According to data, the total e-waste generated in India in 2022 was 1601 kt, and 1723 kt of installed capacity with 569 registered recyclers, but only 527 kt is recordedto be collected and processed, ie., 32%. [6]

Around 70% of the treatment of e-waste is unknown, likely dumped, traded, or recycled in a non-compliant or
non-environmentally sound way. [2] However, primitive harvesting of valuable components such as copper or gold from PCBs and cables happens through open acid baths or burning, such as in Delhi, leaving appalling impacts on the health of the surrounding population and the environment.

New rules in e-waste management, plastic waste management, battery waste management along with relevant amendments to the hazardous waste management rules of 2016 have introduced the concept of Extended Producer Responsibility (EPR) to push the onus of accountability for recycling onto the producers of the various products reaching end – of - life.

With older versions of the rules lacking clarity on the definitions of “end” recycling and no oversight on the recycling certificate generation process, EPR credits often became a paper trading exercise. In part this was encouraged by loopholes in the rules that allowed opportunities for self-policing by the vested interest groups of producers, producer responsibility organizations (PROs) and recyclers.

Suitable amendments or newer notifications of all these rules have placed the Central Pollution Control Board (CPCB) at the crux of the process flow, with online portals controlled by the nodal agency responsible for vetting capacity and validating transfer of any recycling credits. This puts the CPCB at the heart of the authorization process for recycling, significantly increasing their footprint beyond drafting of legislation and issuing of guidelines which was their preferred ambit in the past.

Authority of the SPCBs has been restricted to the issuing of consents and disseminating knowledge with dual layering of the approval process to the portal ensuring that the central government retains ultimate authority on the validity of the players in the ecosystem. Additionally, audits by the CPCB as well as potential technology tie backs to the GST portal of both recyclers and producers will introduce significant transparency to the process and make it difficult for bad actors to engage in the dubious practices common in the past.

It is apparent that the government is taking the migration to a circular economy seriously. This is particularly significant as oversight of the prevailing circularity in key commodities and critical materials is likely to have serious implications on our ability to be self reliant in many key areas such as electric mobility and defence.

However, change is a slow process and inefficient interfaces across the multitude of stakeholder bodies and technical difficulties in the implementation of migration to digitalization (of for e.g. the portals which will be the heart of the transactional process for credits) means step changes in results are hard to see from the ground.It is interesting to note that along with the specific and more clear rules being formulated around the critical waste (e-waste, plastic, battery and hazardous) streams of interest, the government also seems to have taken note of the mushrooming of activities under the banner of ESG. Specifically for activities taken up under the environmental impact aspect of ESG.

Typically, the quantification, reporting, veracity and validity of actions/projects and the documentation of actual environmental benefits accrued, typically remained in the hands of unregulated consultants and often self-certified expert bodies. This often resulted in somewhat glorified reporting by participatory actors with sometimes little actual environmental benefit ever being realized. Here again the government has framed new rules called the Green Credit Rules 2023.