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6 minutes, 14 minutes, 19 minutesthe approximate time taken by a mobile
phone, a PC/laptop, and a TV/refrigerator, respectively, to turn obsolete, get
discarded, thereby adding to the phenomenally growing base of e-waste. Discarded
electronic waste is the fastest growing waste stream in the world. Not
surprising, considering that the electronic industry is the fastest growing
manufacturing industry in the world.
The biggest contributor to e-waste is considered to be the IT sector, with
over 30% share in the total e-waste generated. While its common knowledge that
e-waste is a substantial hazard for health and environment, what is lesser known
is the fact that communities most affected by e-waste are not the creators of
this waste. Developed countries export about 80% of their e-waste to developing
nations, where e-waste management is still a highly unorganized sector. E-waste
contains many toxics, such as heavy metals, including lead, mercury, cadmium,
etc.
Indian Scenario
India generated some 3.3 lakh tonnes of e-waste in 2007. This figure is
expected to touch 4.7 lakh tonnes by the year 2011. Toxic Links, a Delhi-based
NGO estimates this to be worth a staggering $1.5 bn. With the massive sale and
proliferation of low cost mobile handsets, at the rate of some 7 mn per month,
it is easy to see that the booming economy is going to lead to some serious
problems and unless some urgent steps are taken, this could cascade into a
catastrophe.

Although the governments world over have woken up and acted upon the issue,
the Indian government is yet to come up with a concrete policy on the matter.
E-waste in India is indirectly and remotely covered by laws like Hazardous
Wastes (Management and Handling) Rules, 1989/2000/2003, DGFT Exim Policies, etc.
However, there has been a start. Some states like Karnataka have a loosely
knit policy in place and the draft for policy and guidelines for e-waste
(management and handling rules), is finally under consideration. The Ministry of
Environment and Forests (MoEF) finally woke up to the issue in 2003 (only Delhi
was taken into consideration then), and in April 2008 CPCB posted the guidelines
for safe management and disposal of e-waste.
The guidelines for e-waste have been formed by the WEEE (Waste from Electric
and Electronic Equipment) Task- Force, comprising Ministry of Environment and
Forests, Central Pollution Control Board (CPCB), Manufacturers Association for
Information Technology (MAIT), Ministry of IT, industry associations and various
NGOs like Sahaas, Toxic Link, etc. These guidelines have been the stepping-stone
for formulating a regulation policy for e-waste, the need for which is
unanimously voiced by producers, as well as the consumers. The National Workshop
on Awareness and Consultation on Guidelines for Environmentally Sound
Management of e-Waste, organized by MAIT on June 17, 2008 saw the first public
unveiling of the regulation text.
This is one of those rare incidents when the government has agreed to an open
discussion of an upcoming regulation. This workshop was only the first step of
this process to interact with the public (recyclers, producers, and consumers)
and inculcate their concerns within the regulation. According to Vinnie Mehta,
executive director, MAIT, the workshop is an effort toward an enabling
framework, which is more than just a policy.
He recognizes the problem with the implementation part because of the huge
unorganized sector participation in the recycling issue. However, he also
acknowledges the willingness of the industry for a legislative structure.
Although the industry stakeholders are keen to have a separate regulation,
the government hasnt shown much interest in the same. Their plan is to include
the e-waste rules under the already existing Hazardous Wastes (management and
handling) Rules or HWR. Dr Lakshmi Raghupathy, former director, MoEf, in her
speech at the workshop, clearly displayed the reluctance of the government to
have a separate legislation on the matter.
When approached, the CPCB officials gave a slightly different picture. The
e-waste act, according to them, is currently coming up under the HWR, but will
evolve into a separate law over the coming two years.
The regulation was supposed to be in place by September this year, but the
interaction with the industry has resulted in a delay. Nevertheless, the
regulations are expected to come up before one years time. That means that by
the same time next year, we can expect penalties for people who arent disposing
their e-waste responsibly.
It is yet to be decided whether e-waste is going to be a separate regulation
or not, but what is confirmed is the opinion that for effective implementation
of the law, the informal/unorganized sector needs to be incorporated within the
formal recycling process. As Vinnie Mehta, expressing strong concern over the
issue reflected, the informal sector cannot and should not be displaced. He
strongly advocates the inclusion of the unorganized sector at least up to the
collection and segregation level, citing the uniquely Indian model where the
concept of kabbadiwallahs ensures door-to-door collection.
In spite of the complications of the collection and recycling process, the
act is a straightforward concept. Simply put, the act is going to state that
anyone who is producing e-waste is to be accountable for its recycling. The two
important constituents of the regulation are EPR (extended producer
responsibility) and RoHS (restriction of hazardous substances). While the first
seeks to make the producer accountable for his products, the latter emphasizes
upon the minimal quantity of toxics in the products.
Registration to recyclers shall also be provided under the act. The State
Pollution Control Boards shall grant the licenses following the standard
guidelines. Although recycling, especially of consumer equipments (TVs and
refrigerators), is not a profitable business, Mehta sees great potential in the
recycling business. In fact, he already has a list of two-dozen recyclers
willing to start operations in India.
The penalties for handling your e-waste irresponsibly will be on the same
lines as specified under the HWR. They, however, can come out to be more severe.
CPCB however, expects this law to work smoothly in the initial stages. This is
because the Indian corporates have so far responded positively to the e-waste
issue and giants like Wipro and Videocon already undertake complete recycling of
their products.
Industrys Response
According to the MAIT-GTZ e-Waste Assessment Study, 2007, 94% of the
organizations studied did not have any policy on disposal of obsolete products.
Out of the total e-waste generated only about 40% finds its way into the
recycling stream. The rest remains in storehouses, etc, due to the inefficient
collection system. Although the picture doesnt look too promising, Vinnie Mehta
is hopeful. He sees a general willingness, even initiative, on the industrys
part to come forward to tackle this issue.

HP for example, according to P Ravindranath, director, public affairs, HP
already complies with RoHS norms. Moreover, it has actively been recycling its
products since 2003, through its flagship-recycling program, Planet Partners
Program (PPP). Although, the PPP currently applies only to enterprise customers,
Ravidranath hopes to offer a take-back program for consumers soon. Taking the
lead, HP has also begun a reuse approach, where the products recycled are used
in new HP products. Moreover, HP also recycles all of its personal productivity
equipment.
While there have been examples set by giants like HP and Wipro, a major part
of the industry still has some apprehensions about the recycling business. The
collection system and recycling of equipments add up substantially to costs, and
when these costs are passed on to the consumer, the market share and profits are
at risk. The producers also fear losing out to the unorganized sector if the
costs are to be escalated. The challenge of the economics involved in the
process is yet to be addressed.
This spells out the need for regulation. Producers and recyclers both need
the assurance of law to create a viable recycling environment.
Right now the handful of recycling plants in India (one each in Bengaluru and
Chennai, those coming up in Mumbai, Delhi, and Haridwar) are functioning below
capacity as only 22-30% of e-waste is recycled in the organized sector.
However, even if combined together, these plants will not be able to handle the
mammoth amounts of e-waste produced. But at least this policy will ensure that
these plants dont remain underutilized.
Given the current scenario of the e-waste legislation process, many producers
are waking up and getting their acts together. They are signing up with
recyclers at reasonable prices (since even they are looking for work at this
time), for once this policy comes into effect, these contracts will neither be
so cheap nor so easy to obtain. So, the first mover advantage here is clear.
So far, Indian producers have had it easy. Production, transportation, and
delivery costs are what they had to incur as far as the equipment was concerned.
Add to this collection and recycling costs, and it rises substantially. However,
there are ways you can have it a bit easier, if you act at the right time, which
is now.
The first alternative is to approach a registered recycling agency, or a PRO
(producer responsibility organization) immediately. These agencies usually take
care of everything from collection to transportation to recycling. However, make
sure that the agency you approach has a registration certificate either from the
MoEF or from CPCB. CPCB officials clearly say that their job is only to assign
registration as per the guidelines. The economics part shall be left to the
agency and its clients. And if left to the agency that too after the policy is
in force, the skyrocketing of prices are only a natural consequence.
The second alternative might be to start your own recycling plant. However,
as the layoff time and the investment are massive, this option is only for the
select few.
Another option available is to check your products at the production stage
itself. Switch to green products with minimum toxic content, which dont require
an elaborate recycling process. These products can either be dismantled by hand
or with the use of small-scale machinery. Although this might require some
initial investment, you can save up on the recycling costs. Besides, clean
technology is often highly energy-efficient.
However, the biggest challenge in e-waste recycling for the producers is the
tracking and collection of products after their end life. This doesnt only
require huge infrastructure investment but also a lot of database management.
Most of our companies do it in other nations because of the existing laws there.
Considering this fact, the e-waste law shall come as a great relief. Its time
to explain to the world that our country is no dumping ground or landfill.
And in the end, a lesser known fact: the law prohibits any import of e-waste
into India. That is, all e-waste coming in from western nations in the Indian
Territory is not only immoral but also illegal. But we all know it happens, and
is always brushed under the carpet, by giving it the term, misdeclaration.
Why? Because it is given in the name of Donation or Charity (which our laws
allow), but more often than not, it is intended for the dismantling yards. It is
imported under the garb of great benevolence from the West, which our nation is
assumed to be highly in need of. I think all should adhere to the famous quote:
Charity begins at home.
Mehak Chawla
mehakc@cybermedia.co.in
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