New E-Waste Disposal Requirements Under Review for India
July 25, 2022 | The Toy Association submitted comments in response to a new electronic waste (e-waste) proposal issued by the India Ministry of Environment, Forest, and Climate Change (MoEFCC), which could impact toy manufacturers and producers of electronic toys. The scope of the requirements includes electronic toys (electric cars and trains and hand-held e-toys (i.e. gaming consoles)) for the first time.
The new rules would amend the country’s current e-waste disposal framework to require manufacturers of electrical and electronic equipment (EEE), producers who market these goods, and recyclers and refurbishers of e-waste to handle the collection, dismantling, and disposal of e-waste. It would no longer allow the use of authorized dismantlers and producer responsibility organizations (PROs) to manage disposal.
In its comments, The Toy Association requested a longer transition period to facilitate compliance and efficiency, noting that the aggressive timeline the country seeks to implement the new framework would not be workable for the industry.
Additionally, under the current framework, producers are required to take back a percentage of their products at the end-of-life stage for disposal. The new rules seek to increase the Extended Producer Responsibility (EPR) recycling targets producers must achieve. While new percentages have been mapped out for producers with a set number of years of sales operations less than the average life of their products, The Toy Association has asked MoEFCC to provide similar targets for other companies to ensure compliance.
The Association has also urged India to notify its updated EPR regime with the World Trade Organization (WTO) Committee on Technical Barriers to Trade (WTO TBT), as is required under TBT rules. Doing so will also help raise awareness among impacted parties prior to implementation.
“With many of our members taking active steps to be more sustainable and environmentally friendly, The Toy Association welcomes the opportunity to provide critical feedback to the India government for such end-of-life recycling programs,” said Al Kaufman, senior vice president of technical affairs at The Toy Association. “This is yet another opportunity to work with governments around the world to help mitigate pollution in a feasible manner and share our industry’s work in helping protect the environment through eco-conscious business practices.”
Additional questions on the new requirements may be directed to The Toy Association’s Alan Kaufman.