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Toxics Link study Finds a Long Road to Circularity in India’s E-waste EPR Model

A new report by an environmental group, Toxics Link, reveals significant structural gaps in India’s Extended Producer Responsibility (EPR) framework for e-waste. The study, titled “Long Road to Circularity,” warns that while the EPR model is a cornerstone of waste management, it currently fails to capture a vast range of critical minerals essential for India’s green transition.

The Extended Producer Responsibility (EPR) framework mandates the recovery of only four metals—gold, copper, iron, and aluminium—leaving critical metals untapped. A vast range of valuable and critical metals, including neodymium, dysprosium, and lithium, are essential to strengthening resource security but is currently overlooked and lost.

In light of these concerns, the report examines current e-waste regulations and highlights critical challenges limiting their effective implementation. The report also underscores persistent issues, including low consumer awareness, poor financial traceability of e-waste flow and limited monitoring capacities. The study identifies several operational gaps. Key findings from the report include:

  • The EPR portal currently lacks data on total market players and leaves small-scale manufacturers, online sellers, and grey-market importers outside the system.
  • Information regarding non-compliance penalties and environmental compensation remains unavailable for the 2023–24 and 2024–25 fiscal years.
  • Detailed data is accessible only to operators, resulting in limited public visibility into system performance.
  • The current regulation does not identify and place responsibility on any individual stakeholder for the setting up of collection centres, thus making it extremely difficult for consumers to deposit their waste in the authorised e-waste stream.
  • No incentive to producers and manufacturers adopting “green” product designs or for recyclers implementing high-quality, advanced recovery processes.

“While Extended Producer Responsibility is a cornerstone of India’s e-waste management framework, the principle alone cannot deliver the desired outcomes. It must be complemented by an effective and robust waste collection system, integrating the informal sector and the development of high-tech recycling facilities along with public awareness for advancing system transparency”, Satish Sinha, Associate Director, Toxics Link.

The report suggests the following key recommendations to plug some of the gaps in the
present system:

  • Enhance system accountability and transparency by making data accessible to the
    public.
  • Strengthen reverse supply chains and collection mechanisms to streamline the flow
    of e-waste.
  • Expand consumer awareness on the advantages of e-waste recycling and the
    importance of using authorised collection channels.
  • Integrate the informal sector into the e-waste management ecosystem.

Together, these measures can help build a stronger and more effective e-waste
management system.

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