E-Waste (Management) Rules (2022): Assessing India's Extended Producer Responsibility Framework - IMPRI Impact And Policy Research Institute

Policy Update
Sudeepti Joshi

Background

India’s approach to e-waste has shifted over time, from simply regulating disposal to making producers themselves responsible for what happens to their products after use. The E-Waste (Management) Rules, 2016, notified by the Ministry of Environment, Forest and Climate Change (MoEFCC), built this Extended Producer Responsibility (EPR) framework, requiring producers to ensure collection and environmentally sound management of e-waste from their products. It covered 21 categories of Electrical and Electronic Equipment (EEE).

But electronic consumption grew faster than the system built to manage its waste. As volumes and product types multiplied, how well the EPR framework worked depended less on the obligations placed on paper and more on how collection, recycling and reporting were actually tracked.

The 2016 Rules provided an important starting point, but the scale of the problem was changing rapidly. CPCB data shows that e-waste generation from the 21 notified EEE categories more than doubled, rising from 7,08,445 tonnes in FY 2017–18 to 16,01,155.36 tonnes in FY 2021–22, an increase of around 126% (Ministry of Environment, Forest and Climate Change, 2023). This raised questions about whether the 2016 framework was equipped to keep pace with the growing volume of e-waste.

MoEFCC responded by notifying the E-Waste (Management) Rules, 2022 on November 2, 2022, replacing the 2016 Rules, with the new framework taking effect from April 1, 2023 (Ministry of Environment, Forest and Climate Change, 2022c). The core EPR principle stayed, but the machinery around it changed: a more formal system for tracking producer obligations, covering manufacturers, producers, refurbishers, dismantlers and recyclers under one regulatory umbrella.

The bigger shift was toward measurable outcomes. Producers are assigned specific EPR targets, and recycling is tied to EPR certificates issued through registered recyclers (Ministry of Environment, Forest and Climate Change, 2022c). That raises the real question this piece is trying to answer: does a tighter regulatory structure actually produce more formal recycling, or does it just produce more paperwork?

Functioning

The 2022 Rules run on a centralised online system for managing and monitoring EPR compliance. Manufacturers, producers, refurbishers and recyclers must register on the CPCB’s portal, and cannot legally operate or deal with unregistered entities.

One change from 2016 stands out: “Authorization” was replaced by online “Registration.” The idea was to make compliance simpler while building a single, searchable database of who’s actually operating in the system.

EPR compliance runs through the same portal. Producers and Producer Responsibility Organisations (PROs) get targets tied to the production data they submit for EEE listed in Schedule-I, so a producer’s obligation scales with what it actually puts into the market, rather than being a flat requirement applied to everyone equally.

Recyclers connect back to producers through EPR certificates, generated and uploaded on the same portal, then exchanged to help producers meet their targets. This formally links recycling activity with producer compliance, while allowing CPCB to record and monitor EPR certificate transactions through the portal.

CPCB, meanwhile, estimates national e-waste generation by combining producers’ sales data with the average lifespan of each notified EEE category. That is the basis on which producer-level targets get set in the first place.

Performance

The numbers CPCB has published show generation rising: 13,46,496.31 tonnes in FY 2020–21, up to 16,01,155.36 tonnes in FY 2021–22, based on the 21 notified categories (Ministry of Environment, Forest and Climate Change, 2023a). CPCB itself has called this “not substantial as compared to other major economies of the world” (Ministry of Environment, Forest and Climate Change, 2023a), which is worth keeping in mind before drawing international comparisons.

The rise in reported generation within a single year points to a growing waste burden, even if India’s reported volume remains lower than that of some major economies. This matters because the formal collection and recycling system must expand alongside this increase; otherwise, a larger share of discarded equipment could continue to move through informal or unauthorised channels

The formal recycling side has grown too. By 2022, CPCB had registered or authorised 472 dismantlers and recyclers across 22 states, with a combined capacity of 14,26,685.22 metric tonnes a year (Ministry of Environment, Forest and Climate Change, 2022b).

The increase in formal processing capacity suggests that recycling infrastructure has expanded, but capacity alone does not show how much e-waste is actually reaching authorised facilities.

On the producer side, 2,061 producers held EPR authorisation or registration nationwide (Ministry of Environment, Forest and Climate Change, 2022b). The growing number of registered producers indicates greater formalisation of the sector, at least on paper. However, registration alone does not establish actual compliance with EPR targets or confirm that e-waste is reaching authorised recyclers.

The number of producers under the EPR framework increased substantially between 2021 and 2023, indicating wider formal participation. However, registration itself does not establish that producers fulfilled their EPR obligations, making compliance with assigned targets the more important measure of effectiveness.

Impact

Judging the EPR framework’s real impact is hard, mainly because so much of India’s e-waste still flows through the informal sector. The government has admitted as much: in a written Parliament reply, it stated “no authentic estimate is available so far regarding the proportion of e-waste being handled by the informal sector” (Ministry of Environment, Forest and Climate Change, 2022a).

Formal collection has climbed year on year: 1,64,663 tonnes in FY 2018–19, 2,24,041 tonnes in FY 2019–20, 3,54,291.22 tonnes in FY 2020–21 (Ministry of Environment, Forest and Climate Change, 2022a). Against that, the Technology Development Board (2023) put national generation at 3.2 million tonnes for FY 2019–20 alone, a figure that likely reflects a wider scope of e-waste than CPCB’s 21 notified categories, so the two aren’t strictly comparable(Ministry of Environment, Forest and Climate Change, 2022a; Technology Development Board, 2023). Given the difference in how the two estimates are defined, the size of the collection gap is difficult to establish precisely. A comparable dataset covering the same categories would provide a stronger basis for assessing the extent of the gap.

TDB and Ministry data put the share of e-waste going through formal recycling at around 20% (Technology Development Board, 2023). Roughly four out of five tonnes, in other words, never enter the regulated system. The government’s own stated goal for the 2022 Rules, to “channelize the informal sector to formal sector” (Ministry of Environment, Forest and Climate Change, 2024), makes clear this isn’t a side issue. It’s the central problem the framework has to solve.

Formal capacity has expanded fast: 14,26,685.22 MT/year in 2023 to 22,08,918.064 MT/year across 322 recyclers by February 2025, plus 72 registered refurbishers adding another 92,042.18 MT/year (Ministry of Environment, Forest and Climate Change, 2025a). (The 472 figure in Performance covers dismantlers and recyclers together; the 322 here appears to be recyclers alone. Worth confirming against the source so the two numbers don’t read as conflicting.) More capacity hasn’t necessarily meant more e-waste actually flowing through it.

This expansion in capacity has largely taken place without dedicated government funding under the 2022 Rules. A 2025 Rajya Sabha reply confirmed there’s no provision in the 2022 Rules for funding the construction or upkeep of e-waste processing units (Ministry of Environment, Forest and Climate Change, 2025b). Private investment and the EPR mechanism itself are doing the work.

The government has at least recognised that informal recyclers need a way in, not just a wall around them. A MeitY-led initiative, “Informal Sector Capacity Building Upgradation,” is meant to help upgrade informal recycling clusters through the MSME scheme (Ministry of Environment, Forest and Climate Change, 2025c). Building formal capacity is one thing. Pulling the existing informal network into is another, and this is the government’s first real attempt at the latter.

Emerging Issues

Informal Sector Enforcement

Informal and unauthorised e-waste processing remains a significant enforcement challenge. CPCB directed State Pollution Control Boards on September 6, 2022, under the Water Act, 1974 and Air Act, 1981, to check unauthorised dismantling and recycling and verify who was actually licensed. The need for such directions highlights the continuing difficulty of bringing informal activity within the formal regulatory framework.

Registration Compliance

Registration compliance has also required continued regulatory intervention. More than a year after the 2022 Rules came into force, CPCB issued a further direction on January 30, 2024, requiring producers, manufacturers, recyclers and refurbishers to register on the Online E-Waste EPR Portal (Ministry of Environment, Forest and Climate Change, 2025a). This suggests that registration requirements were not being uniformly met even after the new framework had taken effect.

EPR Certificate Compliance

The EPR certificate system has faced similar compliance issues. CPCB’s February 14, 2024 direction specifically called on recyclers to generate EPR Certificates for producers’ FY 2023–24 obligations (Ministry of Environment, Forest and Climate Change, 2025a). This indicates that certificate generation also required active regulatory follow-up.

Monitoring and Enforcement

CPCB can inspect and audit Producers, Importers and Brand Owners as well as plastic and e-waste processors, and can direct State Boards to take action against violators. The effectiveness of these powers, however, depends on the frequency of inspections and the timely follow-up of violations.

Way Forward

Assessing Compliance Burden

Registration was supposed to be simpler than the old Authorization system. It’s worth actually checking whether that’s true in practice, whether the compliance burden on manufacturers, producers, refurbishers and recyclers has genuinely dropped, and whether oversight has held up alongside the simplification.

Strengthening Monitoring and Enforcement

CPCB’s repeated interventions in September 2022, January 2024 and February 2024, on informal activity, registration, and certificates respectively, tell their own story: an online portal isn’t self-enforcing. Consistent monitoring, and firmer enforcement where needed, will matter more than any further redesign of the system.

Bringing the Informal Sector into the Formal Chain

The informal sector needs real attention, not just acknowledgment. The government has admitted it doesn’t know how much e-waste the informal sector handles. Fixing that data gap would be a reasonable first step toward figuring out how to bring informal operators into the formal chain rather than just working around them.

Linking Capacity with Actual Recycling

Rising capacity also needs to be matched by rising use. More registered recyclers and more processing capacity mean little if the waste doesn’t actually reach them. Better tracking from collection through to final recycling, using the EPR portal itself, could help pinpoint exactly where e-waste is slipping out of the formal system.

Selected References and Important Links

Ministry of Environment, Forest and Climate Change. (2022a, March 31). E-WASTE management in informal sector [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/Pressreleaseshare.aspx?PRID=1812032

Ministry of Environment, Forest and Climate Change. (2022b, July 18). Extended Producer Responsibility [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=1842627

Ministry of Environment, Forest and Climate Change. (2022c, December 8). Re-cycling of e-waste [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=1881761&reg=48&lang=2

Ministry of Environment, Forest and Climate Change. (2023a, July 20). e-Waste Management [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=1941054

Ministry of Environment, Forest and Climate Change. (2023b, December 14). E-Waste (Management) Rules, 2022 in force since 1st April, 2023 to manage e-waste in an environmentally sound manner with an improved Extended Producer Responsibility (EPR) regime in place for e-waste recycling [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=1986201

Ministry of Environment, Forest and Climate Change. (2024, December 19). Recycling of e-waste. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleseDetailm.aspx?PRID=2086134

Ministry of Environment, Forest and Climate Change. (2025a, February 13). Management of growing e-waste in the country. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2102701&reg=48&lang=2

Ministry of Environment, Forest and Climate Change. (2025b, July 24). E-waste processing management. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2147876&reg=48&lang=2

Ministry of Environment, Forest and Climate Change. (2025c, August 11). Electronic waste management. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleseDetailm.aspx?PRID=2155124

Ministry of Environment, Forest and Climate Change. (2026, March 23). Circular economy framework and extended producer responsibility. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleasePage.aspx?PRID=2244104&reg=3&lang=1

Technology Development Board. (2023, September 6). TDB-DST supports M/s Eco Recycling Limited’s innovative “Recycling on Wheels Smart ER” to address India’s e-waste challenge [Press release]. Press Information Bureau, Government of India. https://www.pib.gov.in/PressReleaseIframePage.aspx?PRID=1955127&reg=48&lang=2

About The Contributor

Sudeepti Joshi is an undergraduate student pursuing a B.A. (Hons.) in Economics at Dyal Singh College, University of Delhi. Her interests lie at the intersection of economics, public policy and development.

Acknowledgements

The author extends sincere gratitude to Khushi, Madhuritha D and the IMPRI team for their expert guidance and constructive feedback throughout the process.

Disclaimer

This article is intended for academic purposes only. The views expressed are those of the author and do not necessarily reflect the views of IMPRI or any government institution.