A few weeks ago, key stakeholders who have been collecting and dealing with e-waste since the last five to six years came together and formed a federation—the Indian Federation of Reverse Logistics (IFRL). This was not a knee-jerk reaction but something producer responsibility organisations (PROs) , dismantlers and some recyclers had been contemplating for a long time. However, the notification on the draft E-Waste Management Rules 2022 seems to have hastened the process as these key players in the value chain found that the government proposal had left them out of the picture altogether.

Unlike the previous e-waste management rules, this time in the ‘registration’ section of May 20, 2022, notification only four stakeholders are mentioned—-manufacturers of electrical and electronic equipment (EEE), producers who market these goods, recyclers and refurbishers of e-waste. Dismantlers and PROs were missing, though today the country has over 400 dismantlers and 77 PROs, who are formally registered with the government for five years. In other words, once the ongoing registration period ends, will PROs, who represent manufacturers and producers, cease to exist despite having invested crores of rupees in creating their own e-waste channels including door-to-door collection streams, collection centres, warehouses and partnering with informal waste workers?

Some members of the IFRL have recently petitioned the government asking for a discussion on the issue and are hoping for a positive response. Meanwhile, it is important to take a look at the e-waste value chain and exactly what role PROs, dismantlers and consumers play in the circularity of e-waste. While consumers are the ones who decide on the end life of a product and it is their awareness and action that brings the used product into the recycling process, the PROs play the crucial role as stewards. In most developed countries it is the PROs who collect the products back from the consumers on behalf of producers and manufacturers (in India often with the help of kabbadiwallas), set up and manage collection centres, undertake collection drives, carry out awareness and capacity building of collectors and dismantlers in the informal sector, ensure the safe transportation of e-waste, channelise it to dismantlers or pre-processors and to registered recyclers.

“While several nations across the globe are engaged in developing a circular economy through legal confirmation, India is also looking to modernise legislation to encourage a circular economy. However, it is important to consider the efforts and investments by organisations such as PROs engaged in developing a network of structured and formal collection and dismantling centres, and regulations must seek to support such bodies so that these may help producer organisations fulfill their responsibilities and facilitate the e-waste management process,” concludes Nisha Banth, the spokesperson of IFRL.