E-waste Rules from Indian Government

The Indian Ministry of Environment & Forests has announced that "E-waste Management and Handling Rules 2011" (S.O. 1035(E), Government of India Press, 12/05/2011) will come into effect 1 May 2012. These are useful rules for reducing the amount of toxic material from electronic devices polluting the environment, but the Indian government needs an on-line system to make the rules workable.

The rules apply to producers , bulk consumers and recycling centres for electrical and electronic equipment (batteries, small enterprises and radioactive waste are excluded). Under these rules producers are responsible for recycling of e-waste at the "end of life" of their products, including the cost of collection and recycling centres.

The rules are contained in a 23 page, 1.3Mb PDF file (also available in Hindi). Unfortunately the English version of the rules appears to be a poorly scanned facsimile of a paper copy. This will make it difficult for organizations to find the rules and prepare internal documentation in order to comply with them.

Organizations covered by these rules are required to register with their state pollution control board or Pollution Control Committee, keep records of e-waste handling and file annual returns with the government. Unfortunately the forms provided in the rules are poor quality facsimilies of paper copies. It appears that the Government of India's intention is that organizations will fill these forms in on paper and send them through the post. This will create a large administrative burden for the companies and government agencies concerned. It will also create an environmental burden due to the materials and energy consumed in the process. The paper based records produced will be of little value in monitoring e-waste.

I suggest the Government of India produce a central web based registration system for producers to register and enter their annual returns. Responsible agencies can then also register so they can monitor the activities in their region. The e-forms used could be design to be filled in using a smart phone or other low cost low bandwidth device, so minimal burden will be imposed on industry. The system could be self funding by including advertisements on the web site.