The environment ministry has published draft rules to regulate the management of information and communication technology (ICT) waste. Although an important step towards sustainable development, the E-Waste (Management and Handling) Rules 2010, likely to come into force next year, fall short on some key parameters.
First, the rules fail to integrate the informal sector in the collection, segregation and dismantling of e-waste. While allowing the recycling of e-waste through state-approved mechanisms, they propose penalties for unregistered recyclers. This isn’t helpful, as India’s large informal sector can play a major role in this effort.
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Second, while the new rules seem to declare the import of electronic goods under charity as illegal—a welcome regulation given the huge volume of illegal import from the West—the ban does not take into account imports on the pretext of metal scrap. Nor does it restrict the import of electronic goods for recycling, which goes against the international Basel Convention, to which India is a signatory.
Third, the rules don’t seem to address the issue of historic waste and disposal mechanisms required to deal with them.
The rules have been framed in the light of the Environment (Protection) Act, 1986, which was otherwise silent on impact of ICTs on environment and climate change. They have also adopted the global framework of e-waste management by incorporating extended producer responsibility (EPR) and reduction of hazardous substance (RoHS) compliance in electronic manufacturing.
The highlight of the policy document is a detailed list of the responsibilities of various stakeholders involved in the supply chain of e-waste management—including consumers, producers, distributers, refurbishers, collection centres, dismantlers and recyclers.
The rules have, for the very first time, identified and categorised e-waste by distinguishing between IT and telecom equipment and consumer electrical and electronics. They have also decentralised authority by vesting enforcement powers in state-level pollution control boards.
The publication of these rules brings forth the larger issue of policy advocacy and thrust on ICTs, environmental sustainability and climate change in India—which has remained sidelined despite the country’s growing status as an Information Technology power.
While there has been no study to reveal the magnitude of ICTs’ influence on environmental sustainability and climate change in India, the biggest concern that has emerged so far is from e-waste.
The Digital Empowerment Foundation (DEF), as a member of the Association for Progressive Communications, conducted a baseline study vis-à-vis mapping of the status of the issues, policies and practices around the themes of ICTs and environmental sustainability, ICTs and climate change, and e-waste in India.
The yet-to-be-released report says that policy advocacy and initiatives at the national level have lately begun to be led by the ministry of environment and forests. There is little consensus on its draft e-waste policy—while the paper calls for ICT producers to be mainly responsible for managing e-waste, the producers argue for shared responsibility.
Surprisingly, there are no such major policy advocacy and departmental measures from the ministry of communication and information technology. Initial efforts have been made by the department of science and technology; but advocacy and initiatives at state government-level are marginal, with the exception of Karnataka, Tamil Nadu and Delhi.
For instance, the Municipal Corporation of Delhi has brought out enforcement mechanisms for effective disposal of e-waste; in Karnataka, policy advocates such as the Karnataka State Pollution Control Board have argued that the absence of a specific legislation for regulating the management of e-waste restricts action against violators.
E-waste advocacy and programmes set up by industry bodies are not necessarily in line with the larger national focus. The industry initiatives are self-ideated and guided by economics. These initiatives are more towards micro-programmes rolled out by select industry agencies, that too without any formal policy or organizational mandate and documents. The role of civil society and other stakeholders is nascent. Advocacy has been seen in pockets, such as Karnataka, and led by bodies such as E-Parisaraa and ATREE (Ashoka Trust for Research in Ecology and the Environment), which advocate end-to-end regulations for every process in e-waste management.
The crux of the issue remains lack of awareness and organised approach among stakeholders. That is the biggest conclusion of the Digital Empowerment Foundation study, which is called “Mapping policy advocacy on ICTs, environment sustainability & climate change in India”.
It will be released in July, in the presence of 30 stakeholders from the industry, government, civil society and individual experts who were consulted for the study.
Meanwhile, the DEF has launched another initiative called Green Prakriya, which is meant to do the full cycle exercise of advocacy, research, knowledge gathering and selective interventions in this nascent area of information and communication technologies and its implications for environmental sustainability vis-à-vis e-waste.
You can also join us through http://greenp.engo.in/.
Osama Manzar is director of Digital Empowerment Foundation and curator, mBillionth Award. He is also member of working group for Internet governance at ministry of IT.
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