6

STRATEGIES AND
INITIATIVES FOR DEALING
WITH E-WASTE IN INDIA

The growing production of waste electric and electronic equipment (WEEE)

justifies the increasing attention of both institutional and industrial organizations.
The fast adoption of legislations, rules, and practices leads to a great dis-
homogeneity in the technical, organizational and cost models adopted world-wide.
Elia and Grazia Gnoni (2015: 271)

This chapter encompasses pan-Indian initiatives for dealing with e-waste

management, ranging from building knowledge base through research and social
action by different stakeholders to technological and legal advancements and
industrial initiatives. All these initiatives are organised on time scale, in a
manner, to capture every initiative in its context with its evolutionary journey.
The chapter is divided into two sections: the first section covers the period of
2001–2012, until the Rules, 2011 were enforced in May 2012; and the second
section elaborates on law driven implementation, post-2012. The first section
covers milestones and activities, such as, getting to know ground reality and
creation of information and knowledge base; initiatives to reach out to masses
through media reports and to the stakeholders/ sector players; and dialogues and
advocacy with different government agencies for separate legislation on e-waste.
Thematically, information is provided on e-waste generation1 (computers, and
mobile phones) and its quantum; e-waste flow (domes- tic and imported2); trade
chain and informal sector; recycling scenario (Toxics Link 2003, 2004a, 2004b;
Mehra 2004); role of awareness in e-waste management; and role of CSOs and
newspapers in identification of policy/legal points by non-government actors;
EPR and take-back campaign; and fostering formal-informal sector partnership.
The second section elaborates on law driven implementation, which includes
initiatives by the GoI (awareness campaigns; strategy papers on resource
efficiency, linking e-waste management with three missions – Digital India,
Clean India, and made in India, etc.); expansion of discourse on e-waste
management
DOI: 10.4324/9780429285424-
6
 Strategies and initiatives for dealing
134
through economic aspects of EPR (tax structure, business opportunities created,
producers’ budget allocation for PROs’ functioning, financing for e-waste
management, etc.); industry development through start-ups (PROs, recycling
units); and starting of academic courses on e-waste management.
An attempt is made to link global and local – how and what/which global
thinking and doing have reached India and which Indian actors have acted upon,
including the government. The discussions and discourse on regulatory
framework for e-waste management in the Chapter 5 are the contexts for this
chapter. While narrating initiatives or actions, names of the specific actors
(research organisations, bi-lateral agencies, industrial actors, stakeholders under
the Rules, 2016, etc.) are consciously not spelt out because of two reasons. The
first reason is to avoid cherry picking (naming a few may become a promotion of
the named ones, and implied neglecting the others) in the given competitive
scenario in the industry/e-waste sector; and the second is to document pan-Indian
initiatives comprehensively – making thoughts, perceptions, discussions and
debates, transitions/shifts, etc. more important as an academic objectivity and
pursuits. Thus, the chapter leaves an open space and yet recognises those actors
and initiatives that are not named or covered may have taken place in India.

I: Overview of pan-India initiatives for dealing with

e-waste during 2000 and 2012
The years 2000 and 2012 are believed to be founding years for building up the
discourse and actions for e-waste management in India; a game changer in the
larger context of growth of electronics industry as one of the promising engines
for economic development in India. These years were beginning of enforcement
of two international regulations – the Basel Convention across the world, and the
WEEE Directive in EU countries; regulating transboundary movements of e-
waste, and specific guideline for e-waste management and introduction of EPR
respec- tively. India had amended Hazardous Waste Management Rules in 2003 in
light of the Basel Convention, and later in 2008; and introduced E-waste Management
and Handling Rules, 2011 towards end of 2010.
The global thinking on e-waste management had begun in late 1990s on the
following issues: growing quantity of e-waste; landfills as well as leaching of
toxins to soil and water, and its hazardous impact on environment and human
health; safe disposal/treatment of e-waste as a necessity because of its toxic
composition; developed countries shipping e-waste to developing countries, sale
of ‘grey goods’; and EPR and waste management.
India is an example of economic growth and environmental protection
indicators are at odds with one another. Indian electronic industry, especially IT
industry witnessed huge growth, that is, from 1998 to 2002, there was a 53.1%
increase in the sales of domestic household appliances, both large and small; and
the growth in PC ownership per capita in India between 1993 and 2000 was
604% compared to a world average of 181%. As a result, the total PC base
during this period has
 Strategies and initiatives for dealing
135
grown from an estimated 450,000 PCs–4,200,000 PCs. On the other hand, India
ranks an abysmal 101st on the 2005 Environmental Sustainability Index, and for
Environmental Governance gets only the 66th rank, with a score of −0.10 (the
highest being Iceland with 1.65, and the lowest Iraq with −1.52) (quoted in
Sinha- Ketriwal et al. 2005: 498). ‘MAIT (2007) provided figures, total PC sales,
between October and December 2006 were 1.39 million units, registering a
growth of 28% over the same period a year before.’ (Quoted in Arora et al.
2019b: 69–70.)
As part of domestic e-waste, large quantity of e-waste is generated by
consumers and manufacturers. The e-waste from manufacturers is generated in
the form of defective printed wiring boards, IC chips, and other components,
which are discarded in the production process. All types of e-waste are being
recycled in the country. The unorganised recycling units as part have been
developed organically as a natural branching of the established scrap industry,
which has been market-driven and driven by economic necessity associated with
poverty. For these units, main incentive is financial profit, not environmental or
social awareness (Sinha-Ketriwal et al. 2005). Materials recovery interest small
scale recyclers, and entire communities, including children, earn their livelihoods
by foraging metals, glass, and plastics from the e-waste.

Getting to know ground reality, knowledge base created

The first report on e-waste scenario in Asia (including India) was published by
the BAN and SVTC (Silicon Valley Toxics Coalition) in 2002 with the
contributions of three country representatives 3 (Puckett et al. 2002). This report
revealed how the USA and other rich economies that use most of the world’s e-
products, generate most of the e-waste, and exporting the e-waste crisis to the
developing countries of Asia. It stressed on unjust, inappropriate export of
pollution to a particular region (China, India, and Pakistan) simply because it is
poorer. After showing e-waste impacts – environmental4 and occupational, and
legal implications of e-waste export, it drew attention to – how from a legal
standpoint, the issue has become murky and is dependent on how seriously a
government intends to deal with the hazards (ibid.: 27). As part of
recommendations, this report stressed upon making implementation of the Basel
Convention; making producer responsible; activating product take-back system;
encouraging design for longevity, upgradability, repair and reuse, and for
recycling. Thus, most actors of e-waste sector were made aware of Indian ground
reality in the global scenario – e-waste export by rich countries, its hazardous
impacts, limitations of Indian laws to deal with e-waste dumping vis-à-vis the
Basel Convention as well as the WEEE Directive in European countries and its
implementation.
The ‘Indo-German-Swiss E-waste Initiative’ 5 was started in 2003–2004 for
knowledge partnership through an understanding between MoEF and EMPA, 6
working on a mandate for SECO (Swiss State Secretariat for Economic Affairs)
and GTZ,7 Germany (renamed as GIZ in 2011). This was commissioned under
BMZ and ASEM (Advisory Services in Environmental Management)
Programme. This
 Strategies and initiatives for dealing
136
programme was instrumental in supporting the WEEE strategy group, which was
establishing national WEEE baselines, and assisting in implementing WEEE
pilot projects. A national workshop on ‘Electronic Waste Management’ was
organised jointly by CPCB, MoEF,8 EMPA, Switzerland, and GTZ in New Delhi
during March, 2004. This workshop emphasised urgency of inventorisation and
micro- level intervention to tackle the potential problem of e-waste in India.Two-
pronged strategy was adopted: first, at the macro level, national level desk study
was proposed; second, a national level working group was formed (Arora et al.
2019b).The working group included multiple stakeholders, such as regulatory
authorities,9 industry associations,10 NGOs,11 recyclers (formal and informal),
research institutions, and experts in the field like EU and UNEP. This
consortium was to take initiatives to improve recycling practices, providing
fiscal incentives, and evolving standards for recycling, formulating legislative
tools, providing cleaner production options to manufacturers using fewer toxic
components, and take steps to check illegal imports of e-waste in the country. The
CPCB commissioned by the proposed desk study to IRGSSA,12 its report was
published in 2005.13
The multiple stakeholder group undertook various initiatives, such as,
awareness raising among consumers, corporate houses, government agencies,
manufacturers, and informal recyclers; capacity-building of government agencies,
producers of EEE, formal and informal recyclers; occupational health safety
measures for informal recyclers; improving recycling recoveries; and policy advice.
Training was carried out by GTZ based on a tool – PREMA (Profitable
Environment Management) for informal recyclers of Delhi and Bangalore cities.
One of the lessons learned by this training was that ‘not much can be achieved by
aiming to improve the methods of metal extraction, as the processes cannot be
improved unless they are carried out in an environ- mentally safe, risk-free, and
economically efficient manner.’ (Arora et al. 2019b: 77.)
IRGSSA was to carry out a study covering the following: rapid assessment for
quantification, characterisation, future projections for e-waste, documenting e-
waste management in different cities, and plans for new management systems. This
report estimated e-waste generation (computers) based on ‘the average penetration
levels of PC in a population of 1,000…According to this estimation, total e-waste
generated in India was 146,180 tonnes’ (quoted in Sinha 2019a: 28–29).
Maharashtra was at the top among 35 State and Union Territories with 20,270.6
tonnes followed by Tamil Nadu with 13,486.2 tonnes, and Andhra Pradesh with
12,780.3 tonnes.Among them,

some of the important sectors like railways, defence, and health generate
very large volumes of e-waste…individual households are perhaps the
lowest contributors to e-waste for PCs…[but] large-scale generation from
consumer durables, such as TVs, refrigerators, air conditioners, and
washing machines.
(ibid.: 31)

This shows that the e-waste generation was linked to production and
consumption pattern; production was linked to lifespan of an e-product and
 Strategies and initiatives for dealing
137
introduction of newer technology in short span of time.
 Strategies and initiatives for dealing
138

Domestic generation of e-waste

Most of the studies on estimation of e-waste are based on the market supply
method, while some studies use end-of-life models (Subramanian 2014: 27). A few
reports on inventory of e-waste are based on models of obsolescence and not
based on actual physical inventories; this trend was observed until 2008. The
statistics of production, exports, and sales of each product and their average life
have been considered in these studies. For example, average life of a PC was
assumed to be 5 and 7 years and of a television (TV) to be 15 and 17 years. It
was also assumed that 100% of electronic units sold in one particular year would
become obsolete at the end of the average life. These perceptions of life of e-
waste were based on urban conditions; the conditions are far from it considering
the rural scenario (Chatterjee and Kumar 2009: 895).
A report was jointly prepared by GTZ and BIRD in 2007, which is one of the
firsts WEEE Assessment Study to develop a sound methodology for estimation
the volume of WEEE produced in India (limited to computers, television, and
mobile phones).This study aimed at developing methodology for calculating WEEE
in India, including – (i) projections of e-waste over next five years, (ii) disposal
behaviour and recycling practices, (iii) identify stakeholders in e-waste trade value
chain, (iv) assess capacities of existing recyclers, and (v) recommend a national
action plan for major stakeholders to ensure proper handling and disposal of e-
waste (Khattar et al. 2007: 9). The methodology adopted for e-waste assessment
and quantification study was ‘Funnel Approach’ for accuracy and better
understanding of the e-Waste production in India; WEEE was estimated at three
levels: (i) potential annual e-waste;14 (ii) e-waste available for recycling;15 and (iii)
e-waste recycled.16 Based on this method,

…the total annual e-waste generated in India in the year 2007 is 3,82,979
MT,17 including 50,000 MT of imports in India…the amount available for
recycling was 1,44,143 MT but due to the presence of considerable
refurbish- ment market only 19,000 MT of e-waste has been recycled in the
year 2007.’
(Khattar et al. 2007: 9)

Another survey was carried out in Mumbai and Pune cities by an expert group
appointed by Maharashtra Pollution Control Board (MPCB) in 2006–2007. The
report (2007: 28) has described conceptual methodology for mapping of e-waste
in Mumbai and Pune cities in a layered manner. The four layers are: identifying e-
waste streams as layer 1; value added [chain] as layer 2; labour input as layer 3; and
hazards as layer 4. It stresses on primary survey method for estimation of WEEE
quantity – material flow, input quantities/import, reuse, disposal, recycling
technology, and hazardous processes – these are the stages of estimation; this is
similar to UNEP Manual (2007). Based on survey, MPCB informed that total e-
waste generation in Maharashtra was 20,270.6 tonnes, out of which Navi
Mumbai contributed 646.48 tonnes, Greater Mumbai 11,017.06 tonnes, Pune
2,584.21 tonnes and Pimpri- Chinchwad 1,032.37 tonnes (MPCB 2007).
 Strategies and initiatives for dealing
139
Until almost 2010, e-waste related estimates included computers, cell phones,
and TVs. Different projections were made about generation of e-waste during
2005– 2009. For example, ELCINA (2007) estimated 4.84 lakh tonnes (0.48 Mt)
e-waste
by 2009; CPCB (2008) estimated 8.0 lakh tonnes (0.80 Mt) by 2012 (quoted in
LARRDIS 2011: 5); while Dwivedy and Mittal (2012) projected e-waste around
2.49 million MT during 2007–2011 based on a study conducted in 2010. Thus,
recognising a range of e-products for preparing a list of e-waste became a point
of policy/regulatory framework in India, which was reflected in the Rules, 2011.
The need for preparing inventory of e-waste in the country has been an agenda
for almost 15 years.
The UNEP (2007: 12) data mentioned that ‘total e-waste generated in the EU
is about 14–15 kg per capita or 5 MT to 7 MT per annum while in countries like
India and China, annual generation per capita is less than one kg.’
After the Rules, 2011 were notified and enforced in 2012, GEM 2014 reported
that India generated 1.7 Mt every year.This shows that increase of almost 1.4 Mt
in seven years, that is, 0.37 Mt e-waste in 2007, jumped to 1.7 Mt in 2017; about
one kg/inh to 1.3 kg/inh (1,641 kt). In GEM 2017, India was ranked fifth with 2.0
Mt (about 2.0 kg/inh) e-waste generated annually (Baldé et al. 2017).

Details about imported e-waste

Along with e-waste generation in India, imported e-waste was also talked about;
figures were available in ‘truckloads’, estimating in tonnes until 2009. For
example, ‘Old Seelampur18 acquires about 15–20 truckloads of e-waste,
amounting to 1.5–
1.8 tonnes of e-waste every day’ (Basu 2019: 57), thus, 45–50 tonnes a month.

About 300 days of the year, two truckloads of scrap PCs arrive daily in
Delhi…about 133,000 units and 3,600 tonnes arriving per year (PC weighs
about 27 kg). For an assumed obsolescence time of 7 years, the quantity of
locally produced PC scrap is almost doubled by imports (+ 89%).
(Quoted in Babu 2007: 316)

One of the official figures of imported e-waste is available through a

newspaper report, which mentioned, ‘the environment and forest ministry has
approved the import of 8,000 tonnes of e-waste by Attero Recycling, a company
that has set up an integrated recycling plant for safe extraction of metals near
Roorkee.’ (Mudur, 22 September 2009.)
Sinha (2019a: 32) mentioned that, ‘estimates suggest that import of e-waste
accounts for an amount almost equal to that being generated in the country.’ He
further provided details,‘the waste follows a very circuitous route, originating
from developed or OECD countries or through many intermediaries before
landing up at one of the India ports.’ (ibid.: 33). The reason for importing e-waste
at India, China, and Pakistan was, ‘the cost of recycling a single computer in the
United States is $20, while the same could be recycled in India for $2, a gross
saving of $18
 Strategies and initiatives for dealing
140
if the computer is exported to India’ (ibid.: 33). This reason also became a point of
advocacy, arguing that

even though the import of e-waste is legally banned in India, there are
many reports of such landing at Indian ports…these goods are brought in
under different nomenclature, like mixed metal scrap, or as goods meant for
charity, by exploiting and finding loopholes in the current regulation.
(ibid.: 33)

(ILO 2014:17) provided more details about imported items and why illegal e-
waste is difficult to track. Importers bring in huge quantities of e-waste including
used and obsolete monitors, printers, keyboards, central processing units (CPUs),
typewriters, projectors, mobile phones, polyvinyl chloride (PVC) wires, etc.These
items exist in all ranges, models and sizes, and are functional as well as unsellable
and non-reusable materials.

Often, illegal shipments of e-waste are labelled as donations or imports of

second-hand EEE, to cross borders as a legal trade transaction. These
illegal transactions are difficult to track as they are both hidden and
controlled by criminal groups that profit from informal e-waste recycling
practices.
(ibid.)

Reasons for huge amount of imported e-waste were identified after

studying Customs Act, 196219 and confusing related to this Act; also, loopholes
in the Basel Convention were referred to. Simultaneously, information and
knowledge base include existence and functioning of informal sector, which had
dominant presence for collection, crude methods applied for recycling of e-waste,
and selling of recovered materials in the existing market (Toxics Link 2003; Inagaki
2008). Second-hand computer could be received as donation for some charitable
institutions, anomaly of the EXIM (export-import) code for both old and new
computers are the ways to importing e-waste (Sinha 2019b).To bring about clarity
and required changes in the Customs Act became a point of awareness raising as
well as a policy issue – amendments in the existing Act in consonance with the
Basel Convention.
The Southern Asia statistics on exports showed that ‘an average of 0.9 kt/year
for the period of 2008 to 2013, with a total value of EUR 2.8 million. The exports
show a rapid increase trend from 2008 to 2012, but a rapid decrease after 2012’
(Baldé et al. 2016: 23).This led to believe that flow of imported e-waste is
reduced; however, not stopped, and no further statistics are available for India.

Recycling scenario
Regarding e-waste recycling, several authors noted that it was gaining currency as
a lucrative business from early 2000s, as larger quantities of electronics are coming
into the waste stream and e-waste as an abundant source of metals. Also, that
recycling is
 Strategies and initiatives for dealing
141
known to be a complex task, especially in terms of special logistics requirement
of its collection, cost, release of toxins, and its environmental impact (Toxics Link
2004; Arora 2019b; Basu 2019; Jain 2019; Sinha 2019b). In India,‘ environmental
concerns among manufacturers as well as the awareness of consumers regarding
environmental issues are not very high. While the government has passed several
environmental protection laws, their enforcement remains questionable’ (Sinha-
Khetriwal et al. 2005: 498). Parallel to these processes, a couple of recycling units
were established and recognised by the SPCBs across India, who showcased
recovery of precious metals through formal way of functioning, that is, by
installing proper infrastructure, technology, and scientific methods by 2005
(www.attero.in; www.ewasteindia.com). ‘The informal recycling sector has a vast
network of collection, storage, segrega- tion, and material recovery facilities’
(Sinha 2019a: 34); a large number of women, children, and migrant unskilled
labourers are engaged in different stages of recy-cling. Inagaki (2008: 21)
mentioned,

Only 5% of the total e-waste recycled in India is handled by four formal

recycling companies who have recently emerged in the recycling market;
and apart from large corporate, some of formal recyclers are now under the
negotiation with informal recyclers in specific stages of the chain on
benefit sharing from PC components collected by them. The same formal
recycler repeated that this scheme would create the win-win effect on both
of the informal and formal sides.

Attero, a recycling enterprise, officially informed in the same newspaper report

that,‘We have a capacity of processing 36,000 tonnes of e-waste each year,’
(Mudur, 22 September 2009), which indicated capacity of formal recycling in
India, that is, of 400,000 tonnes of domestic waste generated in India. However,
the CPCB reported in 2011 that ‘there are 23 registered e-waste recycling units in
operation having recycling capacity of about 90,000 MT per annum,’ (quoted in
LARRDIS 2011: 99). By 2013, there were ‘over 2,000 informal recyclers in
India, and Gujarat ranks among the top states for this practice,’ (Shah 2014: 9).
He further noted about Ahmedabad based authorised recycler ‘receives a total of
6–7 tons/month, far below its e-waste facility’s capacity of 500 tonnes/month.
Thus, it operates at a meagre 1.5% of its capacity, far below AMC estimates of
recyclers operating at 30% capacity’ (ibid.: 26).
Jain (2010: 6) has provided an overview of scrap industry, not specific to e-
waste and resource recovery, as follows:

At sector level, the recycling industry is organized into paper, plastic,

ferrous, and non-ferrous sectors. In the non-ferrous sector, the majority of
recycling industry is involved in zinc, copper, and lead production.
Recycling industry meets 40 to 50% of the total demand of the metals,
plastic, and paper in the country.
 Strategies and initiatives for dealing
142

Trade chain and informal sector

In India,

the informal sector has a historic role in waste management and recycling,
partly because of the notion of waste being a fringe commodity, rather than
being a waste. As a result, historically the fringe commodity was left to be
handled by the fringes of society – the informal sector.
(Chaturvedi et al. 2010: 2)

As waste management is primarily a responsibility of local governments,

every government agency needs to manage huge quantities of waste generated
in large cities. As traditionally, the existing informal sector has been contributing
to reduce the burden of formal waste management agencies with their manual
skills, widespread and active network, recycling of waste, especially e-waste makes
a profitable business venture. Khattar et al. (2007) mentioned that 94% of
manufacturers were not aware of IT disposal policy and were disposing e-waste
to the informal sector.
As part of understanding the network for e-waste management, functioning of
the informal sector, particularly material flow, trade value chain, recycling
methods and recovered materials were studied, and alongside, hazardous
emissions, residues/ metal precipitates and landfills, leaching of toxins into soil
and water, etc. during recycling techniques related concerns were highlighted.

The existing recycling methods used are helpful only in the recovery of
merely a few metals and non-metals, namely Cu, Au, Ag, Al, Fe, Pb and
plastics. The present technology is of no use for the recovery of other
elements,
e.g. Pt, Pd and Ni, or glass.
(Dimitrakakis et al. 2006: 3)

‘Primary survey by the Greenpeace found high concentrations of Sb, Cu, Pb,
Ni, Sn and Zn,’ (Brigden et al. 2005: 7). Some data was generated on toxicity and
its impact through a primary field study (Brigden et al. 2005; Dimitrakakis et al.
2006; Manda 2008;Wath et al. 2011).The recycling techniques of the informal
sector has mainly been studied from Delhi20 and surrounding areas, and a few
from Chennai and Bangalore; most media reports were Delhi centric (Manda
2008).
Most observers of informal sector agree upon that this sector survives in the
country because it externalises different costs including recycling infrastructure,
recycling materials, labour cost, and logistics related costs (Sinha-Khetriwal et al.
2005; Raghupathy et al. 2010; Skinner et al. 2010; Sinha 2019b).

The cost of labour, the structure of the economy including the important
informal sector, the existing regulatory framework and the possibilities and
limits of law enforcement have to be taken into account in order to find
 Strategies and initiatives for dealing
143
solutions that can improve the situation with regard to environmental
impacts, occupational hazards and economic revenue.
(Sinha-Khetriwal et al. 2005: 503)

Some observers also confirmed that the informal sector focuses on cherry
picking of the precious components for metal recovery and the non-recoverable
are dis- posed off in landfills (Chaturvedi et al. 2010; Khetriwal-Sinha 2019).

The study conducted in Bangalore on precious metal recovery by the

informal sector states that the efficiency of the processes adopted by the
sector is around 28–30% whereas the gold extraction efficiency is around
99.99% by the smelting companies in developed countries.
(Chaturvedi et al. 2010: 2)

Inagaki (2008: 23) had studied PC-waste in Delhi and described five stages of
trade value chain as follow, which is applicable to all types of e-waste even after a
decade:

In the first stage, big traders purchase bulk PC-waste through domestic
auctions and from importers, and then re-sell the PC-waste to small traders.
In the second stage, small traders purchase PC-waste from big traders,
store the waste, segregate it into working and non-working PCs and parts.
The working PCs are sold to the secondary market and the non-working
PCs are sold to dismantlers. In the third stage, dismantlers purchase non-
working PCs from small traders through tender or from middlemen or
household waste scrap collectors and dismantle them…sell dismantled
components to extractors. In the fourth stage, extractors purchase scrap
components constituting specific raw materials and extract these materials
but not in a pure form. In the final stage, smelters recover specific raw
materials.

Inagaki (2008: 25–31) has studied spatial organisation of the chain, social structure.21
how upper part of trade chain – traders have huge economic gain because they
are equipped with large financial and spatial assets, and bottom part of the chain
– dismantlers and extractors, who seem to gain profit at the expense of payment of
safe equipment to workers and utility. Due to the difference in financial and social
status between trading and recycling parts, a structure of dependency of recyclers on
traders have been established. Economic benefits and environmental health costs
are structured differently between the trading and recycling parts; environmental
health costs are mainly burdened on workers and local residents in and around the
recycling units, affected through exposure to toxic materials emitted during the
recycling process.
As against structural analysis of the informal sector’s functioning, Sinha
(2019: 34–35) opined that

the e-waste trade chain, though informal in nature, is a very well-oiled

machine – well-networked adapting itself to an excellent hierarchy of
 Strategies and initiatives for dealing
144
control
 Strategies and initiatives for dealing
145
and distribution…excellent outreach points, its ability to access materials
from the most remote points and then getting back to mainstream trade is
highly efficient…the sector has deeper understanding of materials involved
and financial benefits associated with it.

He further argued bringing the state in the picture,

the real cause of concern is not the informal trade chain, but the process
involved in segregation and metal recovery from the waste…the state has
not made any effort either educate people involved or bring in that kind of
aware- ness among them so that practices are improved.
(ibid.)

This argument is supported by different actors, focusing on dignity of

workers, improving their quality of life, recycling facility, low rate to recovery of
materials, and need for transparency about sourcing of raw materials an operation
of this sec- tor (Babu 2007; Manda 2008; Subramanian 2014; Sinha 2019b).
Sinha (2019a) presented trade chain from the below,22 from collection to
recycle, unlike Inagaki (2008).

The first players in this sequence of collection are the individual waste
dealers or kabadiwallahs…then linked to large waste dealers or traders…
these large traders also acquire waste from the large offices…through
auctions… from the scrap dealer, the waste moves to he dismantler…each
component is dis- mantled and cannibalises the useable components like
ICs, capacitors…dismantlers are finally linked to the recyclers…who are
engaged in final recovery of materials. The metals extracted are usually sold
to smelters that purify the metals and sell them in the market for reuse.
(Sinha 2019a: 36–38)

The recycling trade provides livelihoods to a significant number of urban poor;

recovery of materials from this waste and ploughing them back into the supply
chain process are some of the advantages of the sector. The flipside of the
recycling sector is the hazardous practices and processes (Basu 2019; Sinha
2019a). As per a study conducted by the Centre for Science and Environment,
it mentioned that as informed by the district administration, around 100,000–
150,000 persons are engaged in informal e-waste recycling in Moradabad (Uttar
Pradesh) alone. Workers are paid around INR 200 per day for working in the e-
waste recycling sector with women and children earning far less (CSE
2015).‘The situation is likely to worsen if there is an exclusive environmental
focus while implementing the e-waste rules with scant attention paid to
livelihoods of the informal sector,’ (Chaturvedi and Gaurav 2016: 5).Three goals
are considered,‘closing’ the recycling loop, optimising the value added, and
sustainability of recycling (Wath et al. 2011; ILO 2014).
 Strategies and initiatives for dealing
146

EPR and take-back campaign

Nokia organised take-back campaign for mobile phones in 2009 and continued
till 2012, in different phases. The details of this campaign are presented in detail
in Chapter 2. In the context of EPR, based on Nokia experience about take-back
system, Singhal (2010) said that EPR is effective when there is a shift from
‘Brand Environmental Responsibility,’ (BER) to ‘ecosystem approach’ takes
place; adopted by every producer. Implementation of EPR based regulations,
material flow chain for each e-waste item, and channelisation of material at the
levels of country state, and city; internal/external leakage prevention; local and
cheap solutions for E-waste dismantling/recycling; and integration of informal
sector to formal sector; etc. are the challenges and the regulatory framework
should effectively address these challenges (Jain 2010; Sinha 2019b).

Formal-informal partnerships fostered

Informal sector’s employment presents a challenge in extending the reach of the
state to sections of the population that are often very large. The challenges are of
social and economic types that call upon much more than labour or social policy,
which include macroeconomic policies, fiscal policies, generally the structural
com- position of value added and wealth creation, and job creation. Among them,
macroeconomic policies are the key drivers, structural and sector policies provide
right incentives including improving governance and fighting corruption, and
social protection and risk management policies recognise voice and role of non-
state actor (Jutting and de Laigesia 2009). In this context, Indian informal sector
managing e-waste has remained unnoticed in macroeconomics, and structural and
sectoral policies; the protection and risk management (pollution, informal
economy, etc.) related concerns have been raised by non-state actors. Job
creation, resource recovery and secondary material management aspects of
macroeconomics in relation to e-waste recycling have not been duly addressed in
India.
ILO (2014) has introduced ‘decent work deficit’ with reference to e-waste sec-
tor. Due to bulk of e-waste recycling being carried out in the informal economy,
which is labour- intensive activities. Workers get ‘low earnings, long working
hours and exposure to hazardous substances, leading to a serious of decent work
deficits. The potential mismanagement of e-waste by informal workers can have
damaging consequences on entire communities, including children.’ (Ibid.: 18.)
As more formal recyclers entered in the sector for recycling of e-waste after
2005, the discourse on role of informal sector is fashioned around environment
(harmful to environment); and social, and economic (poverty centric/economic
disadvantages) challenges. This discourse discusses the following points: first,
can formal-informal co-exist, especially when the focus of environment is
shifting to economy (CE); second, what would be the impact on environment of
partnership between formal and informal; and third, whether the existing legal
actions/ regulatory provisions would lead towards formal economy in India.
 Strategies and initiatives for dealing
147
As part of fostering formal-informal partnership, organising workshops and
training programmes for exchange of information, along with a ‘study tour’ to
appropriate industrial sites in Europe as part of Indo-European training workshop
on efficient e-waste management, and detailing of e-waste flow and quantum,
strengthening knowledge base, and creating consensus on policy issues. An
aware- ness campaign was also launched, which led to knowledge and
technology transfer between the major European and Indian stakeholders and
contributed to the train- ing of the project target groups in optimum management
practices and technologies (Dimitrakakis et al. 2006). These workshops provided
space for dialogue between various non-government actors, such as, CSOs, bi-
lateral agencies, industrial associations, and recyclers (Dimitrakakis et al. 2006;
Manda 2008).
A group of observers said that there is a need for the formal-informal partner-
ship, referring to the National Environmental Policy, 2006 (NEP) stressed upon a
point that there is a need to identify the activities and contributions of the
informal sector and provide them with a legal status. They believed that both,
formal and informal together can gain from trading material, social welfare can
also be enhanced, reduction in pollution, better resource management, and
creation of ‘green’ jobs can take place with formal-informal partnership. Social
opportunities include raising aware- ness of communities, engagement of citizens
and the mainstreaming of the informal sector; economic benefits including job
creation, tax revenues for the government, and recycling and resource recovery;
and improvement in environment. (Chaturvedi et al. 2010; Raghupathy et al.
2010). Accordingly, the roles and responsibilities of the informal and formal
sector in the recycling chain should be clearly specified ensuring socially
acceptable, economically feasible, and environmentally responsible workable
models – overcoming the problems related the environmental, health and safety
hazards (Chaturvedi and Gaurav 2016).
A roadmap was prepared by Chaturvedi et al. (2010: 4–5) saying that the path
to formalisation of the informal sector units would require a number of stages.
First, to identify the major clusters of activity within the informal sector. Second,
to federate the disparate members within the cluster and also identify the various
processes within these groups. Third, efforts to create awareness and build
capacities among the groups of informal sector workers on environmentally
sound processes, and economics of recycling using efficient technologies for
processing e-waste. Fourth, hands-on trainings on skills upgradation, process
efficiency, and dos and don’ts, etc. as step towards formalisation process. Fifth,
specific allocation of funds for integration of the activities of the informal and
formal sectors, and environmental surveil- lance by the formalised informal
sector units. Further, the cost structure of the informal sector would change
radically with the introduction of certain processes which were not a part of their
value chain. Sixte, this would require the support of the government in terms of
provision of financial aid, easing access to credit and provision of financial
incentives such as subsidies and introduction of insurance schemes. The formal
recyclers could also support this integration process by build- ing the capacity of
informal sector associations as well as jointly developing the norms for trade of
material between the two sectors.
 Strategies and initiatives for dealing
148
Skinner et al. (2010) specified the role of legislation, in the context of reducing
the environmental hazards of e-waste recycling in India, which needs to address the
abil- ity of informal recyclers to outbid formal and state-of-the-art recyclers
(Figure 6.1).

Legislation must either prevent informal recyclers from accessing e-waste in

the same markets as formal recyclers or prevent them from externalizing their

 Research and Media reports

 Characteristics, composition,
and potentials of e-waste
 Understanding informal sector,
modus operandi, consequences
 International regulations
 Formal-informal partnership
Getting to know
ground reality,  Evolving methods for
Initiatives creating statistics –
generation, flow, recycled
Information,  Imported e-waste related
knowledge
base created
 Imparting trainings and
conducting workshops
with different actors
Reaching out  Awareness campaigns
masses  EPR – producers’ efforts
Pan
Indian
initiatives Policy  Separate law for e-waste
dialogues,  Use of hazardous
advocacy substances, toxicity
 Adopting and enforcement,
of International regulations
GoI
initiatives
Enforcement  Environment Protection Act, 1986
of regulations a) Hazardous Waste
Management Rules, 2008
b) E-waste Management Rules,
2011; repealed by Rules, 2016
and amended in 2018
 EPR – plan and targets  Strategy paper on ‘Resource
 Authorization of efficiency’ (2019)
PRO, recyclers  Linking with 3 missions – Digital
 Awareness related mandate India, Make in India, Swachh Bharat
 Thin institutional  Toxicity, Resource efficiency
mechanism for monitoring, data collected
evaluation of EPR plans  Efforts for spreading awareness

FIGURE 6.1 Overview of pan-Indian initiatives for dealing with e-waste during
2000 and 2020
 Strategies and initiatives for dealing
149
costs. Ideally, this would be done in such a way that the informal sector
would be integrated into the formal one.
(Skinner et al. 2010: 11)

Policy dialogue and advocacy for legislation on e-waste

The consortium formed after the workshop in 2004 continued working on
identifying various aspects of e-waste management. A workshop was jointly
organised by GTZ, Toxics Link, MAIT (Manufacturers Association of Information
Technology) and EMPA in 2009, in which ‘many stakeholders have argued that
the absence of legislation is one of the biggest stumbling blocks in implementing
an e-waste management system,’ (quoted in Skinner et al. 2010: 19). Dimitrakakis
et al. (2006: 8) mentioned that there is no policy or regulations for handling and
disposal of e-waste in the country out of the existing 14 laws for governing the
environment23. Though the GoI has signed the Basel Convention on the control of
transboundary movement of hazardous wastes and their disposal from developed
countries, India needs to ensure that wastes do not flow from the countries that
are not members of the agreement convention.
Wath et al. (2011: 260) had prepared an overarching map of different types of
challenges including scientific (eco-friendly recovery solutions for base and precious
metals, value addition to recyclables for reuse, such as, plastics, glass and others,
and disposal of process waste and residues – reduction in toxins and its extent);
engineering (scientific collection, transport, handling, segregation, and disposal
of e-waste, integrated/distributed processing facilities – informal to formal, and
engagement of NGOs and small and medium enterprises (SMEs), feasible techno-
economic solutions – processing, recycling, and recovery); and institutional
challenges (appropri- ate definition for e-waste in Indian context, inventorisation
of e-waste generation, import, and its characterisation, organisation and
structuring e-waste management system, and training and awareness on safety,
health, and environment).This map has been enhanced with many other social
actors’ studies (comparing India with other countries – EU countries, USA, etc.),
experiences and suggestions on management of e-waste; legal framework and
compliance; and formal-informal partnership, which are actually cross-cutting
concerns (Figure 6.2).
There was only one study conducted by ELCINA on consumer’s behaviour
for e-waste (Jain 2010).The key findings of this study include: at household level,
65% of the individuals while at corporate/ business level, 60% of the companies/
offices look for best monetary or exchange value for their old e-products; of
them, 2% of individuals and 6% of the organisations think of the impact on
environment while disposing off their old EEE respectively. Of total respondents,
48% replaced computers under ‘exchange and buy back scheme,’ 21% through
second-hand market, and 11% enter e-waste stream through scrap dealers.
Most social actors expressed concern about imported e-waste and need for
com- plying with international legislations (Puckett et al. 2002; Jain 2010); and
amendments in the existing Customs Act in consonance with the Basel Convention
(Toxics
 Strategies and initiatives for dealing
150

Need separate
Regulate informal
legislation for
Implement International sector - workers’
e-waste
Regulations for rights, improve
imported e-waste resource recovery

Formal-
Safe environment, informal
human health to be partnership
ensured
Policy
issues EPR
before implementation,
Hazardous 2010
substances, toxicity monitoring,
to be regulated inventorisation

FIGURE 6.2 Policy issues for e-waste management before 2010

Link 2003; 2004). Initial workshops, meeting, and studies on e-waste generation
and flow stressed upon two policy issues – production and consumption pattern
and need for inventorisation; and product design improvement for increased life-
span of an e-product, reduction in RoHS, and introduction of newer technology
(Toxics Link 2004; Khattar et al. 2007).
ILO (2014: 19) has articulated policy issues with respect to informal sector,
suggesting that the regulation and formalisation of the sector will be required to
tackle negative employment indicators and improve working conditions. As
profits in this sector are high and growing, and many view e-waste as an
opportunity for business ventures and income generation.The contrasts within the
sector vis-à-vis income needs to be recognised. Informal collectors, who are at
the bottom of the value chain, live on survival incomes while the incomes of
traders, scrap dealers, and dismantlers can vary greatly depending on how low or
high they are in the value chain.
The recycling scenario in the country was studied by several actors, and they
stressed upon the following policy issues: poor working conditions in informal
units dealing with e-waste, employment of child labour and casual labour,
rudimentary methods applied for recycling of e-waste, landfills, and leaching of
toxins, formal-informal partnership for creating win-win situation, etc. resource
efficiency, resource recovery, reuse/dealing with secondary materials – improved
technology, scientific methods, and infrastructure; legal framework to ensure safe
environment and protection from health hazards; designing system and its
institutionalisation related to collection, transport, economic instrument, roles,
and responsibilities of every stakeholder, monitoring); and creating data on level
of toxicity, level of emission and pollutants, and their impact on workers as well
as on environment and human health from different parts of India (Toxics Link
2004; Khetriwal-Sinha 2005; Jain 2010; Skinner 2010; Arora 2019b; Basu 2019;
Jain 2019; Sinha 2019b).
 Strategies and initiatives for dealing
151
Multi-pronged strategy, specific fund allocation, and necessary action with
reference to the NEP, 2006 for fostering formal-informal partnership. WEEE
management related activities and outcomes cover a wide range of sectors, thus
affecting the whole chain of industry, trade, academia, community, and
environment. Therefore, with regard to environmental protection and the quality
of life of the people involved in the recycling chain need special attention;
knowledge and technical expertise transfer, sensitisation, and dissemination, etc.
need to be addressed by the legislation (Dimitrakakis et al. 2006; Chaturvedi et
al. 2010; Skinner 2010).
Refurbishment has specifically not mentioned by the existing studies, rather it
has been considered as part of reuse/recycling. In response to the ‘Draft E-waste
Management Rules’ in 2010 (Skinner et al. 2010: 22) mentioned ‘Given the role
of the refurbishment market in India, it may take considerable time for the
benefits of this provision to become evident in recycling facilities.’
All these policy issues have been articulated from a sectoral perspective as
well as e-waste as hazardous waste (keeping safe environment and human health
as a context), with a greater emphasis on enacting a legislation. They envisaged
the State at the centre stage along with assigning responsibilities to producers; the
State to take up responsibilities of creating inventorisation, streamlining recycling
activities through monitoring and follow up necessary action by the regulatory
bodies while producers to take responsibilities for activating and managing entire
value chain – from e-waste collection to recycling; and dealing with informal
sector in such a way that its skills, value, and trade chain, etc. create win-win
situation for different actors in the sector. In between this space three issues have
been put forth: fostering formal-informal partnership; need for studying EPR
models and modify according to Indian scenario; and awareness leading to
behavioural changes (disposing e-waste responsibly and accepting 3Rs).

What was not thought about in the policy dialogue

and advocacy before 2010
In this scheme of ‘role of awareness,’ aspects, such as, the consumer/user of an
e-product is the producer of e-waste; repair and refurbishing are ways to lengthen
life of e-products; management of secondary materials in the globalised era and
global market; etc. were not thought thoroughly and put forth extensively.
The economics of recycling (technology, infrastructure, cost of reverse logistics,
etc.); potentials of recycling – resource recovery and organising secondary material
management; economics of EPR functions and performance; economics of
informal sector’s functions and performance, violation of worker’s rights, etc;
issues of governance and institutionalisation (engagement of various ministries
and centre-state government agencies) in federal structure and linkage of e-waste
with international regulations, Customs, Science and Technology,Trade and
Commerce, Environment, Health ministries, etc. were not articulated expansively
based on almost a decade’s experience regarding e-waste and its management.
 Strategies and initiatives for dealing
152
Due to non-recognition of informal nature of e-waste work by the authorities,
the workers remained excluded from the social and policy dialogue as well as
from gaining full awareness of the sectoral dynamics (risks involved in their
occupation) and from forming organisations and securing representation in
sectoral dialogues with other stakeholders in the value chain.Thus, workers’
collective concerns, needs and challenges among other industry players and
public authorities, and improving their working conditions, including skills
development and better income remained away from policy dialogue (ILO 2014).
In order to respond to policy dialogue and advocacy measures, the most
important step by the GoI was to prepare a research paper (titled E-waste in
India) by the Research Unit (LARRDIS) of Rajya Sabha Secretariat in 2011.This
report has covered country’s e-waste management scenario very
comprehensively and with minute details. The knowledge base created by all the
civil society actors is wisely used in the report; describing legal nitty-gritties, policy
requirements, different department/ ministry’s data and performance, media reports,
and people’s perception, etc. are substantial value addition to the existing literature
on the e-waste management in India.

II: Law-driven e-waste management – initiatives by

the government, non-government agencies, and
judiciary
This section covers pan-Indian initiatives post-2012; almost all initiatives
appeared to be associated or driven by the existing regulations. The actors are –
government, industry actors, non-government agencies, and the judiciary. The
initiatives include awareness measures; educational initiatives; conducting
research on various topics, such as, formal-informal partnership, gap analysis in e-
waste management based on multi-stakeholder views, etc; preparing roadmap for
the Agenda 2030; experimentation for resource efficiency and working out its
economics as part of CE; and launching courses on e-waste management.

Initiatives by government agencies and industry actors post-

2012
The first set of initiatives, taken by various government agencies, such as, state
government/ department (IT, Science & Technology, etc.) issuing Executive
Orders,24 mandating the government agencies for the proper disposal of e-waste
and its mechanism during 2012 and 2016; strategy papers on ‘resource efficiency
in EEE sector’, and on ‘resource efficiency and circular economy’ by the GoI in
2019; expression of intention to link three missions (Digital India, Clean India,
and Make in India) for economic betterment of EEE sector; actions taken by
regulatory agencies – CPCB and SPCBs at centre and state levels respectively
including inventorisation, creating database on e-waste generation; state run
academic institutions/ portal (e.g. SWAYAM,25 Skill Council for Green Jobs
(SCGJ),26 and National Skill Development Corporation (NSDC)27) launching a
course on e-waste management, and providing hand on experience; a training
manual for training of trainers on E-waste awareness for bulk consumers28
published by the MeitY under Digital India Mission (Chaturvedi et al. 2016b);
 Strategies and initiatives for dealing
153
initiatives on SDGs/Agenda 2030; and so on.
 Strategies and initiatives for dealing
154
The second set of initiatives cover industry actors (associated in the chain of
EPR implementation), including PROs, dismantlers and recyclers, repairers,
refurbishers, etc. contributing to the sector as part of legal compliance and
strengthening formal economy. Some corporate entities (e.g. YES Bank and
TERI report) have attempted to capture corporate perspective, bringing in newer
ideas as future action plan. The third set is of civil society organisations (CSOs)
including academic and research institutions, international (e.g. International
Finance Corporation (IFC), a World Bank Group and its five year long ‘e-waste
management program’) and bilateral agencies (e.g. GTZ).Their initiatives include
awareness measures; fostering for- mal-informal partnership; furthering research;
and teaching e-waste management at various places, in different ways. The fourth
set of initiatives came from the judiciary. This section is covered s part of ‘evolving
jurisprudence on e-waste management’ in Chapter 5. Few observations about the
profile of litigants, judiciary’s way of dealing with the legality, etc. are presented
very briefly.

Awareness related efforts, research, and materials

created
One of the firsts awareness raising on e-waste by the GoI is the Environmental
Information System (ENVIS).29 The centres are active in installation of e-waste
bins or e-bins and are motivating and providing the subsidised infrastructural
facilities and other necessary things to the private players for management and
disposal of collected e-waste through these bins. Chandigarh administration, in
companionship with the CII and Attero Recycling Private Ltd., collected
approximately 800 kg of e-waste from the city of Chandigarh alone (Yadav and
Bandopadhyay 2015).
Awareness aspect of e-waste and its management were explored by a few
stud- ies in the 2010s, more so, after the regulatory framework was enforced
capturing ground reality. Most studies are micro level, city specific like
Ahmedabad30 (Shah 2014), Bengaluru31 (Iyer 2014; Botharkur and Govind 2017),
Delhi32 (Kwatra et al. 2014), Srinagar, Uttarakhand (Nath et al. 2018);33 Pune34
(Bhat and Patil 2014; Shivathanu 2016), etc. while a study by Toxics Link (2016)
is a multi-city study, with the largest number of respondents from different parts of
India. All these studies are carried out studying Rules, 2011 but the findings are
relevant in the present time. These studies considered ‘awareness about e-waste’
as a critical part of e-wate man- agement, as awareness can lead to enhancement of
e-waste collection, to increase in recycling, and consequently reduction in hazards
for environment as well as human health.They have focused on different aspects
related to e-waste, such as, awareness about ‘what is e-waste’; about Rules, 2011;
as hazardous waste; disposal related – per- ception, attitude, behaviour, and the
existing mechanism; about recycling – meth- ods, hazards, etc. Among these
studies, the most common findings among different cities, reflecting ground
reality are awareness about e-waste varies; e-waste as haz- ardous waste is
known among almost 80% respondents; not more 50% know about channel of
disposal; and not more than 40% know about the Rules, 2011.Wipro has its take-
back channel which reported 100% recycling against the collection. Most banks
 Strategies and initiatives for dealing
155
and IT companies prefer to dispose of e-waste through auction.
 Strategies and initiatives for dealing
156
Pan India Awareness Programme (PIAP) was organised by MeitY, GoI in
2015. It was identified that lack of awareness about the safe disposal of e-waste
amongst stakeholders is a key challenge in enforcement of the Rules, 2016
(Chatterjee and Porwal 2019). The author duo has shared key findings of the
programme.35 First, informal sector has low awareness about the health and
environmental impacts as well as safety precautions associated with the recycling
of e-waste. Second, infor- mal sector workers have very low literacy and
awareness regarding hazards related to the unsafe handling of e-waste. Third,
awareness amongst consumers regarding e-waste management is inadequate;
consumers expect some return from end-of- life products and do not contribute
anything towards the safe recycling of products and thereby further promoting
unsafe recycling. Fourth, limited information and guideline on responsibility for
inventorisation of e-waste, getting authorisation for EPR and renewal, recycler
registration, monitoring compliance and action against violations of these rules.
With this context, they have described a few suggestions, which include
awareness and capacity-building content based on the local need and in local
languages, on social media, on platforms for massive open online courses
(MOOC) are made available; different media to be used for reaching out to each
stakeholder; and effective implementation of EPR, wherein producers’ websites
and awareness programmes are necessary (Chatterjee and Porwal 2019: 59–63).
Three manuals have been prepared under the Digital India, sponsored by MeitY,
GoI (Chaturvedi et al. 2016b, 2016c, 2016d).
Recently, Delhi based study by Malhotra (2020), covering 100 respondents is
another effort to know about awareness after Rules, 2016. Major findings are:
nearly 90% replace their mobile phones every 4–6 years; 60% were aware of e-
waste’s hazardous impact on environment and health. Around 51% of the
respondents were not aware about the existing policy for e-waste. 79% did not
come across any adver- tisements, campaigns, or any other related initiatives of
the government on e-waste disposal. 41% respondents shared that they had rarely
come across advertisements by any manufacturing or producer entity; this finding
corroborates Toxics Link (2019b) study on EPR compliance by producers – low
level of compliance by most of the producers, have not reached the consumers, at
large. 33% respondents sold their electronics to Kabaadiwala; 75.6% respondents
were willing to trade off e-scrap to recycler provided they were paid for it. 81.63%
did not know of any other col- lection mechanism for the purpose; 14% could
identify formal recycling companies. The study observed that ‘the responses of
consumers point towards “lack of infor- mation” on formal collection services
rather than “lack of willingness” as a barrier to safe waste disposal.’ (Toxics Link
2019b: 33.)
Regarding attitude of consumers towards e-waste, Ahmedabad based study
has quoted a government official of Gujarat state, which has been repeatedly
been cor- roborated by micro studies:

Indian consumers are not willing to part with electronic goods without
some monetary compensation…buyers and sellers do not know the
definitive value of an unused electronic. Without set prices, a trust deficit
arises between the
 Strategies and initiatives for dealing
157
buyer and seller…both buyers and sellers are discouraged from operating in
the formal system, in turn encouraging informal exchanges.
(Shah 2014: 23)

Preparing inventory on e-waste

Post-2012, inventorisation of e-waste is stressed upon, as there is no clarity about
its composition, method for calculation, and tracking e-waste that is collected
and recycled. Two states, Chhattisgarh and Telangana prepared inventory after
2015 (IRG 2016).36
Telangana state reported that 39.11 MT e-waste generated by three
government registered producers during the year 2016–2017. Of them,

M/s. Electronics Corporation of India Limited (ECIL), (Dept. of Atomic

Energy) produced 24.500 MT; M/s. Apple India Pvt., Limited, 5-132/B,
Sy.No.97/C, Near Kompally Railway Bridge, Secunderabad produced
13.585 MT, and M/s. Bharat Electronics Ltd., (A Govt. of India
Enterprises), IDA Mallapur produced 1.0227 MT e-waste.
(TSPCB 2016: 102)

The projected district wise E-waste inventory estimates both in numbers and
weights for Raipur division starting from 2011 till 2020. In 2016, 78,004 cellular
phones with 11.70 tonnes, 13,213 fixed line telephones with 13.21 tonnes, 6,092
computers with 127.54 tonnes, 2,798 printers with 19.59, 289 washing machines
with 15.87 tonnes, 51,243 TV with 1,584.17, 431 refrigerators with 15.07, and 200
air conditioners with 11.02 tonnes are listed (IRG 2016: 58–59).

Formal-informal partnership roadmap based on work

experience, research
The informal sector has a historic role in waste management and recycling in
India, and have strong linkages with secondary material market. Some theoretical
con- siderations are developed for formal-informal partnership. They are: first, the
exist- ing reality in India since more than a decade is – although formal recycling
units ensured recycling in environmentally sound manner and increased recovery,
they were unable to access large volumes of feed material owing to the activities
of infor- mal collectors, scrap dealers, and recyclers who operate on a door-to-door
basis and pay a good price for e-waste compared to formal recyclers.This
situation asked for striking a balance between two sectors (Wath et al. 2011;
Chaturvedi and Gaurav 2016). Second, the existence of an informal is enabled
with a widespread and active network, considerable manual skills, and economics
of recycling; the SMEs are infrastructure based entrepreneurial units that permit a
profitable e-waste manage- ment business. As most of the informal SMEs
concentrate on one or two recycling stages (collection, segregation, dismantling)
with well established relationships to
 Strategies and initiatives for dealing
158
other informal e-waste recycling SMEs up or down the recycling chain, some
value is added at each stage creating employment at different levels, which may
contribute to sustain the system. Third, among the informal sector recyclers,
social bond is an important factor, which could be used as a cohesion factor to
bring them closer and provide a platform for them to share their thoughts. Once
the informal recyclers create a bond among themselves, a ground is prepared for
their interactions with formal sector actors. Fourth, though the formal recyclers
are equipped with best available technologies, they face dual challenges –
investment in machinery along with more cost-intensive working standards, and
competition with informal sector recyclers vis-à-vis flow of e-waste and on cost
factor. Hence, the complementarity is thought of. Fifth, recycling per se is
considered as a secondary enterprise; its ability to create employment is considered
to be lesser than the primary/informal sector with its value chain. The move
towards formalisation of the informal sector can begin through integration of
mainstream recycling of e-waste, making them registered units, forming
associations, and professionalising their businesses. (Raghupathy et al. 2010;Wath
et al. 2011.)
GTZ/GIZ started forming partnership of formal-informal sectors for waste man-
agement in developing countries (Brazil, Egypt, and India) by late 2000s. One of
the reasons given was informal recycling economy in solid waste management
financially supplements the formal system in many ways (GTZ 2010, 2011).
Learning from SWM experiences, GTZ started articulating similar concept for e-
waste manage- ment. For example, forming and registering member based
organisations of informal sector workers after creating common grounds for
organising (trust building and a shared vision); strengthening capacities of the
informal sector (making informal sector workers as stable entrepreneurs and
reliable partners); technical specialisation; feeding experiences into national
policies and legislation; and so on (ibid.).
The Indian e-waste sector is characterised by highly dynamic market environ-
ment and high degree of fragmentation. As of now, linkages between formal and
informal actors in India are scarce and have not been implemented on a large
scale. After a ten-month project financed by GIZ, a study was conducted in 2017
to advise public and private institutions on approaches to sustainable
management of WEEE regarding options for producers and formal recyclers to
partner with informal collectors under the Rules, 2011. Six case studies were
investigated – green e-waste recyclers, Delhi; SWaCH, Pune; Saahas Zero Waste,
Bengaluru; E-WaRDD, Bengaluru; GIZ-Microsoft, Delhi, Kolkata and
Ahmedabad; and Chintan, Delhi – which succeeded or failed in maintaining
formal-informal partnerships across the Indian e-waste management system (GIZ
2017). In 2018, similar study was initiated to complement the study of 2017,
aimed at providing practical guidance under the recast policy framework of the
Rules, 2016 (GIZ 2018).
Before sharing the findings, the report clarified that ‘at times, the research
team was confronted with contradictory information and needed to cross-check
various sources in order to verify findings and produce warranted results.
Therefore, the findings presented in this paper should be interpreted carefully’
(GIZ 2017: 5). As part of recommendations, the report focused on design of
 Strategies and initiatives for dealing
159
partnerships, agreements
 Strategies and initiatives for dealing
160
and incentives, longevity of partnerships, and scale up and replication. The report
GIZ (2018) complements the report GIZ (2017) and provides practical guidance
under the recast policy framework of the Rules, 2016.
After the Rules, 2011, it was found important that the entrepreneurial char-
acter of informal collectors is to be recognised and respected in a way that the
organisational structure of partnerships should avoid strict top-down hierarchies.
After the Rules, 2016, focus shifted to how producers fulfil their responsibility.
In principle, they can opt to do so either individually or collectively; through self
or through a PRO. In the given scenario, two options were suggested – an
assessment of stakeholders should cover all relevant parties of the informal
economy (collectors, dismantlers, aggregators and recyclers) and analyse their
willingness to formalise; and producers and/or PROs shall cooperate with local
interface agencies, possi- bly represented by CSOs/NGOs or cooperatives of
waste pickers operating in the e-waste sector. Because trust is an important
factor, in fact, a pre-condition for the creation of formal-informal relationships
and should be seen as a valuable resource when connecting to informal
collectors.The CSOs can offer additional benefits to informal collectors in form of
trainings, educational activities or advocacy of work- ers’ rights and have the
ability of raising awareness for proper handling of e-waste among the informal
sector. For true partnership, if producer provide additional information on the
company’s view on the informal sector, it can strengthen the credibility of EPR
plans (GIZ 2017, 2018).
After the Rules, 2011, it was suggested that should be some degree of
flexibility in agreements between formal and informal, in order to adapt to
changing local conditions. The Rules, 2016, neither address the informal sector
per se nor spe- cific prescription is provided to producer for channelisation e-
waste – collection to recycling. Here is a scope for collaboration for
formalisation in qualitative manner, offering long-term support and technical
assistance to partnering informal sector players. Fostering an incremental
approach also has been suggested; frequent inter- actions and close monitoring
by producers or PROs should determine reporting frequencies for the amount of
e-waste collected together, also to assess the quality of materials, recommend
changes in organisational set-ups and prevent leakages of collected e-waste
towards informal channels producers. Such protocols need to include
occupational aspects, such as decent health and safety standards in collec- tion,
dismantling and recycling, transparency and reliability of prices paid to infor-
mal workers and strict exclusion of child labour (ibid.).
Institutionalising partnership include a few important aspects, such as,
designing an implementation schedule as a monitoring tool for producers and
PROs, conduct periodic audits at the partnering organisation, data from audits
needs to be thor- oughly documented in coordination with the partnering
organisation, reporting to public domain if both partners agree, sealing leakage
as much as possible with mutual commitment, and so on. For such partnership
and interactions, necessary resources should be provided, along with direct
support in form of granting access to in-house communication channels,
establishing contacts to bulk consumers or offering tailor-made capacity-building
measures (ibid.).
 Strategies and initiatives for dealing
161

Corporate sector's perspective and performance

A report written by Agarwal and Mullick (2014), published by YES Bank and
TERI-BCSD provides corporate sector’s perspective on e-waste management
including decision making about e-waste disposal, whether any policy exists in
the company, awareness about the Rules, channelisation of e-waste for recycling,
and filing annual return.
This study has surveyed 150 respondents from various sectors including BFSI
(Banking, Financial services, and Insurance), IT & ITES (Information technology
and outsourcing services), education, automotive, EEE manufacture, and miscel-
laneous such as consulting, aviation and hospitality. In order to present corporate
perspective, the survey has looked into how companies comply with the Rules,
2011. Of total 150, 52 (37%) respondents/companies were not aware of the
Rules; in corporations, 28% IT department takes care of compliance but 16% did
not know who complies with the Rules; 43% companies do not have any policy
to manage e-waste; 60% of them have authorisation from SPCB to handle e-
waste in their facility, however, 100% comply by filing return (Form 2); 32%
bulk consum- ers channelise their e-waste to authorised vendors and recyclers
and 30% maintain records (Form 1) and submit to SPCB.These findings show
that the companies lack awareness, have taken half-hearted measures for
implementation of the Rules and compliance related actions.The results
corroborate with Toxics Link reports (2014b, 2019a) regarding performance of
producers (Agarwal and Mullick 2014).
Regarding the recent environmental laws, the report observed that, the corpo-
rates aimed at

products rather than end-of-pipe pollution focus on new product design

mandates, substance restrictions, energy efficiency, and take-back
mandates. Such emerging trends of legislation is identified as a risk and
creator of chal- lenges for the industry: functioning of EPR systems
hampered due to unbranded and counterfeit products, original components
often get replaced with those of other brands during repair, by the lack of
knowhow regarding collection systems for recyclables, etc; transparency in
downstream of recy- cling industry in terms of data loss, data leakage, and
data security; and limited success of take-back policies.
(Agarwal and Mullick 2014: 12–13)

The report stressed on collection system as a crucial leverage for the success of
the overall system, and suggested that conventional market-based collection sys-
tem is to be utilised, if it is appropriate; in case, a new collection system is
evolved, the stakeholders should be made aware of that. The government needs
to provide incentives to the actors in collection system; the cost and
responsibility (primarily transportation and recycling) should be shared by three
primary stakeholders – the producer, the generator (households and bulk
consumers), and the local regulatory body (municipality).
 Strategies and initiatives for dealing
162
Regarding collection and recycling model, multiple modes of collection are
required for achieving the closed-loop flow for e-waste recycling; producers to
pay for this. The entire setup can be accomplished through strong mass public
aware- ness programmes to operationalise the system in the region, which can be
the mandate of PROs (setting up collection agents, aggregation, and transport
system). Manufacturers should bear the part of the financial responsibility by
contributing to a ‘Producer Responsibility Fund’ that would finance the cost of
establishing and operating PROs.The collection agents could be the local bodies,
NGOs or private entities, and may engage kabaadiwalas for door-to-door
collection.
The model of integration of the activities between the informal and formal
sectors is portrayed as an ideal requirement, for e-waste collection, segregating,
and dismantling. For consumers and bulk consumers, recommendations include
robust policy by bulk consumers, empanelling authorised recycler, and sensitisation
of their employees about hazards of e-waste. For manufacturers, various action
complying the Rules, including RoHS related, collection and recycling related
policy, com- munication related, etc. for policy makers and regulators,
recommendations include establishing strict monitoring mechanisms, inclusion of
informal sector, organising awareness raising programmes, and creating schemes
to encourage entrepreneurs to establish dismantling and recycling facilities in the
state.

Gap analysis in e-waste management representing

multi- stakeholder views
A report written by Verena Radulovic (2018), published CRB (Centre for
Responsible Business) and GEC (Green Electronics Council) has undertaken gap
analysis in the context of the given challenges in implementing the Rules, 2016.
This report was prepared based on survey of 20 stakeholders (producers, autho-
rised PROs, and recyclers, NGOs and Waste-picker Collectives, Trade
Associations, Government, Multilateral organisations, academics, and general
waste management provider), and their work experience since May 2017. This
report aimed to assess current priorities of the government and industry practices
pertaining to EoL man- agement of electronics in India, and what kinds of
capacity-building criteria would most effectively ESM.
The report has presented a synopsis of e-waste management efforts during
2008 and 2017, covering regulatory overview, producers’ collection and
recycling pro- grammes, bulk consumers’, and households’ pattern of disposing e-
waste, operations of informal sector, and flow of e-waste.The report introduced
‘voluntary consensus sustainability standard’ (VCSS) to build capacity.

Over the past decade, voluntary ecolabels for electronics have given
purchasers a mechanism to demand more sustainable products that exceed
product-centred environmental regulations, namely ones that are even more
energy efficient, made with fewer harmful substances, and recycled
responsibly at end-of-life.
(Radulovic 2018: 12)
 Strategies and initiatives for dealing
163
The findings highlight current gaps and posit ideas for how capacity-
building37 criteria in a voluntary standard (to which producers would
certify and that purchasers would use) could help ameliorate them.
(ibid.: 13)

Major findings include the following: (i) poor e-waste collection by producers
and inadequate supply of e-waste to the authorised recyclers; (ii) lack of metals
extraction capability among formal recyclers and leakage of e-waste to informal,
local recycling markets; informal collectors, dismantlers, and aggregators con-
tinue to generate higher profits selling material to informal recyclers instead
of formal recyclers; (iii) any NGOs with whom producers, PROs or recyclers
partner to reach informal workers may need initial training to understand India’s
e-waste trading markets;38 (iv) consumers and bulk consumers lack awareness of
their responsibilities under the current Rules, and of collection and recycling
opportunities; (v) CPCB and SPCBs lack technical capacity and resources to
screen and enforce registrations of recyclers and PROs; and (vi) only a few stake-
holders are in the early stages of considering linkages between e-waste manage-
ment, SDGs, and CSR (corporate social responsibility) requirements under the
Companies Act (ibid.).
This report has described opportunities for future research areas for e-waste
management in India; they are: (i) Audits for financial and mass balance
traceability claims; (ii) Formal processing (metal processing capabilities and
reasons for why smelters have not been established); (iii) Small Scale processing
for current infor- mal recyclers (evaluate feasibility of mobile processing small
scale factories); (iv) Organising the informal sector (what lessons from other
industries, such as, tanning, electroplating, fruit selling, etc. could apply to
informal communities for e-waste management); and (v) Material downstream
flows (examine end markets for materi- als in electronics within India).

IFC's e-waste programme in India: multiple agenda

achieved
This programme was started in 2012 with a pilot study in three cities –
Ahmedabad, Delhi, and Hyderabad.The baseline collected information from
consumers and last mile collectors (LMC). One of the achievements reported was
– increased income of LMCs, from USD7/month (INR 6,500) to estimated USD
36/month (approx. INR 25,000). The Bhubaneshwar project demonstrated
public-private partnership model. Several multi-stakeholder dialogues on
business, environment, health and social policy, and technology; celebration of
E-waste Day; etc. were organised dur- ing 2017 and 2019.
IFC and Karo Sambhav, Pvt. Ltd. a PRO, jointly developed an ecosystem,
aligned partnership with multiple stakeholders and civil society actors. Five
major pro- grammes were developed – with schools for awareness raising and e-
waste collec- tion; with bulk consumers for channelising e-waste and creating
awareness; with repair shops for capacity-building of repairers; with waste
pickers for engaging
 Strategies and initiatives for dealing
164
LMCs and increase in their income; and with waste aggregators for moving
towards formalisation/formal economy.

Roadmap India – vision 2030 documents experiences and

views of stakeholders
A published compilation titled, E-waste roadmap 2030 for India: A compilation
of thought pieces by sector experts39 by IFC and Karo Sambhav Pvt. Ltd. (2019) has
cap- tured Indian scenario and has shared a roadmap for e-waste sector. Some
important thoughts, initiatives, etc. are shared here as potential area for future
action – EPR, PRO, formal-informal integration, recycling technology and
infrastructure, inven- torisation of e-waste, monitoring for implementation of the
Rules, public aware- ness, etc. Only newer thoughts, which have not been
covered until now/in the previous chapters are mentioned here.
Tsuyoshi Kawakami (2019) reminded of ILO (International Labour
Organization) Safety and Health Convention (No. 155, 1981) that defines the
responsibilities of the government and employers in OSH (occupational safety
and health) and also the duties and rights of workers. He stressed upon
implementation of ILO Guidelines on OSH Management Systems (known as
ILO-OSH 2001) offer sys- tematic approaches (training and coordinating
government policy) for continuous improvements of OSH at the workplace/e-
waste recycling units.
Bernd Kopacek (2019: 74–76) has identified similarities and differences
regarding e-waste in India and Europe. His observations have been shared in the
Chapter 5.

Shift in discourse and necessary actions for e-waste

management by the GoI
Most important shift observed in the discourse of e-waste management is the
focus on CE. In the initial phase of public policy dialogue, safe environment and
human health under EPR were the focus. Now after almost a decade, CE has
become a focal point along with EPR as a core strategy to achieve SDGs too.
Initiatives by the GoI, such as, skill building initiatives under SCGJ and NSDC
2015 onwards, experiments by C-MET, strategy paper (MeitY and NITI Aayog
2019), etc. are directed toward enhancement of resource efficiency, in turn,
strengthening the CE through e-waste management. The regulatory provisions,
especially covered under the EPR and guidelines for its implementation clearly
show that these efforts are directed to strengthen CE.
However, the financial arrangements, and economics is yet to be worked out
for by the GoI, that is, fund allocation by the concerned ministries/state depart-
ment (e.g. MoEFCC, MeitY, Science and Technology), by three different
missions, and other sources.Two policies – New Environment Policy, 2006, and
National Policy on Electronics, 2012 under which newer programmes/schemes
could be launched by the GoI for the e-waste management. Such possibilities and
potentials are on the way.
 Strategies and initiatives for dealing
165
Monitoring (data based, field inspection) by the regulatory bodies has been
stressed upon in most write ups/dialogue.The CPCB took action based on inspec-
tion in Uttar Pradesh and has served a notice to three authorised
dismantlers/recy- clers on 12 March 2020. It has been intimated to the concerned
stakeholders that

during inspection, the above-mentioned dismantlers/recyclers were found

to be in violation with E-Waste (Management) Rules, 2016 and the amend-
ments thereof. All the producers and PROs are hereby informed not to
have interaction/agreement related to EPR of producers under the E-Waste
Rules with the above-mentioned dismantlers/recyclers.

The Goa SPCB has withdrawn authorisation of a collection centre with immedi-
ate effect in 2018.40 An engineer, in charge on e-waste at the Gujarat Pollution
Control Board (GPCB) informed on 4 August 2020 that he had served ‘intent
notice’ to every authorised dismantler/recycler unit in Gujarat state in the month
of March/April 2020, stating that there exists a gap between recycling capacity
and amount of e-waste recycled reported in last one year.This means that each
the unit is not functioning to its full capacity. The notice seek explanation from
each unit. Consequently, there has been an increase of about 10–25% in
dismantling/recycling of e-waste in a quarter (during May to July 2020). He has
also started a dialogue with all the authorised dismantlers/recyclers in order to
understand challenges they face. He has suggested to form an association of all
authorised dismantling/recy- cling units; thus, dealing with the existing
challenges of dismantling/ recycling, such as, improve quantum of inflow of e-
waste, sharing of facilities, reducing leak- age, dealing with cherry picking, and
so on.The formation of an association of the authorised dismantlers/recyclers is
under progress, as reported by the engineer of the GPCB.
Effective implementation of the Rules, 2016 and Amendment Rules, 2018
have begun to bear results in terms of legal compliance by the PROs, filing
annual returns by the bulk consumers, etc. based on figures available from the
website of the respective SPCBs, the latest annual reports of 2017–2018.

Indian e-waste sector is expanding

Throughout the chapter, role played by different Indian actors – government
agencies, industry actors, non-government agencies, research institutions, and the
regulatory bodies – and how each one interacted with bi-lateral, multilateral and
international actors/agencies on individual or collective basis is mapped out. The
initiatives include measures awareness raising; educational initiatives; conduct-
ing research on various topics, such as, formal-informal partnership, gap analysis
in e-waste management based on multi-stakeholder views, etc; preparing
roadmap for the Agenda 2030; experimentation for resource efficiency, and
working out its economics as part of CE and bringing in standardisation; and
launching courses on e-waste management.
 Strategies and initiatives for dealing
166
The e-waste sector needs to deal with a couple of chronic, inherent problems
of e-waste management, which have not been addressed by the existing legal
frame- work, for example, dominant presence of informal sector and workers
engaged in various operations; need for evolving standardisation for collection and
segregation, and dismantling/recycling of e-waste; preparing inventory of e-waste
so that cherry picking for recycling could be prevented; provision for funding to
develop recy- cling infrastructure and technology, which could enhance resource
recovery and efficiency. The process for developing ‘voluntary consensus
sustainability standard’ could be operationalised. Market development for sale of
secondary development is need of the hour so that not only metals but also
different type and grade plastics and glass also could be reused; access to this
market for the recyclers/dismantlers could be established and enhanced.

Notes
1 It is estimated that the volume of cell phone handsets will surge to over 100 million
and PCs to 25.5 million by 2007 (Mehra 2004). Of nearly 5 million PCs, 1.35 million
were likely to become obsolete in India in 2003, and in terms of weight it was
equivalent to 414,000 tonnes (Toxics Link 2003: 13); these figures were revised – of
nearly 8 million PCs, 2 million were likely to become obsolete in India (Toxics Link
2004a). For more details, refer LARRDIS 2011.
2 For example, about 30 MT of e-waste was imported and landed at Ahmedabad port.
Out of this, 20 MT was pure scrap and 10 MT was in reusable condition (Toxics Link
2003: 14). ‘According to a study conducted by the Central Pollution Control Board
(CPCB), 7,200 tonnes of imported e-waste arrive daily in the city [Delhi] for 300 days
a year’ (quoted in Dimitrakakis et al. 2006: 6).
3 Toxics Link from India, SCOPE (Society for Conservation and Protection of the
Environment) from Pakistan, and Greenpeace from China.
4 This report provided details about composition of a PC, sedimentation related details
of 18 metals and its impact on human health – allowable limits and increased
pollution, etc. as annexures.
5 This programme was planned in three phase: first phase (2003–2004) was to identify and
document the current e-waste handling situation in three urban areas – Delhi (India),
Beijing (China) and Johannesburg (South Africa); second phase (2004–2005) was planned
for improving the prevailing situation were jointly developed with the local partners in
the same three countries; and third phase (2005–2008) the programme is instrumen-
tal in supporting the various involved stakeholders to implement the planned activities
(Widmer et al. 2008: 466).
6 Swiss Federal Laboratories for Materials Testing and Research also named as Swiss
Federal Institute for Materials Science and Technology. In 2003, Switzerland had initi-
ated a knowledge partnership programme with industrialising countries, including India,
China, and South Africa.This was funded by Seco (Swiss State Secretariat for
Economic Affairs) and implemented by EMPA in cooperation with local partners and
authorities.
7 GTZ (Deutsche Gesellschaft für Technische Zusammenarbeit) has been active in
India on behalf of the German Federal Ministry for Economic Cooperation and
Development (BMZ), a cabinet level ministry of the Federal Republic of Germany.
GTZ works with the Central Government and various State agencies with its prior-
ity areas; e-waste is one of them as part of environmental policy and conservation,
 Strategies and initiatives for dealing
167
and sustainable use of natural resources. Renamed as GIZ (Deutsche Gesellschaft für
Internationale Zusammenarbeit) in 2011.
8 The Ministry of Environment and Forests (MoEF) was renamed in 2014 as Ministry
of Environment, Forests and Climate Change (MoEFCC).
9 MoEF, MoIT, CPCB, SPCBs, and PCCs
10 CETMA (Consumer Electronics and Television Manufacturers Association), MAIT
(Manufacturers Association of Information Technology), NASSCOM (National
Association of Software and Service Companies), CII (Confederation of Indian
Industries), ELCINA (Electronic Industries Association of India), and Telecom
Equipment Manufacturers Association of India (TEMA), and others.
11 This included Development Alternatives, TERI (The Energy and Resources Institute),
and Toxics Link.
12 IRGSSA (IRG System South Asia Pvt. Ltd.). 2005. Country level WEEE assessment
study. Delhi: Central Pollution Control Board.The e-copy or physical copy of this
report is not available.
13 For more details, refer Arora et al. 2019b: 69–87.
14 It typically includes products at the end of active life which either gets stacked inside
warehouses/store rooms or products that are not sold by consumers because of
inappro- priate resale value or are used for lower level application.
15 It includes the products that have been exchanged/ sold by their owners. Large quantities
of the Waste Electrical and Electronic Equipment get refurbished, reused or relocated
to smaller towns or villages.
16 This includes the disposed electronic products which are actually recycled and would
include the dismantled parts and components of EEE.
17 Of total 382,979 MT e-waste, 50,000 MT was imported, 56,324 MT was of comput-
ers, 27,5000 MT was of TVs, and 1,655 MT of mobile phones. Of total 144,143 MT
e-waste available for recycling, 50,000 MT was imported, 24,000 MT was of computers,
70,000 MT was of TVs, and 143 MT was of mobile phones. Of total 19,000 MT e-
waste recycled, 12,000 MT was of computers and 7,000 MT was of TVs.
18 Old Seelampur and Shastri Park in Delhi are the hubs for dismantling and recycling of
e-waste since early 2000s.
19 For example, ‘scrap of electrical items and copper wire, including jelly filled
telephone cables were imported under Chapters 85 and 74 of the Customs Act,
respectively, during financial year 2000–2001.
20 ‘Nearly 25,000 workers are employed at scrap yards in Delhi alone, where 10,000 to
20,000 tonnes of e-waste are handled every year’ (quoted in Dimitrakakis et al. 2006:
7). Delhi had become well-known for two processes – receiving and channelising
imported e-waste for treatment, and housing several recycling units.
21 The informal recycling chain is embedded with unique social structure with high ratio
of Muslim population involved. Starting from big traders, the deeply connected
Muslim community penetrates along the chain of recycling activities. The recycling
part of the chain is mainly dominated by poor Muslim migrants.
22 For the sequence of events in a recycling chain, see Sinha 2019a: 38 – a flow chart.
23 The MoEF has issued the following notifications related to hazardous waste until
2006: HWM Rules, 1989/ 2000/ 2002; MoEF Guidelines for Management and Handling
of Hazardous Wastes, 1991; Guidelines for Safe Road Transport of Hazardous Chemicals,
1995; The Public Liability Act, 1991; Batteries (Management and Handling) Rules,
2001; The National Environmental Tribunal Act, 1995; Bio-Medical Wastes (Management and
Handling) Rules, 1998; Municipal Solid Wastes (Management and Handling) Rules,
2000//2002;
 Strategies and initiatives for dealing
168
The Recycled Plastic Manufacture and Usage (Amendment) Rules 2003; and The National
Environment Policy, 2006.
24 Department of Science & Technology, GR no. COB-2004-394-DST, Gandhinagar,
Dated 24/12/2014 by the Government of Gujarat. Circular No. MPCB/RO(HQ)/B-
1980, Dated 20.04.2013 by the member secretary of the Maharashtra Pollution Control
Board, State of Maharashtra. State of Kerala, State of Goa and many other state
governments have issued notifications.
25 SWAYAM is a programme initiated by Government of India and designed to achieve
the three cardinal principles of Education Policy viz., access, equity and quality. The
objective of this effort is to take the best teaching learning resources to all, including
the most disadvantaged. SWAYAM seeks to bridge the digital divide for students who
have hitherto remained untouched by the digital revolution and have not been able to
join the mainstream of the knowledge economy (https://swayam.gov.in).
26 SCGJ promoted by the Ministry of New and Renewable Energy (MNRE) and CII,
established as a not-for-profit, autonomous, industry-led society under the Societies
Registration Act XXI, 1860 on 1 October, 2015.
27 NSDC acts as a catalyst in skill development by providing funding to enterprises,
com- panies and organizations that provide skill training. It also develops appropriate
models to enhance, support and coordinate private sector initiatives.The differentiated
focus on 21 sectors under NSDC’s purview and its understanding of their viability
will make every sector attractive to private investment (https://nsdcindia.org).
28 This manual aimed at covering 10 states Madhya Pradesh, Uttar Pradesh, Jharkhand,
Orissa, Goa, Bihar, Pondicherry,West Bengal, Assam and Manipur.The activities
include organising awareness workshops for RWAs (resident welfare
association)/localities, schools, colleges, bulk consumers (including corporate & Govt.
sectors), informal sector, dealers, refurbishers, manufacturers, etc. so as to build
capacities of the target groups to channelize e-waste in a manner that the rules are
effectively implemented (Chaturvedi et al. 2016b).
29 ENVIS was introduced in 1983, as a part of the Sixth Five-Year Plan. This is a
govern- ment’s computerised database system which facilitates qualitative and
quantitative infor- mation to policy makers, research organisations, decision makers,
scientists, etc. There were 68 nodes known as ENVIS centres existed in 2012.
30 A survey covering 55 respondents in Ahmedabad city in 2014 shared that 40
respondents did not know about formal collection channel/system; 18 respondents
could name spe- cific hazard of e-waste while 37 knew about hazards but could not
name any; six knew about government body or policy for e-waste management but
none of them knew particularly about the Rules, 2011.
31 Iyer (2014) conducted a study regarding e-waste collection and safe management in
academic institutions in Bangalore based on 37 respondents (students and teaching
fac- ulty); Faculty is more concerned towards e-waste generation, collection and
disposal, compared to student community. Botharkur and Govind (2017) conducted an
empirical study with the ‘bulk consumers’ – Banks, educational institutions, an IT
sector companies – to evaluate the existing E-waste management structures, consumers’
disposal behaviour and associated awareness. IT companies like Wipro adopts a ‘take-
back system;’ most of the banks and educational institutes take ‘auction’ as the measure
by calling tenders from authorised e-waste recyclers; one bank embracing an ‘e-waste
exchange system,’ or com- plying through PROs; they were unaware of recycling
practices.
32 Kawatra et al. (2014) covered 400 respondents in Delhi. Major findings: very low
aware- ness level; most were totally unaware about correct ways of its recycling and
management;
 Strategies and initiatives for dealing
169
less than a fourth replaced their consumer e-products and PCs within the first three
years of purchase; some users expressed willingness to pay extra cost for proper
management of e-waste provided that there is proper cost sharing between consumers
and producers; stressed upon producer take-back channel.
33 This was a community based cross sectional (consumers and scrap dealers) study in
Srinagar city of Uttarakhand state on knowledge about e-waste, its types and disposal
practices. 6.7% respondents heard the term e-waste; 77% of the respondents did not
know about the ways of disposal; 45.7% were totally unaware of hazardous effects of
improper disposal. Knowledge among scrap dealers about e-waste was altogether
absent.
34 Bhat and Patil (2014) conducted a survey of 100 respondents of Pune city. Of them,
65% were unaware of e-waste policy; 80% know about its hazardousness, collection
facility, and presence of metals; 57% disposed e-waste along with MSW. Shivathanu
(2016) con- ducted a survey of total of 600 consumers from Pune city. 58.5% of the
consumers are aware of e-waste management, and of them 91.45% of the show
preference for proper disposal of e-waste.
35 The manual of ToT (Chaturvedi et al. 2016b) was used to reach out to different
stakeholders
36 Both reports have mentioned about five models, mentioned in UNEP Manual (2007).
Chhattisgarh state has adopted Carnegie Mellon method for inventory assessment; two
approaches were adopted for required data – (i) combination of primary and secondary
data, and (ii) e-waste tracker tracking. The required data were: (a) information about
stakeholders i.e. recycler/dismantler, scrap dealer, consumer etc; (b) stock and
generation of e-waste; (c) origin of new electrical and electronic equipment i.e. mode
of procure- ment; (d) lifetime of electrical and electronic equipment; (e) EoL
management of EEE;
(f) process involved during dismantling; and (g) final destination of e-waste fractions.
A combination of Carnegie Mellon method and tracer tracking has led to inventory
assess- ment, covering all the aspects of material flow chain (IRG 2016: 50–51).
37 ‘Capacity building’ need not be limited to the informal sector, but also applies to
formal market and regulatory actors to foster systems better equipped to deliver
environmentally sound EoL management of e-waste.
38 PRO’s work with informal collectors, dismantlers, and aggregators, specific interven-
tions can begin to shift selling behaviour into formal channels; and interventions
should be tailored to the informal worker’s role in the e-waste management hierarchy
and the geographic market in which he or she operates.
39 Most of the written pieces are also published in the ‘Colloquium – E-waste
management in India: Issues and strategies’ in the journal Vikalpa, 44(3).
40 No. 1/20/18-PCB Lab/10785 Dated 31/08/2018.
7
MOVING TOWARDS HORIZONS

Traditionally, India has had a longstanding culture of circularity, which was

pushed in the early 1990s to a linear system of production which was more
compatible with global trade, global supply chains, and economies of scale.This
was resulted in to downscaling of traditional values of reuse and repair, and the
jobs associated with the end of the value chain being transferred to the informal
economy where they exist today. However, in recent years, the return of circular
economy principles has brought these traditional Indian values back into the
mainstream, mainly through a route of policy making in India. Businesses have
begun to adopt resource efficiency and circular production in their operations,
creating opportunities for the formal waste management sector (MeitY and NITI
Aayog 2019).
The way ahead could be consolidated on four domains of the e-waste manage-
ment as illustrated in the Figure 7.1.They are: legal and judicial domain;
economic concerns; recycling culture/ society; and environment concerns.These
domains are organised based on the ‘e-waste management thinking’ matrix,
presented in the Chapter 6.This chapter is organised around these four domains.

I: Legal and judicial domain

As the e-waste and its management is largely law/regulation driven with EPR as
a strategy, it is very important to comprehend the architecture of the regulation;
how it offers opportunities and identifies challenges for its enforcement thorough
insti- tutional mechanism, processes, and action by the stakeholders; role of
monitoring ensuring legal compliance; what happens in case of non-compliance;
understanding jurisprudence; and how regulatory body plays its role – in
monitoring, enforcement, and legal compliance after the Court/Tribunals’ order.

DOI: 10.4324/9780429285424-
7
 Moving towards horizons
166

Legal, judicial domain

Economic concerns
a) Enforcement through EPR, facilitation a) Circular economy -business model
for compliance b) Fund for infrastructure, technology to
b) Non-compliance to be tracked by deal with market gaps and barriers
monitoring c) Skill building, Repair & refurbishing
c) Evolving jurisprudence -compliance d) Formal-informal sector partnership,
by regulatory body is necessary Employment generation
E-waste
management in
India
Recycling culture/society Environment concerns
a) Culture of 6Rs - repair, reuse, a) Design modification, innovation
refurbish, responsibly disposed, folloing LCA, RoHS compliance
recycle, recover and its b) Responsible disposal
institutionalisation c) Sustaibnbility -SDGs compliance -
b) Prioritising investment, management ecosystem approach & EPR
of secondary material market

FIGURE 7.1 Way ahead for e-waste management in India

Architecture of the regulation, EPR, and outcomes

The architecture of the regulation shows clear equation, in line with EPR, as
follow: classification of the e-waste according to its various components and
compositions (Schedules I and II), and emphasising on preparing inventory, role
of stakeholders defined including collection to treatment mechanism creating
awareness raising, reporting, and filing annual returns, etc., and this database
becomes an instrument for monitoring and evaluation.This would lead in increase
in e-waste collection and recycling, and thus a step forward for the resource
recovery, resource efficiency, and the CE. The CE is important, especially in
terms of making life longer of e-prod- ucts, reducing quantum of e-waste, and
contributing to economy.
In such a straightforward equation, several nodes, and legal loopholes
remained untied or unaddressed, which have become challenges. The challenges
are articu- lated from wider context of environment, economics, human health,
dominance of informal sector, and of governance. This domain covers mainly the
following aspects that have created opportunities and challenges: (i) statistics
related; (ii) legal compliance by producer, through PRO; (iii) regulatory body
related; (iv) monitor- ing import of e-waste; (v) awareness raising among various
stakeholders related; and
(vi) coordination with/among different ministries/government agencies/missions
(government programmes).

Role and scope of statistics and data driven actions

Almost all countries have expressed concerns for either not having database or
dif- ficulties in creating database, mainly due to absence of standards and
methods for calculating e-waste – generation, collection, flow, treatment and/or
recycling as well as data on resource recovery based formal economy (ISWA
 Moving towards horizons
167
2014).
 Moving towards horizons
168
With mandate for all the stakeholders of maintaining records and updating
time to time, and filing annual returns, have created a huge opportunity and a
possibility of a strong database, inventory of the e-waste. As against this, the first
challenge is, if the required information is not provided by the stakeholders, what
action would be taken by the regulatory authority?
With collection of these data, every stakeholder’s performance could be
monitored and evaluated, as and when required, based on the available database.
However, as these reporting items on e-waste are limited, some essential data
would not be created/available on other important aspects of e-waste manage-
ment, such as, extent of resource recovery and improvement in efficiency,
second- ary market scenario, jobs/employment created and other economic
benefits, how the CE is enhanced, impacts on human health, and impact on
environment (CO2 emission, BFR related, mercury level, use of fossils, carbon
and natural resources, levels of contamination of different metals and POPs, etc.),
and cost saving through refurbishing of EEE.
Though refurbishers are key players as per the Rules, 2016, their contribution
to e-waste management, in terms of repair and reuse of EEE, also may remain
undocumented.Whether authorised units could employ skilled labour or the
unau- thorised units/informally operating units for dismantling/recycling e-waste
earning livelihood – such broader concern of unemployment/development agenda
would remain largely unanswered. Empirically, such concerns may remain open
to ques- tion (Gaikwad 2019).
A few challenges are also foreseen with regard to informal sector’s
functioning that has not been covered under the Rules, 2016. For example,
informal collection and unscientific recycling of e-waste would be continued by
unauthorised disman- tlers/recyclers, and consequently would remain unreported.
How would CPCB and SPCBs would collect data that has remained unreported,
out of the legal purview. ‘To what extent e-waste has been dealt by unauthorized
agencies,’ may not be answered with the existing database. In this case, some
damage to environment and human health takes place by unauthorised
dismantler/recyclers, how would CBPB or SPCB find out.What actions would be
taken against them?
Data may be collected on collection, dismantling, and recycling but in
absence of due processing the collected data, the monitoring by regulatory
authority may not take place or remain weaker. For example, data on ‘awareness
measures taken by producers and its impacts’ may not be available in form of
whether awareness led to the desired extent of disposal of e-waste. If awareness
of consumers/bulk consum- ers, and other stakeholders leads to some positive
environmental impacts (reduction in toxicity, use of energy, reduction in emission,
etc.), the desired/required statistics may not get generated/available due to greater
emphasis on EPR enforcement strategy.
A couple of questions are raised, which may turn out to be a challenge related
to statistics and e-waste management through meaningful statistics. For example,
can wholesome inventory be prepared based on available data, and whether
CPCB is equipped with methods and technology to process the available data?
 Moving towards horizons
169
Thus, selective set of data would be collected as part of regulatory measures;
effective use of datasets would depend upon the enforcement agency, leading to
achievement of e-waste management.The scope for data driven actions remain
lim- ited, for example, awareness raising, employment generation, CE related.

Legal compliance by producer, through PRO

Under EPR, producers pay for entire reverse supply chain, clarity on funding
mechanism is required. However, ambiguity about ‘who is a producer’ further
com- plicate the matters; and becomes a barrier for new business models. For
example, along with material flow and financial flow analysis, who pays to
whom for what and how are critical, as these matters are technical and political in
nature (Khetriwal 2019; Sharma 2019).
If producer cannot implement all the responsibilities mandated under the
Rules, performing these duties through an authorised (capacitated) PRO 1 is an
oppor- tunity to achieve objectives of the Rules, as it sets up entire value chain
(from collection to recycling e-waste)/ecosystem. However, this provision has its
own implications and challenges.
Though the concept of PRO as an entity is an integral part of EPR, which is
mainstreamed across the world; Indian stakeholders covered under these Rules
are still not well aware of it. Further, masses know lesser about the PRO as an
entity. The partnership between a PRO and a producer is critically based on
principle of cooperation, on long term basis; generally speaking, this also is a
lesser-known fact. A couple of PROs, dealing with e-waste in the country have
started shar- ing their work experiences, and are articulating challenges based on
their work experience.
A PRO has to build a holistic system/ecosystem that goes beyond ‘compli-
ance’ in its simplistic form. Building up ecosystem aims to collaborate and
develop partnerships with all the concerned stakeholders from the entire value
chain for varied tasks – large number of informal waste pickers and aggregators
from vari- ous locations, ‘bulk consumers’ including central and state
government authorities, civil society actors and organisations, research and
academic institutions, and so on. PRO’s varied tasks include quality of e-waste
collected, ensuring safety measures for storage and transportation, fair pricing,
recycling and recovery, etc. Creating and maintaining database for such varied
tasks and activities become necessary for a PRO (Sinha 2019b), which demands
commitment and efficiency.
Given objectives of the Rules, 2016, reduction in illegal e-waste collection and
recycling requires due diligence in such long-term processes. Usually, a producer
engages a PRO on annual, contractual basis. This situation creates a sort of gap
between the two entities on the count of commitment – the process-oriented tar-
gets become physical target on short term basis. This situation creates potential
scope for ‘paper trading, malpractices,2 multiple accounting practices,3
misreporting’ (Singhal 2019b: 152), and age-old problem of leakage of e-waste –
from a PRO/ recycler to informally functioning recycling unit, back to the waste
aggregators and
 Moving towards horizons
170
again marketed as e-waste to be recycled. Though such problems defeat the
objec- tives of these Rules, they have not been taken into consideration.
In order to enhance e-waste collection, it is important that bulk consumers dis-
pose their e-waste and legally comply by filing annual returns. Most bulk
consumers are not aware of PROs and their role in e-waste management; those
who are aware about PROs, have not started disposing e-waste through PROs,
mainly because of lack of coordination and gap of communication between
government entities. For example, a platform like Metal Scrap Trading
Corporation (MSTC) which is used for selling scrap material, including e-waste,
by most public institutions. At present, MSTC does not allow PROs to use its
platform. On one hand, the CPCB authorises the PROs, and the government run
unit like MSTC does not recognise the authorised entity like PRO, on the other
hand.‘However, it has not been com- municated to the MSTC,’ (ibid.).4

Regulatory body – institutional mechanism, capacity, and

effectiveness
The CPCB is an autonomous regulatory body, which is an advantage. CPCB and
SPCBs perform several functions, such as assessment of pollution – air, waste, soil;
monitoring of source specific pollution of air, water, soil; monitoring of ambient
air and water quality; development and enforcement of standards; hazardous
waste management and dissemination of information; and conducting mass-
awareness programmes (IIML 2010); and improving quality of air and water,
disposal of differ- ent types of wastes (hazardous, electronic, bio-medical,
municipal solid, etc.). These bodies have been engaged in monitoring of pollution
levels, contamination, etc.; thus, they would be able to monitor e-waste as per the
Rules.
Building capacity of these bodies is an opportunity. Thomas Lindhqvist in his
interview in 2019, reflecting on EPR implementation, shared his observations
and views. Regarding EPR monitoring, he said, ‘we need to raise the competence
of these organizations (CPCB and SPCBs). They really have to learn how to do
this efficiently.’ While answering the question, ‘what is not working regarding
EPR implementation in India,’ he said, ‘you have to try to make people
understand why it’s important and understand what consumers want… you also
have to make com- panies understand why this is important and that people
might not reward you every time they are buying something, but they
(companies) have to build an image of a responsible actor, of someone
consumers can believe in.’ Quoting EU coun- tries as examples, he also stressed
the need to think beyond guidelines (rules), and interpreting them to fulfil. Such
intention is to be replicated in India (Kapil 2019). As against these
responsibilities, there exists very thin mechanism for enforce- ment at the CPCB
and SPCB, with a staff small in number. This creates huge challenges for their
effective functioning, especially monitoring, reporting non- compliance, taking
necessary punitive actions as per the legal provisions, ensuring compliance
ordered by the Court/Tribunal, and so on. The Centre for Science and
Environment (CSE) has shared their experiences regarding regulating e-waste
 Moving towards horizons
171
as an environmental policy issue, its report highlights that the approach of regula-
tory agency is geared towards giving multiple clearances, consents and authorisa-
tions, and with poor monitoring and enforcement (CSE 2014: 6–10). By giving
an example, the report reinstated that most SPCBs suffer from severe deficit of
man- power, infrastructure, and competence in addition to the challenge of
transparency and accountability. Describing MPCB in 2014, the report illustrated
that a technical officer is responsible for monitoring more than 250 factories; 30%
of the sanctioned posts have been filled in the Pollution Control Boards of
Haryana, Andhra Pradesh, and Odisha states).
As such, the formalisation (registration, authorisation, and monitoring) of pro-
ducers and dismantlers/recyclers may be effective under EPR, yet several loop-
holes and implementation related challenges are highlighted by the practitioners
of e-waste management.A couple of suggestions5 for improvements in
performance of SPCBs in dearth of human resources and multiple functioning are
under consider- ation by the CPCB.
First, there are several unauthorised units are functional for e-waste collection,
channelisation, and dismantling/recycling.Without authorisation, selling or placing
of EEE in the market by any producer is not legal, penal provisions are not men-
tioned in The Rules. How would CPCB find out functioning of non-authorised
units? For continuity of such illegal activities, what role regulatory authority can
play for achieving the objectives of the Rules, 2016?
Every producer is expected to achieve the target every year; in case, the target
is not achieved by a producer – how would CPCB verify? What penal action will
be taken by whom – the CPCB or MoEFCC – is not mentioned in The Rules. The
process of maintaining records for compliance with the regulation’s requirements
would be expensive in addition to the administrative costs to every key
player.The authorised producers and dismantlers/recyclers are already struggling
to compete with informal sector players.There is a likelihood of weak
compliance on the count of maintaining records of different types; the regulatory
authority would have dif- ficulty in monitoring with thin mechanism, without
putting IT solution in place.
In this context, the third challenge is, if data on RoHS compliance is not pro-
vided – what action will be taken by whom (CPCB or MoEFCC) is not
mentioned in the Rules; the CPCB Guidelines too is silent on this point. If no
data provided by a PRO on awareness measures undertaken, what action will be
taken by whom (CPCB or MoEFCC) is not mentioned in the Rules.
An e-portal for monitoring by the CPCB has been in process, as mandated by
the NGT. However, it is argued that instead of centralised database, the process
needs to be state-centric for better performance at state level. In light of dearth of
human resources, it is suggested that third party audit and verification of
local/state data of vendors, aggregators, recyclers, etc. could be done by the IT
solutions, in place of every SPCB office. Thus, human burden could be reduced,
and monitor- ing could be effective with technology enabled solutions. The
problem of leakage of e-waste is closely linked to this issue. One of the ways to
deal with this problem is: an association of recyclers/dismantlers could be
promoted so that every SPCB
 Moving towards horizons
172
office deal with the association. At present, every SPCB deals with each
authorised recycler/dismantler on one-to-one basis. If there is a platform on
which common issues are discussed (e.g. auction of e-waste by every bulk
consumer, collection and transportation of e-waste within state, minimum
quantum of e-waste to be recycled per annum, etc.), solutions could be sought
and implemented affectively, and gen- eralised solutions rather than a piece-meal
solution, by building the bridge between the different stakeholders/ implementors
and the regulators.
The attitude of the existing rules and regulations is ‘to eradicate’ informal
play- ers, which is not possible in the current scenario. Regarding leakage and e-
waste entering grey market, revision in the existing provision is required as well
as role of municipal corporations/urban local bodies (ULBs) to be
operationalised. For example, every waste collector needs to be registered with
an authorised recycler. At present, every authorised recycler is required to recycle
a maintain a minimum quantum of (300–500 tonnes e-waste) per annum. Instead,
if small scale recycling/ dismantling units are authorised, the informal sector
units could be formalised this way, and transportation of collected e-waste would
reach state-based recycler. Tracking e-waste within a state by the regulator would
be easier, small scale unit (becoming informal to formal unit) would be able to
treat e-waste in small quanti- ties and reported, and consequently, how much e-
waste residues (plastic, glass, etc.) other than the metals recovered go to the
landfill could be quantified. Further, if market linkages are established for selling
of secondary materials, landfills and con- sequent contamination could be
controlled to great extent along with stoppage of leakage of e-waste.Thus, overall
monitoring by the regulators improves at state level, in decentralised manner, along
with participation of different stakeholders.
Tracking of recovered materials needs to be done on two counts – RE and CE,
and toxicity; thus, along with economic value of recovered materials, data is
availed on toxic materials recovered, leading to effective environment
protection.This is an opportunity, and a challenge, too.

Monitoring import of e-waste – not duly addressed

Skinner et al. (2010) commented on the Draft Rules, 2010, based on a research
on monitoring efforts in the EU and USA. This observation has come true and is
still applicable, even after a decade.‘The draft rules are unlikely to stop e-waste
imports, illegal or legal, as the complex mechanisms involved with monitoring
imports, exports and domestically generated e-waste are all extremely resource-
intensive,’ (Skinner et al. 2010: 23). Monitoring in India could be ‘hampered by a
lack of inter- national customs codes differentiating between new computers, old
computers and e-waste, and a large number of entry and exit points for e-waste in
each country.’ (Ibid.) Further,

the states possess the main responsibility for determining methods of moni-
toring and compliance may lead to additional administrative and
compliance costs as well as differing degrees of enforcement…Unnecessary
administrative
 Moving towards horizons
173
costs caused by legislative and monitoring contradictions and overlaps further
add to the financial burden of enforcement activities.
(Ibid.)

Awareness raising responsibility of different

stakeholders and their performance – producers,
state governments, regulatory body
It is believed that if consumers are aware of e-waste, its composition with
hazardous and non-hazardous substances, its potential for resource recovery and
responsible use of e-products and disposal of e-waste could be enhanced; and in
turn strengthen the formal or circular economy.Awareness can lead to behavioural
changes, custom- ers’ commitment to 6Rs could be translated into practice. Thus,
awareness is seen as a critical component of e-waste management; the Rules have
mandated different stakeholders to spread awareness, which is considered to be
promising opportunity. Toxics Link report (2014b, 2015) showcased that
limited awareness measures have been undertaken by producers. Toxics Link
(2016) revealed that 66% of con- sumers (including bulk consumers) remained
unaware of e-waste and the Rules, after five years of its implementation. These
revelations articulate the challenges regarding awareness, implementation of EPR,
and e-waste management, especially, the continuation of informal sector’s
operations, such as collection and unscientific
recycling of e-waste, employing children as workers, and so on.
Different aspects of awareness on e-waste were discovered with studies
carried out in different cities (see Chapter 6). The state governments and ULBs
are made responsible for undertaking initiatives for e-waste management. With a
special ref- erence to Ahmedabad Municipal Corporation (AMC), a study has
observed that most ULBs have no financial mechanism in place, which hinders e-
waste collection activity. This makes producer compliance ever more vital (Shah
2014). The AMC had a tie up with an authorised recycler in 2017; however, the
recycler did not get anticipated quantum of e-waste. ‘Ahmedabad procures
around 400 tonnes of elec- tronic waste [every month]. Of this, only 13% is
recycled,’ (Patel 2017). A study on Pune city reported that its solid waste
management system has to bear an extra 30% of load of e-waste not being
separated, collected of recycled by the government institutions (Takale et al.
2015: 4241).
The challenges are as follow: various stakeholders – producers, state govern-
ments, SPCBs, etc. are responsible for spreading awareness on different aspects
of e-waste management. However, in absence of availability of macro data, it is
not clear – who has done what, how many initiatives, with which stakeholders,
etc. awareness spreading, and impacts of awareness measures.

Coordination among different government agencies

and missions
E-waste is complex. Different ministries are involved in e-waste management;
for example, MoEFCC is a nodal ministry, MeitY has taken up various measures
 Moving towards horizons
174
including awareness related, resource recovery related (through C-MET), role of
Ministry of Science & Technology in innovation, etc. The strategy paper by
MeitY and NITI Aayog (2019) on resource efficiency has mentioned
involvement of three missions (Clean India, Digital India, and Make in India) –
these are opportuni- ties for e-waste management. However, concrete actions like
budget/fund alloca- tion, launch of a specific programme for e-waste
management, upscaling C-MET experiment – from laboratory to commercial
scale for recycling unit, etc. awaited. Some cities (e.g. Ahmedabad, Pune) have
entered into association with an NGO for waste collection, including e-waste, and
have created a channel from e-waste collection to recycling.
Disposal of e-waste by bulk consumers, specifically government agencies
require changes in General Finance Rules (GFR).There are practical problems as
against the Ahmedabad and Pune city is, a commissioner, in charge of waste
management, faces issues of e-waste disposal and the revenue earned. It is
observed6 that if a municipal corporation ties up with a PRO for e-waste disposal,
the revenue earned and associ- ated financial auditing ask for changes in the
present set up. It is also observed that the District Collector asks for an Executive
Order/guidelines for e-waste disposal. For example, the Department of Science
and Technology, Government of Gujarat has issued a notification in 2014
regarding e-waste disposal by the government agencies.This notification could be
considered valid even after the Rules, 2016 were enacted. However, the ULBs
expressed a need for specific guidelines. Thus, such opportunities become
challenges.

Scope for legal review, institutional feedback

mechanism, grievance redressal mechanism needs to
be built in
The existing regulation is as such in form of rules and not legislation in itself,
thus the scope for implementation is restricted. While looking at from
governance per- spective, i.e. accountability, people’s participation, and
transparency, it becomes clear that it does not provide a scope for institutional
feedback mechanism and grievance redressal mechanism. When any regulation
directly deals with industrial matters, opportunity for its review is essential, as it
can incorporate experience-based lean- ing and modification-based performance.
The regulation thus evolves simultane- ously with industrial development. Two
mechanisms – institutional and grievance redressal – provide opportunities to
plug the gaps identified during implementation of the Rules.

II: Economic concerns

Economic concerns include opportunities for CE through the existing/newer busi-
ness model; building up infrastructure supported with a cadre of skilled workers;
using green technology; dealing with market gaps and barriers; need for employ-
ment and skill building for repair and refurbishing units; and by fostering formal-
informal sector partnership.
 Moving towards horizons
175

Business opportunities
E-waste is a value creating waste, mainly through the process of recovery of
materi- als, and selling of recovered/secondary materials.Two opportunities
created through the Rules – first, start-up for dismantling/recycling of e-waste;
and second, being PRO and creating ecosystem for upscaling innovative and
cohesive initiatives for e-waste management. There is a huge potential for job
creation in the value chain of e-waste, including waste collectors, aggregators,
repair shops, refurbishers, ware- house keepers, and transportation business. The
e-waste sector has the potential to create around 6 million jobs, perhaps in just a
few years.The opportunity for a start- up is linked to the legal provision – all state
governments are made responsible for facilitating e-waste management related
various activities including creating eco- parks, providing infrastructure, capacity
and skill building of dismantling/recycling units, and workers engaged in e-waste
collection and recycling for start-ups. ‘Hub and Spoke model’7 for infrastructure
and viable recycling businesses is suggested (Chaturvedi and Gaurav 2016).
Financing for start-ups is a challenge. Recycling, its infrastructure, capital
invest- ment, inflow of e-waste, circular value creation across downstream and
upstream, etc. challenges have been mentioned in the preceding chapters.Another
set of challenges is whether or not a state government would be able to maintain
e-waste focus in every infrastructure created for industrial purpose is to be seen, a
challenge in itself. Refurbishers occupy an important position in the emerging
circular economy for electronics, as they extend the lifetime of both new and
used EEE. However, in doing so, they invariably generate residues from the e-
waste from the used EEE. Due to a lack of infrastructure and waste management
systems, this e-waste is not always disposed of in a safe and environmentally sound
manner (Shevchenko 2019).

Fostering formal-informal partnerships

In the existing set up, informal sector has a very organised network for collection
to recycling of e-waste as well as selling of secondary materials. This sector has
flourished on market-driven requirements and strategies, especially the entire value
and trade chain, subsidising the cost of formal operations across the chain.
Studying functioning of the informal sector players, their functioning, skills,
management abilities, infrastructure, sustaining and expanding the network of
various players in the entire value and trade chains, etc. and learning from them
could be a value addi- tion.This is a huge opportunity for moving towards formal
economy, and away from the informal economy, and making the formal and
circular economy sustainable. The informal sector has been recycling e-waste,
and trading the secondary materi- als for more than four decades, and expanding
exponentially. Building up formal- informal partnership can bring in more
transparency, accountability, and auditability.
While focusing on collection and treatment (refurbish/dismantle/recycle) of
e-waste, the existing regulatory framework has not taken cognisance of the
informal sector in the country, dealing with e-waste and controlling entire value
chain – from
 Moving towards horizons
176
collection to recycling. As the regulation has not taken cognisance of
unorganised sector, it does not entail measures for rehabilitating those persons
who are engaged in the e-waste management operations in unorganised manner.
By not recognising existence of informal sector players, these Rules are also over-
looking critical aspects of the objectives, ‘how informal operations – collection
to dismantling/recycling activities would be reduced.’ Making informal sector
and its range of activities for the trade chain as ‘illegal’ through regulatory
measures would not deal with problem of dominance of informal sector in e-
waste management (Agarwal 2016; Gaikwad 2019). Consequently, not paying
adequate attention to health hazards, damage to environment, working conditions,
wages, and social secu- rity of workers, etc. also would be continued until a
suitable business model is devel- oped.The existing Rules also need to harmonise
with Labour Laws on this regard.

Employment and skills related concerns

There are a few persistent challenges for e-waste management, ‘including but not
limited to, employment opportunities for youth and women, re-skilling and up-
skilling, establishing sustainable enterprises, green jobs and transitioning from infor-
mal to the informal economy.’ (ILO 2019a: 9.)
No learnings from the informal sector regarding such skills, ability to trade
recovered material in the domestic market, need for recycling infrastructure, and
related projects that can help in building up small scale industrial units, etc. are
not taking place. These are identified as barriers for moving towards formal
economy, and resulting in losses to the formal economy. The Skill India
promoting institu- tions and initiatives (such as NSDC, SWAYAM) can play
trend-setting roles in this scenario. With skill upgradation and job creation
processes, this sector can be very promising for economic growth, fulfilling
requirements of safe environment as well as OSH, and rights of workers.

III: Environment concerns

Environment concerns include a range of issues from design, production to recy-
cling (lifecycle to end-of-life cycle) and resource use (e.g. of carbon, fossils,
water, energy, etc.); reduction of RoHS or totally substituting the use of
hazardous sub- stances; adopting green technology; safe disposal and alternatives to
landfilling; tech- niques to identify and reuse components and materials (e.g. plastics,
glass) as integral part of e-waste management. Such envisioning indicates
potentials for safe environ- ment and human health.

Adopting green technology

Green technology focuses on minimisation of energy, and use of natural
resources, right from the design stage to the recycling stage. In terms of
environment protec- tion, two very important concerns – green technology and
alternatives to landfill
 Moving towards horizons
177
(as this is the only option for disposal of e-waste) – have remained underused in
the existing regulatory framework.

Improvement in product design unheeded

One of most important policy principles of the EPR for e-products is to promote
environment improvements, especially in the area of design of the products, pro-
duction systems, and final disposal. The area of products includes factors such as
product material, design, and expected life. The product design for environment/
sustainable development (DfE/DfD), for instance, reducing or totally substituting
the use of hazardous substances, adopting environment friendly technology, tech-
niques to identify smooth dismantling/recycling, and reuse components and
mate- rials, including plastics and measures to promote the use of recycled plastics
in new products, etc. This is an opportunity to promote improvements, if
included in the regulatory framework; eventually, varied concerns of
entrepreneurship/start-ups/ business, viable technological solutions, and benefits
of capitalist economy could be well elaborated, and their direct linkages could be
established vis-à-vis CE as well as environment and health protection.
The ‘E-Waste: From Toxic to Green initiative’ by Chintan organisation could
serve as a model to help other countries recycle e-waste and fight poverty. This
model of handling e-waste is claimed to be highly replicable due to its low cost,
it can be adopted by other cities, and countries where e-waste involves significant
risk to workers, communities and the environment.8

Standardisation related
Standards have a harmonising effect and can remove trade barriers and enhance
economic growth (CENELEC 2017) and ensure safety of all.The Rules have
man- dated the stakeholders to follow standards for storage, dismantling,
recycling, and transportation; however, standardisation in the entire e-waste
value chain is not conceived and not mentioned in the guidelines of the Rules.
There is a need for developing India specific standards on the following:
inventorisation of e-waste data; recycling and rate of resource recovery;
depolluting standard – limit value for con- centrations of hazardous substances
during EoL treatment processes; and quality of secondary materials and cost.
These standards shall be aligned with global practices and methods, such as,
WEEELabex, E-Stewards, R2 (responsible recycling) and CENELEC – this is an
opportunity for harmonizing effect and removing trade barriers, as promoted by
various stakeholders; they have suggested that these standards could be
developed by the Bureau of Indian Standards in collaboration with CPCB, and in
consulta- tion with NITI Aayog and MoEFCC (Bhaskar 2019; Singhal 2019b).
Recently, a bi-lateral agency, a couple of industry actors, and a research organisation
have started working on standardisation; their consolidated efforts would build a
step forward, encashing the opportunity.
 Moving towards horizons
178
Treatment facilities require to follow the defined standards. It is important to
monitor downstream fractions, which provides a verifiable and accurate basis for
the calculation of the recycling and recovery rates, and it provides a clear insight
into the hazardous waste streams processed by downstream operators, with the
state-of- art-technologies (ibid.).

Recycling and disposal of residues related issues

partially addressed
Recycling capacity has been increasing through increase in number of formal
units since 2011. This is seen as an opportunity for greater resource
recovery/efficiency, building database on recycling processes, etc. Though the
number of authorised recycling units have increased, final disposal of e-waste in
environmentally sound manner is a significant challenge for India, especially in
the context of dominant presence of informal sector for e-waste collection to the
recycling, selling of sec- ondary materials, and limited availability state-of-art
technology and infrastructure for recycling (capacity of recycling), and its
sustainability.
The Rules, 2016 assume that greater e-waste collection would lead to greater
recycling and recovery of resources; in this context, mandating ‘recycling target’
shall be useful. As number of authorised recycling units have increased manifold
under the Rules, opportunity is created for scientific way of recycling, increasing
resource efficiency, reducing adverse impact on human health and environment,
and so on. As against this opportunity, a couple of problems/ challenges are
elaborated for low rate of recycling of e-waste in India.

recycling charge is dependent on multiple factors including but not limited

to the cost of procurement from multiple channels, cost of development of
channels, logistics cost, ecosystem development costs as well as returns from
recycling which could be positive or negative.
(Sinha 2019b: 142)

Such situations mostly results into ‘cherry picking – whereby only the
positive value fractions are recycled – is rife. Negative value fractions, such as
CRT TVs or lamps, are not found attractive, and therefore not accepted by many
recyclers,’ (Sinha 2019b: 142).

1. Material composition of electronics is changing with technological advances,

over time, resulting into lesser amount of recovery and intrinsic value of
recov- ered materials after recycling of e-products/e-waste, thus affecting
economics of recycling.

Recyclers and producers agree that monitoring and control are essential.
Recyclers want monitoring to ensure more producers are financing formal
recycling, and there is a crackdown on informal recycling; producers want
 Moving towards horizons
179
monitoring to ensure recyclers meet standards and are not engaged in paper
trading.
(ibid: 143)

2. Recycling facility cannot be generalized, as composition of every e-product

is different from the other. Many Indian recycling units have witnessed
failure, as they started recycling unit with latest technology and huge
investment; as against that, the e-waste flow and economics of recovered
material was skewed.
3. ‘Employing effective recycling technologies for e-waste may require significant
upfront capital expenditures, which may not be justified for private entities
in the absence of certainty around sourcing of enough quantities of e-waste.
Also, these markets suffer from information barriers.’ (Turaga 2019: 130.)
For example, learning from the informal sector is not taking place, low
awareness and lack of reliable information affect functioning of recycling
activities.
4. Some critical aspects of recycling/micro-management of recycling to be
addressed, such as, optimising recovery and product specific method for
opti- mum recovery; infrastructure and technology required for product
specific dismantling/recycling and capital required for a start-up;
sustainability of a dis- mantling/recycling unit based on quality and quantum
of e-waste received, resources recovered, and selling of recovered/secondary
material, and so on.

While comparing the WEEE Directive and the Rules, 2016, Kopacek (2019)
has articulated two major challenges for treating e-waste – first, rapid
technological advances (including 3D printing) make it necessary to keep up with
the fast progress and develop constantly new recycling processes. Second, more
and more chemical processes may take over because the e-products become a
more and more com- plex mix of materials.These points require proper guidelines,
suitable infrastructure, future planning and readiness to bring about necessary
changes in different ways of e-waste management.

IV: Recycling culture/recycling society

The recycling culture is a civil society centric concept and a requirement, beyond
the regulatory framework, wherein all the stakeholders remain the same/not dis-
tinctly categorised. Role of awareness in enhancement of e-waste collection,
recy- cling, and resource recovery has been well established. Realisation of the
6Rs is an opportunity that can change the existing scenario of e-waste. Academic
courses started on SWAYAM and upscaling through many more educational
institutions engaging in academic courses, research, and activities would be
highly apprecia- tive effort towards realising this concept among the audience,
especially students/ youngsters who believed to be in large number as users of e-
products.
The present vicious cycle of ‘Consume–Collect–Recover–Dispose’ is
considered as a model in practice.This is found to be inadequate based on the
 Moving towards horizons
180
argument that it
 Moving towards horizons
181
results in unbridled accumulation of e-waste in the environment. As awareness
and knowledge on the subject tends to determine their recycling behaviour
(Malhotra 2020), ‘recycling culture’ requires deeper thinking including role of
different social actors, and how to mainstream the concept of recycling society.

The dust is yet to settle

One of the major learnings for e-waste management is that there cannot be one-
fits-to-all approach; neither within a nation nor any comparison between nations.
Three most common concerns about e-waste – transboundary movements, domi-
nant presence of informal sector and small portion of e-waste being collected and
recycled, and need for legislation or regulatory framework in every country have
been stressed upon. Ghana reported high levels of imported e-waste, and severe
impacts of e-waste recycling by the informal sector on human health a decade
ago. Now,

Technical Guidelines on Environmentally Sound E-Waste Management for Collectors,

Collection Centers, Transporters, Treatment Facilities, and Final Disposal have
been developed and are being enforced. In Nigeria, the EPR took off with
for- mation of the E-waste Producer Responsibility Organization of Nigeria
(EPRON), a non-profit organization set up by electrical and electronic
producers.
(Forti et al. 2020: 69)

Once, Agbogbloshie in Ghana was considered to be an e-waste dumpsite;

now, ‘it can be described as well-organized scrapyard,’ (ibid.). Ghana, Nigeria,
and Kenya in Africa are still the countries where informal sector is still dominant
in the entire trade value chain. Guiyu in China once was known as an e-waste
dumpsite; now it is a hub in the global e-waste trade. A vast complex of large
industrial hangars, rooms, and multi-storied houses, each filled to the brim with
e-waste.The workers are mechanically disassembling with simple tools and
wearing basic protective gear. Necessary infrastructure and market linkages are
organised in Guiyu (Mujezinovic 2019). It is expected that India, too, will evolve
on the counts of market access, Eco-park development, formal-informal
partnership for dealing with e-waste, and creating level playing fields for
different actors.
Key learnings of EU countries, especially enforcement of regulations; several
policy considerations including futuristic estimation about e-waste generation
and treatment related processes to be undertaken; smart city concept to be
operational- ized from environment (toxic free environment) and sustainability
(zero waste pol- icy) perspective; driving the transition through research,
innovation, and digitisation; sustainable finance – taxonomy, corporate
governance framework; developing EU green bond standards; and so on.
Referring to India-EU Resource Efficiency and Circular Economy Partnership,
declared in July 2020, operationalising such partner- ship is certainly an
opportunity for e-waste management in India; incorporating of
 Moving towards horizons
182
human and social costs in the RE, CE enhancing model would turn the opportu-
nity into long term benefits for India.

Continuing enforcement of the Rules and innovative

initiatives
The regulation driven business initiatives have started showing results as indicative
of enforcement of the Rules, such as, increase in number of authorised PROs and
development of their ecosystems as well as formalization of informal waste
collec- tion, increase in number of dismantlers/recyclers, resulting into recycling
capac- ity, compliance by the bulk consumers, discussions on etc. These
initiatives show a shift in the discourse of e-waste management, i.e. from WHY
e-waste management to HOW e-waste management. Newer topics of discussions
have begun, such as, resource efficiency and circular economy, newer
technology, methods of recovery are tried out by the GoI at laboratory level,
infrastructure have to be set up accord- ingly on industrial scale, and
standardisation across value chain.The RoHS has been largely complied by the
producers. Such beginning for e-waste management is encouraging.
Challenges have been identified, such as, waste aggregation is not discussed
much despite being an important concern, cherry picking of e-waste for
recycling, paper trading and leakage of e-waste make several players feel ‘lack of
level playing field;’ document submission related compliance is low and how to
increase it through regular monitoring; cost of compliance for every producer and
every product needs to be worked out; tie up of bulk consumers, producers, and
PROs with govern- ment run platform like MSTC and streamlining process of
metal scrap auctioning; need for sectoral ‘should cost analysis’ including
procurement, logistics, recycling and recovery, and administrative, etc. need for
initiating processes of dialogues and networking among different stakeholders,
especially the recyclers and PROs rather increasing competitive and conflicting
areas of interests; need for fostering infor- mal-formal partnerships; and so on.
Regarding recycling/treatment of e-waste, stan- dardisation of depollution
practices is required; along with collection of e-waste, resource recovery targets
need to be specified; how to finance recycling infrastruc- ture and technology,
and creating market access for sale of secondary materials are challenges that are
to be addressed.
Areas for further action and research have been identified: several micro stud-
ies are required on different components of e-waste management. For example,
to quantify the impact of e-waste (exposure to metals, small particulate matter,
POPs, and PAHs); environmental risk assessment; economics and sustainability
of small/ medium scale processing for current informal recyclers; upstream and
downstream flows of e-waste and secondary materials; ‘voluntary consensus
sustainability stan- dard’; and so on.
Chaurvedi and Gaurav (2016) have suggested a few initiatives, such as the
State– civic–business alliances – ULB or SPCB – could play lead roles in such
formation; strengthening links between ULBs and SPCB in every state;‘Hub and
Spoke model’ for infrastructure and viable recycling businesses. Other ideas for
action include
 Moving towards horizons
183
creation of a knowledgebase, developing a strategy for raw materials and second-
ary resource, market for sale of recovered/secondary material and linkages to be
developed, capacity building of regulators, debate and engagement with
informality, deepening engagement of SPCB with OEMs and formal recyclers,
cross-ministry collaboration for developing effective policies and programme on
e-waste.
The Rules, 2016 are yet to be studied from different perspectives in depth, for
example,‘environmental justice,’‘recycling culture’ or ‘recycling society,’‘sustainabil-
ity’ and ‘voluntary sustainability standards,’ and ‘circular economy with human
ad social costs.’ When e-waste regulations would be studied from these
perspectives, they would be able to articulate opportunities and challenges.
The environment justice perspective draws attention on uneven distribution of
economic benefits and environmental health costs. The ‘producer’ focused policy
(EPR) encourages the private companies to take profit-oriented strategies and
hence leads to involvement of the formal recycling companies. This equation is
the most suitable to the concept of CE, and intent of safe environment and human
health but does not enter policy debates showcasing the existing inequality, that
is, environmental health hazards faced by socially and economically powerless
workers and local residents or its potential root cause. This set of stakeholders is
yet to be engaged with and to be recognised in the policy-making in India.

Notes
1 Karo Sambhav Pvt. Ltd., an authorised PRO has mentioned their focus areas:
inclusion, fairness, convergence & scalability, traceability, transparency, and
auditability as part of e-waste management. To ensure transparency and auditability,
Karo has developed tech- platform, which is also used to create a database.
2 Issuance of certificates of recycling for materials that have not even been sent to
recycling by the recyclers to the concerned part (PRO/producer). Aggregators of e-
waste have shared that some PROs have offered to pay them 5% GST and 10%
commission for making an invoice without physical transaction and collection of e-
waste.
3 E-waste which has been collected and recycled is allocated to multiple brands leading
to a situation where a collection/recycling of 100 tons is shown as allocated to five
different brands with targets of 100 tons each.
4 This portion was discussed in the conference on ‘A circular economy in E-waste for
an Atmanirbhar Bharat conference’ on 14 October 2020 as part of celebration of
‘International E-waste Day’ organized by Karo Sambhav Pvt. Ltd. Recording of the
con- ference is available at https://www.youtube.com/watch?v=MKb0aETylYE&t=1s
5 In a personal interview with Shri Devang Thakar, engineer, in charge of e-waste
manage- ment, Gujarat State Pollution Control Board (GSPCB), dated 10 April 2021.
6 Based on the author’s personal experience during 2018. Municipal Commissioners of
Bikaner and Nagpur cities shared this problem. The then District Collector of
Kachchh district insisted for the Executive Order for disposal of e-waste through
ULBs.
7 A hub and spoke model for recycling (for solid waste) – a hub is established to
shoulder the financial burden of operating a recycling centre. The spokes, which are
typically located in very rural areas, provide the hubs with recyclable materials. The
hubs process the material and benefit from capturing the value of the material that
they market. The spokes don’t benefit from the sale of the recyclables, and they are not
 Moving towards horizons
184
liable for any of the
 Moving towards horizons
185
expenses that come with operating the facility (https://www.waste360.com/business/
benefits-hub-and-spoke-recycling-system accessed on 2 August 2020). For e-waste
recy- cling, CPCB or MeitY can provide strategic orientation for development of
adequate and appropriate infrastructure.
8 Accessed from https://unfccc.int/climate-action/momentum-for-change/lighthouse-
activities/e-waste-from-toxic-to-green on 26 August 2020.
Moving towards horizons
186