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Some of the major recommendations tabled by Centre for Science and Environment (CSE) in one of its reports addressing the challenges posed by generation of industrial waste have been incorporated by the Indian government in a new draft notification for Solid Waste Management Rules, 2024.
The Union Ministry of Environment, Forest and Climate Change, first introduced the Solid Waste Management Rules, 2016, replacing the Municipal Solid Waste (Management and Handling) Rules, 2000. Then, on December 9, 2024, the ministry proposed a new draft notification for Solid Waste Management Rules, 2024.
These rules are aimed at addressing the adverse effects of unmanaged solid waste, promoting the principles of a circular economy, strengthening monitoring, reporting and enforcement frameworks along with expanding the scope of the rules to cover both urban and rural areas for improved environmental quality.
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While the 2016 rules focused primarily on managing waste, the proposed 2024 draft emphasises effective waste utilisation in alignment with circular economy principles.
The motivation towards circular economy by the apex body has been a key recommendation in a CSE report titled Good Practices in Industrial waste Circularity: a compendium which is published by the Centre for Science and Environment.
The report underlined that the government should assign a central agency responsible for circularity in India and build the capacity of stakeholders along with developing a common digital platform to be built to accelerate and collaborate on circular economy initiatives within the industries.
CSE’s report recommends notifying standards of refuse-derived fuel (RDF) quality to provide push to the stakeholders such as municipalities, industries and third party agencies.
Moreover, the report on decarbonising India’s cement sector by the same think tank recommends increasing the thermal substitution rate to 50 per cent by 2030. It also suggests forming regional coalitions between cement plants and municipalities to produce RDF that meets national standards.
In the new draft, in chapter 2 section 7 which mentions Duties of industrial units and waste to energy plants located within specified distance from refuse derived fuel plants based on solid waste — a framework has been created to foster the recommendations of these reports. It proposes formation of the online portal where RDF plants need to register their availability along with the quality of RDF on a monthly basis. Industrial units are to file annual returns on use of RDF/Segregated Combustible Fraction (SCF)/agri residue through a centralised online portal by June 30 every year.
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Chapter 7 also outlines the duties of Urban Local Bodies (ULBs) and specifies that concerned departments of State/UT governments shall map RDF plants ULB-wise, noting their production capacity and offtake by industries.
Ullash Parlikar Global Consultant (Waste Management, Circular Economy, Policy Advocacy & co-processsing) , says with regard, “ULBs should be given the responsibility of maintaining a quality of waste that is supplied for pre-processing/co-processing. This can be done through mentioning specific quality criteria in the tendering process.”
Though this is a move towards a right path, it loses direction in the Fuel Substitution Schedule. As mentioned in decarbonising India’s cement sector , here are some notable insights from the report's analysis of refuse-derived fuel (RDF), shedding light on the progress in waste co-processing:
ACC Wadi’s cement kiln co-processes more than 600 tonnes of waste daily. The waste includes plastics from municipal solid waste and industrial waste, contributing to a Thermal Substitution rate (TSR) of 18 per cent in 2021.
As of June 2021, Reddipalayam Cement Works achieved a TSR of more than 25 per cent.
Ambuja Cements’ plant in Kodinar in Ambuja Nagar, Gujarat, was able to achieve a TSR of 7 per cent in 2021 across all its three kilns.
When the cement industries themselves achieved these rates of fuel substitution almost four years ago the low ambition of the target seems underwhelming.
Looking north, the aforementioned report also highlights the significant adoption of RDF in the cement industry, particularly in the Netherlands and Germany. By 2008, Netherlands had achieved an 80 per cent replacement of conventional fuels with RDF, while Germany reached 54 per cent. As of 2021, Germany's TSR for the cement industry stood at 69.3 per cent, demonstrating continued progress in RDF utilisation.
“Achieving a higher target by 2030 is technically feasible. There is scope to upgrade the target,” Parlikar adds.
Meanwhile, Parth Kumar, Programme Manager in CSE’s Industrial Pollution stated: “Top cement companies in India have started charting pathways to achieve 25% TSR by 2030. Given the ambition of companies in the Indian cement sector, standardization of RDF is welcome, but a low target might impede progress towards RDF utilisation by delaying the shift to alternative fuels and hindering optimal waste management practices.”
Further CSE’s Report Good Practices in Industrial waste Circularity: a compendium, recommended developing national inventory of biomass generation and availability– as the biomass availability is either not available or non-uniform across the country. Also, there is data unavailability at the state level, which is important in realising the region-wise potential of biomass co-firing in industries.
In Chapter IV of the draft SWM 2024: ‘Environmentally sound management of a horticultural waste and agri-residue” section 1 (1-3), The local body is responsible for facilitating agri-residue collection and storage, tracking its in-situ and ex-situ utilisation, and annually reporting this data on a centralised online portal and its website.
This would empower formalisation of the largely informal sector of recyclers. This includes details on the quantity of agri-residue generated and utilised, as well as information about units established for ex-situ utilisation, their capacity, and operational status.
Making a centralised portal can enable the formalization of the largely informal sector of recyclers. For instance, as suggested in the improving wastepaper circularity in the pulp and paper sector there is a huge potential of integrating the informal sector which will strengthen the supply chain of paper waste. This model can also be replicated to all kinds of waste including municipal solid waste.
However, this section fails to address utilisation focusing only on environmentally sound management. Additionally, the rules do not clearly specify how agricultural residue and biomass generation will be integrated into the supply chain for biomass co-firing or CBG production. Good Practices in Industrial waste Circularity: a compendium highlights a significant gap in the demand and supply of biomass for co-firing, primarily due to the limited number of available vendors.
Furthermore, the report recommends that the government should invest strategically and financially in building a robust supply chain for biomass to fully realize the potential of these policies. Unfortunately, this approach is missing in the current draft.
The draft Solid Waste Management Rules, 2024, represent a bittersweet step forward, blending progress with missed opportunities. While the emphasis on circular economy principles and enhanced frameworks for waste utilisation showcases a commitment to circular economy approaches, the weak Fuel Substitution Schedule targets and lack of a robust agri-residue utilisation pathway highlight areas requiring urgent attention.
Nivit Kumar Yadav, Director, Industrial Pollution, CSE said: “The draft encourages cement sector to achieve 16% fuel substitution target in 6 years. Many cement industries have already achieved a TSR of more than 10 percent. Thus, lack of an ambitious target may end up derailing the the objective of the initiative, essentially asking them to achieve an already achieved target. In order to make use of the co-benefits from waste circularity with the rapid economic growth, these shortcomings must be addressed".
“Greater clarity, stronger enforceability, and strategic planning, ensuring a truly transformative approach to waste management is needed to improve the quality of environment across the country,” he added.