed by the PRO and will be open to review at periodic
intervals. This will give an option to vary the prices according to the prevailing market
values of the materials extracted.
The revenue generated by PRO through sale of this waste to the recyclers will be
utilised for financing the take back process from the consumers (cost paid for the
WEEE) as well as the collection and storage of the waste. In case of products with no
material value and a recycling cost attached, the producer will need to take
responsibility (through PRO) as part of the EPR initiative.
The revenue generated through sales of the materials recovered will support the
administrative, plant and machinery and other overheads. The critical factor deciding
the breakeven period will be both an assured material supply as well as the scale of
operation. The experiences across many countries suggest that the scale of operation
for recycling such waste is growing and such ventures are considered viable and
profitable.
1. PRO take-back: The PRO will provide free collection for the waste and the
generators will be paid for the material according the product type (fixed by PRO). A
proper reporting system has to be established for this to ensure transparency.
2. Dealer take-back: The dealers selling such products will have to take back the old
products and the generators will get a discount on new purchase of electrical and
electronic goods (the end-of-life cost can be fixed according to product type). These
products will be then transferred back to the PRO with proper reporting.
3. By existing informal network: One of the biggest challenges to this model is from
the existing informal sector and the operators will need to address this. The best option
may be to channelise this sector in the collection and storage of waste from various
sources, which is then passed onto authorized distribution channels. The informal
sector will tie up with the PRO to ensure accountability.
The entire rationale, however, for providing suggestions for redesigning the existing
system are the poor working conditions of the informal recyclers as well as the
environmental degradation due to the rudimentary practices of recycling followed.
Therefore, it is proposed that the informal sector should be involved in the following
manner in the e-waste management system
The concept note above has raised some issues which need to be discussed with
various stakeholders. In the format below, we formulate some of the key issues which
need to be debated before the ideal model for India is finalized.
7. Who is
responsible for
control and audit
of…
… the entire
system?
... the
environmental
aspects?
… the financial
aspects?
8. Who is
responsible for the
setting of the
standards?
9. how is the
system financed?
is financing
explicitly regulated?
are historical and
orphan products
mentioned?
are the following
financing structures
adapted (fee model,
ARF, visible fee,
recycling fund,
others..)?
10. What are the
current laws for
waste
management/
treatment/
environmental
legislation?
11. Setting
collection and
recycling targets.
should there be
any?
how could they be
measured and
calculated?
12. monitoring and
compliance
are collection /
recycling targets
set?
are standards (BAT
for recycling, etc)
set for:
- quality control
- quantity control
- financial control
- system
improvement
- registration &
licensing
- enforcement /
penalties
is system control
regulated (who is
the competent
authority)?
is information flow
guaranteed and
unbiaised?