India’s e-waste stream continues to grow, adding urgency to the question of how the country will finance and scale responsible recycling. According to the Central Pollution Control Board (CPCB), India generated 13.98 million tonnes of e-waste in FY2024-25  up 11.45% from 12.54 lakh tonnes in FY2023-24. 

The growth is placing greater importance on India's formal recycling infrastructure and, consequently, on the Extended Producer Responsibility (EPR) framework that is intended to help fund it. 

At the centre of the current debate is the ₹22/kg floor price for EPR certificates. Introduced as part of the pricing mechanism under India's E-Waste (Management) Rules, the floor was designed to establish a minimum exchange value for certificates. CPCB's framework provides for the lowest exchange price of an EPR certificate to be equivalent to 30% of the applicable environmental compensation, with the highest price capped at 100%. 

For recyclers, however, the issue is not simply whether ₹22/kg is adequate. 

It is whether EPR revenues can provide the stability needed to operate compliant facilities, secure feedstock, invest in technology and expand capacity. 

The cost of compliance 

Formal e-waste recycling comes with costs that extend well beyond recovering metals and other valuable materials. Recyclers have to invest in pollution-control systems, worker safety, regulatory compliance, documentation, traceability and the safe handling of hazardous components.

B. K. Soni,Chairman& Managing Director of Eco Recycling Ltd (Ecoreco), believes the discussion needs to be viewed from a broader national perspective. 

“No one welcomes any cost,” Soni says, arguing that the immediate cost of responsible recycling needs to be weighed against the potential long-term cost of environmental damage, health impacts and ecological degradation. 

For Soni, EPR should ultimately be about ensuring that valuable materials contained in discarded electronics are recovered and returned to the economy. 

“The certificate should represent an actual environmental and resource-recovery outcome, not become an end in itself,” he says. 

This distinction is important as India's EPR system matures. If certificates become primarily a mechanism for meeting a numerical compliance obligation, the market risks becoming disconnected from the actual environmental performance of the recycling activity it is supposed to support. 

Why a floor price matters 

Anuj Maheshwari, CEO & Co-founder of Trace Resources, sees the introduction of a floor price as an important intervention during the formative phase of India's EPR market. 

Before the floor price, certificate values were largely market-driven and, he argues, did not always reflect the costs incurred by formal recyclers. 

“Formal recyclers incur substantial costs towards regulatory compliance, environmental safeguards, pollution control systems, worker safety, documentation, traceability and reporting; costs that the informal sector typically does not bear,” Maheshwari says. 

Yet he does not see a fixed floor price as a permanent solution. 

The more fundamental objective of EPR, he says, should be to bridge the economic gap involved in bringing waste into the formal recycling chain. 

Where a recycler receives material through established commercial channels and the recovered materials themselves generate sufficient value, the requirement for additional EPR support may be lower. But collection infrastructure, reverse logistics and efforts to bring waste into formal channels can add significantly to the cost. 

In this context, Maheshwari argues that the EPR certificate should increasingly become a mechanism to compensate for the incremental cost of formalising waste flows, rather than a permanent payment for every kilogram recycled. 

That could point towards a more dynamic pricing model as the market matures. 

Predictability matters as much as price 

For recyclers, one of the biggest concerns surrounding the current debate is uncertainty. 

E-waste recycling requires long-term investments in processing infrastructure and technology, while feedstock availability and material values can fluctuate. 

Rahul Anand Gogi, VP of Growth & Strategy at Recyclekaro, says a minimum price provides recyclers with greater certainty when planning capacity and making investments. 

“E-waste recycling involves highly variable feedstocks, fluctuating scrap prices, and several operating costs related to procurement, processing, compliance, logistics, and environmental safeguards,” he says. 

A minimum price, therefore, is not necessarily about guaranteeing profitability. Rather, it can provide an additional degree of predictability when recyclers assess the economics of new capacity. 

“Material recovery alone cannot be the only incentive for recyclers,” Gogi says, stressing that e-waste management is also an environmental responsibility requiring scientific processing and safe handling. 

This becomes particularly relevant when recycling companies are considering investments in more sophisticated recovery technologies. 

The trading slowdown 

The uncertainty surrounding the floor-price mechanism has also affected the EPR certificate market. 

Maheshwari says the introduction of the floor, together with subsequent legal and regulatory developments, has resulted in caution among some producers procuring certificates. 

“Regulatory uncertainty naturally slows market activity until there is greater clarity,” he says. 

Gogi says there has “certainly been a slowdown” in e-waste EPR certificate trading because the floor-pricing mechanism is being contested. 

For Recyclekaro, he says, this has not immediately affected the underlying business because the company has structured its material-recovery and processing operations so that EPR acts as an additional incentive rather than the sole source of viability. 

The bigger concern is what uncertainty means for future investment. 

“It can reduce confidence and weaken the willingness to scale rapidly,” Gogi says. 

For an industry seeking to build capacity ahead of rising e-waste volumes, that hesitation could become significant. 

Feedstock is the other piece of the equation 

Pricing is only one part of the economics. 

Soni points to another fundamental challenge facing the formal sector: ensuring that sufficient quantities of e-waste consistently reach compliant recycling facilities. 

India has already invested in formal recycling infrastructure, but the availability of predictable feedstock remains a concern. 

“For recycling infrastructure to become commercially sustainable and investible, capacity must be matched by predictable feedstock and a viable return on investment,” Soni says. 

The implication is that a viable EPR system needs to do more than generate certificates. It needs to support a functioning value chain from collection and aggregation to transportation, processing and material recovery. 

If recyclers cannot secure enough material, additional processing capacity may remain underutilised regardless of the EPR price. 

Towards a more dynamic EPR market 

Experts broadly agree that the next stage of India's EPR framework should focus on improving market efficiency, transparency and implementation rather than simply defending or removing the ₹22/kg floor. 

Maheshwari advocates a transparent methodology for periodically reviewing EPR pricing based on scientific cost assessments. He also proposes moving towards a more differentiated incentive structure that recognises the varying costs involved in formalising waste streams. 

Such a system could also recognise differences in environmental performance. 

Maheshwari argues that recyclers investing in advanced recovery technologies and achieving higher material recovery should be incentivised differently from those undertaking only basic processing. 

That could become increasingly important as India seeks to recover greater quantities of valuable and critical materials from electronic waste. 

Gogi, meanwhile, sees implementation as the immediate priority. 

He argues that India already has a relatively strong EPR framework, but that the system needs clearer and more robust audits. These should verify actual processing capacity, material traceability, environmental safeguards and the authenticity of EPR certificates. 

“E-waste recyclers have not yet experienced the full potential of EPR,” Gogi says, arguing that stronger implementation could significantly improve the sector's prospects. 

From compliance to resource security 

For Soni, the longer-term opportunity extends beyond waste management. 

India has already extracted and imported vast quantities of raw materials that are now embedded in products sitting in homes, businesses and waste streams. Those materials represent what he describes as a “mine above the ground.” 

The objective of EPR, therefore, should be to ensure that these materials are recovered and returned to productive use rather than lost. 

This gives the EPR debate a strategic dimension. A well-functioning recycling system can contribute not only to environmental compliance but also to resource security, domestic material recovery and the development of a circular economy. 

But unlocking that potential will require a market in which recyclers can make long-term investment decisions with reasonable confidence. 

Beyond ₹22 

The debate over the EPR certificate floor price is unlikely to disappear simply by settling on whether ₹22/kg is the right number. 

For recyclers, the more important questions are whether the pricing mechanism reflects the real costs of compliant recycling, whether certificate trading is predictable, whether genuine recycling outcomes are being rewarded and whether the policy framework provides enough certainty to support investment. 

The current floor has provided a degree of stability during the development of India's EPR ecosystem. But the industry's own responses suggest that the next phase may require something more sophisticated: a transparent, evidence-based and potentially differentiated mechanism that rewards environmental performance and helps formalise waste flows.