EPR must track health risks across India's waste chain

Dr Sudheer Kumar Shukla

New Delhi, Oct 7 (UNI) India's extended producer responsibility regime must go beyond measuring tonnes recycled to account for the health risks embedded in the waste chain.

India's Extended Producer Responsibility (EPR) regime has grown into one of the world's most ambitious. As of March 2026, the Central Pollution Control Board reports 4,574 registered recyclers across five major waste streams, with cumulative recycled quantities exceeding 417 lakh metric tonnes. The architecture spans plastic packaging, e-waste, battery waste, waste tyres, used oil, end-of-life vehicles, and non-ferrous scrap metal.

However, beneath this scale lies a striking omission: nowhere in the framework is there a requirement for producers to assess, disclose, or reduce the health risks their products create across the recycling and disposal chain. The system measures tonnes collected with commendable precision. It does not measure illness prevented.

The unit of accountability is the tonne, and it treats all recycling as equivalent, whether it happens in a registered facility with pollution controls or in an informal backyard where circuit boards are roasted over open fires. The distinction matters enormously for health. The WHO warns that as many as 18 million children and 12.9 million women may be at risk of adverse health outcomes linked to informal e-waste recycling, with some children engaged in waste processing as young as five. Workers are exposed to over 1,000 harmful substances, including lead, mercury, and chlorinated dioxins.

The evidence across three major waste streams is unambiguous. India generated approximately 4.137 million metric tonnes of e-waste in 2022, but using the Global E-waste Monitor's total-generation methodology, only about 1.4 percent was formally collected and recycled.

A 2017 review estimated that 95 per cent of India's e-waste was handled by the informal sector, where elevated levels of heavy metals have been found in workers' hair samples in studies from Bangalore and Chennai, and an estimated 400,000-500,000 child labourers were engaged in e-waste activities. In batteries, the informal sector handles 30-65 per cent of lead-acid battery recycling; blood lead levels among factory workers have been reported at more than ten times normal. Council on Energy, Environment and Water (CEEW) cites a multi-country estimate in which lead exposure from toxic waste sites in India, Indonesia, and the Philippines imposed a disease burden comparable to malaria and outdoor air pollution.

In plastics, the concern is additives: a 2026 ToxicsLink study found BPA in 94.56 per cent of children tested, and phthalates have been detected in bottled water, municipal drinking water, and food-contact materials, with documented links to breast cancer risk.

The broader context sharpens the urgency. Pollution was responsible for approximately 9 million premature deaths globally, one in six deaths, and deaths from modern pollution risk factors, including lead and toxic chemical pollution, increased by more than 66 per cent since 2000. In India, the Lancet Countdown recorded over 1.7 million PM2.5-attributable deaths in 2022. The chemical pollutants embedded in EPR-regulated products are precisely the toxic pollution the Lancet Commission identifies as the fastest-growing component of this disease burden.

International precedents show this is possible. The OECD has documented that advanced EPR fee modulation can account for hazardous substances, not merely weight. France's CITEO applies a 100 per cent penalty for non-recyclable packaging and a 20 percent surcharge for some electronics, such as game consoles containing brominated flame retardants. The EU Battery Regulation (2023/1542) requires due diligence across the entire value chain to protect the environment and human health.

What would a health-risk screen look like in India? It should be a tiered regulatory filter, not a clinical trial. Tier 1 would require producers to disclose chemical constituents above defined thresholds, building on substances already flagged by BIS, FSSAI, and e-waste rules. Tier 2 would assess exposure pathways, including those faced by informal waste workers, largely overlooked by current EPR systems. Tier 3 would translate the findings into eco-modulated EPR fees-higher for products with hazardous constituents and credible exposure pathways, and lower for those designed for chemical simplicity and safe recyclability.

Critics may point to measurement challenges, compliance costs, and overlap with existing chemical regulations. However, these are reasons for a proportionate, risk-based system-not for excluding health from EPR. The screen need not prove causation; disclosure and exposure assessment can identify credible risks. A tiered approach can also keep burdens low for simple, recyclable products while requiring greater responsibility from higher-risk ones. Moreover, unlike chemical rules that assess products largely in isolation, EPR must account for what happens after disposal-who handles the waste, how they are exposed, and who ultimately bears the health cost.

Three concrete steps to start. First, mandate chemical disclosure as a condition of EPR registration through the CPCB's operational portals. Second, introduce eco-modulated fees based on toxicity and exposure risk, modeled on the French system. Third, integrate occupational health monitoring as a condition of EPR certificate generation. Blood lead levels for battery workers, urinary heavy-metal screening for e-waste workers using thresholds already defined in the CPCB's own Standard Operating Procedure, which requires relocation of workers with blood lead above 42 μg/dL and permits return only below 10 μg/dL. The need is urgent.

As of December 2025, 5.826 million tonnes of battery waste had been processed through formal CPCB channels, yet 85-90 percent of end-of-life batteries still flow through informal networks. Blood lead levels among battery workers in low- and middle-income countries average 37.99 μg/dL - nearly double the ACGIH occupational threshold - with Indian studies recording levels as high as 65.5 μg/dL. In eight Bihar districts assessed in 2024, over 90 per cent of children had blood lead levels above the WHO threshold, and a CSIR-NITI Aayog report recorded child BLLs as high as 190 μg/dL near informal recycling sites.

EPR was founded on the polluter-pays principle. Health harm is environmental harm, the most direct and morally urgent form of it. Success should be measured not only by how many tonnes were collected, but also by how many lives were protected. The data exists. The tools are proven. The portals are operational. What is needed is the will to ask the question the current framework refuses to ask.

(The writer is a senior environmental policy and circular economy expert. Views are personal.)

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