Dr. Buddhaprakash Jyoti IAS currently serves as the Member Secretary of the Telangana State Pollution Control Board (TSPCB), a position he has held since January 2024. Although this role represents a shorter tenure compared to his extensive seventeen-year career in various governmental capacities—from local field positions to state headquarters—Dr. Jyoti continues to make a significant impact at TSPCB. His career is guided by the principle of “the last person first,” emphasizing the inclusion of marginalized groups in governance processes.
As a Cheng Fellow, Dr. Jyoti dedicated his efforts to addressing the challenges faced by manual scavengers in Telangana, collaborating with government agencies, NGOs, and industry groups to eradicate manual scavenging and improve the socio-economic and educational opportunities for affected families.
Recently, empowered by the Central Pollution Control Board’s new directives on Extended Producer Responsibility (EPR) certificates, Dr. Jyoti has intensified his campaign against the environmental and health hazards of electronic waste. His conversation with NareshNunna of NSH highlights his ongoing commitment to environmental advocacy and his strategic efforts in combating the toxic legacy of e-waste:
How does TSPCB prevent fake EPR certificates despite having an online portal?
A. E-Waste EPR Portal is an online E-Waste Management System developed by CPCB, where applicant producers can apply online for grant of Registration Certificate and Recycling Targets / EPR obligation. All the stakeholders like Producer, Recyclers, Refurbishers and Manufacturers are required to register themselves on this system. The CPCB issues Extended Producer Responsibility Registration Certificate.
CPCB is the authority which issues EPR Certificate. They have developed close looped system for generation and transfer of EPR certificates between recycler and producers to eliminate any chances of fake certificate trading. The EPR certificates will be generated through portal only based on the quantity recycled and sale linked to GST portal. Each EPR certificate is generated with unique number and once the certificate is transferred to producers, there cannot be duplicate certificate generation in the portal. There is remote chance of generating duplicate GST sale invoices, hence no duplication of EPR certificates. There is no chance of physical transactions of the certificates.
The centralized portal by CPCB since last year has plugged most of these gaps and there is provision of Environmental Compensation to be levied on producers for not fulfilling the targets as well as for recyclers if the EPR certificates are not generated as per the recycling capacity.
Based on projected sales input provided by producers, the portal generates a recycling target, which producers and manufacturers find third-party recyclers. Thus the chances of fake EPR certificates are very remote due to this system and also third-party audits too.
What’s being done to stop recyclers from faking EPRs by not recycling enough e-waste?
A. Recyclers have to establish purchase of E-waste and sale of extracted metals by submitting proofs on the CPCB portal. It is a real time portal linked to GST. The GST sale invoices only are allowed to be uploaded for which the quantity recycled will be matched and accordingly the EPR certificates for that quantity will be generated through the portal automatically. There is no physical or human intervention in generating the EPR certificates. The documents submitted would further be audited by CPCB or any other agency appointed by CPCB. There is also a provision in the EPR portal to verify the recyclers by CPCB on the capacity of recycling and accordingly the factors are evolved and certificate generation is decided.
How does TSPCB work with customs to stop illegal e-waste from entering Telangana?
A. As per the E-waste rules and Hazardous waste Management rules, import of e-waste is restricted and only with prior permission of the MoEF & CC, CPCB they are allowed to import. Customs Authority under the Customs Act, 1962 to verify the import or export with respect to Extended Producer Responsibility under these rules and Inform Central Pollution Control Board of any illegal traffic for necessary action. There is no role of TSPCB in this matter.
Which areas in Telangana are prone to illegal e-waste imports, and what challenges does TSPCB face in stopping them?
A. Telangana is a landlocked State with no coastline and seaports. Presently, TSPCB has not experienced any challenges or came to know of such illegal imports.
However, as per rule 17 of E-Waste (Management) Rules, 2022, it is the Responsibility of the Port Authority under Indian Ports Act, 1908 and Customs Authority under the Customs Act, 1962 to verify the import or export with respect to Extended Producer Responsibility under these rules and inform Central Pollution Control Board of any illegal traffic for necessary action and take action against importer for violations under the Indian Ports Act, 1908 or the Customs Act, 1962. There is no role of TSPCB in this matter.
Would holding producers directly responsible for e-waste targets work better than relying on recyclers?
A. Yes. EPR is a strategy to place a shared responsibility for end-of-life product management on the producers creating circular economy. The laws make it mandatory for companies to collect-back and recycle their end of life products. This allows the costs of treatment and disposal to be incorporated into the total cost of a product. By placing responsibility on the producer, it leads to better product design in order to save the cost. The companies can either fulfill their EPR Targets by themselves or hire Third-Party Organizations called as Producer Responsibility Organizations (PROs)/Waste Management Agencies to fulfill them.
Manufacturers can pursue EPR in multiple ways, including reuse/refurbishing, buy-back, recycling and energy production or beneficial reuse applications. Life-cycle assessment and life-cycle cost methodologies may be used to compare the environmental impacts of these different waste management options. A growing number of companies (e.g. Dell, Sony, HP etc.,) are embracing EPR with various initiatives towards achieving sustainable e-waste management.
EPR is a preferred strategy because the manufacturer/ Producer bears a financial and legal responsibility for their products; hence, they have an incentive to incorporate green design and manufacturing practices that incorporate easily recyclable and less toxic material components while producing electronics with longer product lives.
What does TSPCB suggest for making e-waste laws in Telangana stronger?
A. While the rules present a comprehensive framework, concerns linger around the role of the informal sector and the potential burden on authorized recyclers. Striking a balance between formal and informal recycling channels is crucial for effective and sustainable e-waste management.
The informal sector, which plays a crucial role in e waste handling, draws no recognition in the new rules and the informal sector needs to be brought on board and incentives to given to get registered and do legitimate business.
How does TSPCB ensure that informal workers in Telangana recycle e-waste safely?
A. The Director of Labour, Department of Labour, Employment Training & Factories (LET&F) Government of Telangana is the authorized agency of the State Government to undertake annual monitoring and to ensure safety and health of workers involved in dismantling and recycling.
