There are challenges and opportunities in India’s 2024 liquid waste management rules
The October 7, 2024 gazette draft rules by the Union Ministry of Environment, Forest, and Climate Change mark a significant step in India’s efforts to overhaul its Liquid Waste Management (LWM) system.
The document details a list of mandates aimed at enhancing wastewater treatment, reuse and septage management across urban and rural areas, with an ambitious focus on sustainability, compliance and accountability.
At the core of this notification is a structured framework that aims to streamline the treatment of liquid waste from multiple sources — households, industries, public institutions, and private establishments.
These rules prioritise the collection, treatment, reuse and disposal of both wastewater and associated sludge. The notification’s legal grounding lies in the Environment (Protection) Act, 1986, and it seeks to address India’s growing wastewater crisis through structured, time-bound, and enforceable measures.
Liquid waste management — the blueprint
The notification mandates that these new rules will be enforced starting from October 2025, giving stakeholders a transition period of one year to comply.
The initial reuse targets for bulk water consumers — industries, institutions and large housing societies—are set at 20 per cent for the 2027-28 period. These targets will rise to 50 per cent by 2030-31.
A key compliance requirement for bulk water users is the Extended User Responsibility (EUR) framework, which mandates that they must ensure proper treatment and reuse of their wastewater.
The notification also establishes a rigorous compliance framework, with provisions for regular reporting and monitoring of wastewater treatment operations. Operators of both centralised and decentralised treatment plants are required to report data on treatment volumes, sludge management, and reuse outcomes. This reporting must be submitted monthly to the State Pollution Control Boards (SPCBs) and uploaded to a centralised online portal.
The timelines, however, seem aggressive, especially given the wide disparity in infrastructure capabilities across the urban and rural landscape.
Larger cities may find it easier to comply due to existing resources, but smaller towns and rural areas may struggle to meet the targets without substantial support.
A phased approach, with region-specific timelines and financial aid, would ensure more equitable compliance. There must also be a significant push for public awareness and education, particularly in residential areas, where the social resistance to using treated water remains high.
Also, while the monitoring portal is an important step forward, its effectiveness will depend on the technological infrastructure and capacity of various local bodies and industries, especially in smaller towns and rural areas. Many of these regions may not have the required digital infrastructure to regularly submit accurate data, which could hinder the overall effectiveness of the system.
Also, the Extended User Responsibility (EUR) framework places the onus on bulk consumers, such as industries and large housing complexes, to manage the wastewater they generate.
The EUR mechanism is a positive development, as it ensures that industries and large users take direct responsibility for the environmental impacts of their operations. However, the challenge lies in enforcing compliance, especially in industries that may find it economically unfeasible to establish treatment facilities.
Management of sewage sludge
The notification incorporates detailed guidelines for managing sewage sludge (or septage), a byproduct of wastewater treatment. This is aligned with the principles of the circular economy, where waste is converted into a resource, thus reducing the environmental footprint of waste management systems.
While the reuse of sludge is a promising concept, quality control will be essential. India produces approximately eight million tonnes of sewage sludge annually (CPCB, 2021), and ensuring that all of this is treated to safe standards will require rigorous monitoring and compliance.
Many treatment plants, especially smaller ones, lack the technology to consistently treat sludge to a safe level for agricultural use. Improperly treated sludge could carry pathogens or heavy metals, which, if used in agriculture particularly, could pose serious health risks to both farmers and consumers.
Regular monitoring and testing of sludge by accredited agencies should be mandated, with penalties imposed on treatment plants that fail to meet the required standards. It is also important to establish clear disposal routes for sludge that does not meet safety criteria, to prevent illegal or unsafe disposal practices.
Financial and structural support
One of the critical aspects of this notification is its call for both centralised and decentralised treatment solutions.
By advocating for decentralised systems, the notification acknowledges the limitations of large, centralised treatment plants, which often struggle to cope with the growing volumes of wastewater. Decentralised systems, however, present their own challenges, particularly in terms of funding and expertise.
The success of these systems will heavily depend on financial support from both the government and private entities. The draft rule did not provide a detailed roadmap for how local governments and smaller urban bodies will finance these new infrastructure requirements, which may hinder the effectiveness of the decentralised approach.
Impediments en route
It is important to mention that the initiative can face hurdles in implementation as it might overlap with government's many other initiatives that are incepted to tackle similar issues.
Firstly, inconsistent targets across various national missions and frameworks which have already decided timelines for water reuse, which may conflict with the new rules such as —
Swachh Bharat Mission 2.0 (SBM 2.0) mandates that cities with populations under 100,000 must reuse at least 20 per cent of their treated wastewater as much as feasible.
Atal Mission for Rejuvenation and Urban Transformation (AMRUT 2.0) aims for cities to recycle 20 per cent of their total water demand and 40 per cent of industrial water demand through treated wastewater.
National Mission for Clean Ganga (NMCG) framework sets even higher targets for states where Sewage Treatment Plants (STPs) are operational—requiring 50 per cent reuse by 2025 and 100 per cent by 2050. Where STPs are not yet operational, the targets are 30 per cent by 2030, rising to 50 per cent by 2035 and 100 per cent by 2050.
Amidst these ongoing frameworks, the new rules propose different reuse targets for bulk water consumers: 20 per cent reuse by 2027-28 for industries and housing societies, increasing to 50 per cent by 2030-31.
This may lead to confusion and overlaps in policy implementation. States and local bodies may struggle to reconcile these varying targets, especially where multiple frameworks are operational. The government should aim to standardise these targets across various missions.
Secondly, the new rules place major responsibility on the Central Pollution Control Board (CPCB) and State Pollution Control Boards (SPCBs) to oversee compliance, monitor water reuse targets, and manage the quality of treated wastewater.
However, the capacity of these bodies to effectively implement and monitor the rules seems difficult.
Without significant capacity-building efforts, the CPCB and SPCBs may struggle to enforce the LWM Rules effectively. The success of these rules depends heavily on strong institutional frameworks for monitoring and enforcement.
Thirdly, while the notification is a strong regulatory framework, its implementation will likely face several challenges. The short transition timeline, coupled with the technical and financial burden on smaller municipalities and industries, could slow down progress.
Additionally, there is the matter of public resistance to the reuse of treated wastewater, particularly in residential and public spaces, which could hinder adoption rates.
To tackle this public engagement remains a critical component in the success of the notification. Educating communities about the importance of treating and reusing wastewater will be crucial to changing behaviours and ensuring that the reuse targets are met.
Lastly, implementing the Liquid Waste Management (LWM) rule requires a multi-faceted approach involving various stakeholders, resources, and infrastructure.
To ensure effective execution, it's important to ask key questions across different dimensions such as infrastructure readiness, financial planning, capacity building, monitoring, and stakeholder engagement. Mentioned below are some critical questions that needs to be addressed before enforcing compliance —
What is the current treatment capacity of centralised and decentralised wastewater treatment plants, and how much additional capacity is needed to meet the 2027 and 2030 targets? Also, do the Urban Local Bodies (ULBs) and rural governing bodies have the existing infrastructure or technical capacity to implement decentralised treatment systems?
How variations in compliance across regions with different financial and technical capacities will be managed, such as between metro cities and smaller towns? How will the financial and technical support be distributed to ensure that ULBs, particularly in smaller towns and rural areas, have the resources necessary for implementing these regulations?
What capacity-building programs will be planned to train ULBs, rural governing bodies, and industry operators in managing decentralised treatment systems and ensuring compliance with reuse and sludge management rules?
What communication channels will be established between the government, ULBs, industries, and the public to ensure transparency in implementation and address challenges in real time? How will public awareness programs be designed to ensure that residential communities, industries, and local bodies understand the importance of water reuse, sludge management, and compliance with the rules?
Addressing these questions can help identify gaps and can guide the successful implementation of the rules.