E-waste management: policy issues and challenges
Insufficient information on e-waste generation rates: The 2012 regulations recognized the lack of waste inventories as a limitation and placed the responsibility for the development of state e-waste inventories on the respective state pollution control board (SPCB). Seven years since the introduction of these regulations, as far as we know, SPCB has not yet released inventory. Sales data of electronic products is an important input for estimating the amount of e waste pickup, and is usually available in aggregate at the national level, which makes it challenging to produce inventory at the state level. In addition to domestic power generation, e-waste is also imported from developed economies, and is usually illegally imported. Little is known about the nature and amount of e-waste imported into the country. Designing an effective collection, transportation, and treatment system requires a reasonable and accurate understanding of waste generation, composition, and flow.
Environmentally unsustainable informal sector practices: Although the formal dismantling and recycling sector has grown (in terms of the number of such facilities), the actual waste handled by the formal sector is still low but waste management in Bangalore is available. Anecdotal evidence suggests that most of these formal facilities are far below their approved capacity due to the inability to obtain sufficient waste. The lack of awareness of the cost of e-waste and returning end-of-life equipment to formal collection centers reduces the willingness of households and institutional consumers to return waste to the formal sector. Most importantly, compared to the formal sector, which has not yet invested in a sound collection and collection system, the informal sector makes consumers more willing to return their waste through the convenience of household collection and monetary incentives (even in name). Processing. The informal e-waste sector provides livelihoods for millions of people, who often belong to the most marginalized groups; on the other hand, the waste management practices of this sector pose serious environmental and health hazards to the workers themselves and the general public. This creates a potential moral dilemma for public policy, and the continued success of any e-waste management system will depend on our ability to resolve this dilemma.
Frictions in the end-of-life product market: The inability to reliably purchase the amount of e-waste that generates economies of scale restricts the entry of private participants, such as PROs that establish e-waste management systems in the formal sector. For example, the use of effective recycling technologies for e-waste may require a large amount of upfront capital expenditure, which may be unreasonable for private entities because of the lack of certainty in purchasing sufficient quantities of e-waste. In addition, there are information barriers in these markets. First, given that e-waste recycling is a relatively new business, the potential lack of information on the cost-effective recycling technology itself may become a market obstacle. Secondly, consumers' low awareness of lack of reliable information about e-waste management affects the operation of the market. Public policy may have to play a bigger role (beyond current e-waste regulations) to create a better market for e-waste.
Inadequate regulatory design and implementation: In the 2012 regulations, the manufacturer’s mandatory recycling system did not have a collection target attached and did not provide an incentive to assume responsibility. Therefore, electronic waste management practices have hardly improved. This was addressed in the 2016 amendment, which provides more regulatory certainty by specifying progressive and stricter collection targets. However, regulatory design puts a heavy burden on already poorly equipped regulatory agencies. It is expected that the regulatory agency will review the EPR plan submitted by the manufacturer, grant authorization and implement the provisions of the EPR plan. The regulations also set detailed standards and procedures for other entities—collectors, disassemblers, recyclers, and bulk consumers—and require these agencies to enforce compliance with these standards. The regulatory capture of lobbying groups benefiting from weak law enforcement, lack of transparency and unwillingness to publicly share information on compliance and regulatory actions has long plagued India’s environmental regulatory enforcement, and e-waste regulation is no exception. This poses a major public policy challenge for the future of e-waste management in the country.
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