Axe that floor price and adapt to market reality

EEE producers argue that this raises compliance costs by up to four times compared to the pre-2024 norms, which did not mandate a floor price. Also, they argue, the policy will be environmentally ineffective, as it turns the ‘polluter pays’ principle into a blunt mechanism.

A March 2024 amendment to India’s e-waste rules introduced a floor price as part of the system of Extended Producer Responsibility (EPR) certificates. It allows the Central Pollution Control Board (CPCB) to fix a price band within which EPR certificates can be traded between producers and recyclers. The lowest price in this range is set at 30% of the penalty for non-compliance, while the highest price is set at 100%.

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The problem here is its attempt to bridge a supervisory gap in India’s waste management ecosystem through intervention in the market price of e-waste. 

The CPCB regulates the safe management of e-waste. A key part of its mandate involves formalizing the informal recycling sector, which still handles 90% of India’s e-waste and yields very low recovery rates of useful metals. Unlicensed recyclers are banned from operating, but to join the formal system, they must invest in expensive upgrades.

Yet, informal recycling remains India’s mainstay. The limited involvement of organized private players is a systemic issue that demands proactive regulation and a formalization pathway for informal actors. A floor price is not a panacea for this. It leaves no room for recyclers and producers to negotiate prices based on market factors. Also,  a guaranteed price disincentivizes  recyclers from cutting costs through process innovations. 

That the current floor price is too high was revealed by recent bids as low as ₹5.90 per kg in a reverse auction that saw the participation of formal players. Recyclers earn EPR credits based on the recovery of such metals as gold, copper, aluminium and iron from e-waste. While recyclers need financial assistance to modernize operations, private producers should not be expected to shoulder the responsibility. Public funding should be used to develop  the core infrastructure necessary for efficient recycling.

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The current regime also imposes a heavy financial burden on India’s electronics manufacturers. Such regulatory constraints reduce competitiveness and discourage investment. Expensive compliance can also push recycling back into the informal sector, defeating the purpose of the regulation.

Given the CPCB’s ever-expanding mandate, it operates with insufficient staff and financial resources. Its staff strength declined from 389 to 379 between 2017-18 and 2022-2023 despite a rise in sanctioned posts. Vacancies nearly doubled, indicating that even as roles were added on paper, positions remained unfilled. 

Over roughly the same time frame, e-waste generation more than doubled to over 1.6 million tonnes, the number of regulated EEE categories jumped from 21 to 106 and the count of authorized recyclers rose from 275 to 567. So the Board’s monitoring task has grown.

Budget allocations have not kept pace. The CPCB was allotted ₹126 crore in 2025-26, even though electronics production has crossed ₹8.25 trillion. Additionally, funds already collected for environmental purposes remain underused. The CPCB spent less than 1% of its environmental compensation funds last year, for example. 

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To address these gaps, three immediate reforms are necessary.

 First, the government must enhance the CPCB’s operational and financial capacity significantly. This should include filling sanctioned staff positions, establishing regional offices and ensuring the full and timely use of collected funds.

Second, the floor price should be withdrawn, with the option kept open to reinstate it later if need be. Allowing producers to sign contracts directly with certified recyclers at market rates would reduce costs, improve efficiency and reward innovation.

Third, the informal sector must be better integrated into  India’s e-waste management system, which is critical to scaling up safe recycling infrastructure. The International Labour Organization’s Recommendation No. 204 outlines how informal workers could be moved to the formal economy via legal recognition, access to finance, skills training and supply chain integration.

Municipal authorities in countries such as Brazil have executed pilot projects to rally informal waste pickers into cooperatives, with access to proper infrastructure, formal contracts and health protection. With India’s recycling ecosystem so heavily dependent on rag pickers, scrap dealers and repair workers, their legal recognition and support through training, finance and access to EPR systems can make this critical activity more inclusive, safer  and scalable. 

The authors are, respectively, sustainability and manufacturing policy experts at Koan Advisory Group, New Delhi.