Abstract
TThe growing problem of End-of-Life Vehicles (ELVs) in India and the environmental hazards caused by their improper dismantling, recycling, and disposal requires a more efficient dismantling and recycling system to recover valuable resources and minimize environmental hazards. India has a large and growing number of ELVs, which are reaching the end of their usable life. Presently, the informal sector dominates ELV dismantling and recycling, often leading to environmentally unsound practices. The newly framed law of the land has proposed to establish a formal system of Registered Vehicle Scrapping Facilities (RVSFs), but remains ignorant towards these informal scrappers. An ideal approach to deal with this would be integrating these informal scrappers into the formal system for better resource recovery and environmental protection. Collaboration between vehicle and spare parts manufacturers, and dismantlers is crucial for a sustainable ELV management system.
Though there remain huge challenges in connecting the dots between the formal and informal sectors; however, such a step would ultimately be most beneficial for the original manufacturers as this will increase resource recovery from ELVs. The benefits of such measures would extend to the environment and human health at large, especially for those who are working in these unregulated dismantling units.
Introduction
An end is not an end, but the beginning of a new discourse; an always affirmative proverb which encourages positivity to what is already on the verge of losing hope. The present story is not so positive though; rather it is a warning towards the beginning of a grave state of affairs, which India is in no position to ignore. It is about the fate of End-of-Life Vehicles (ELV) in India; to the fate of the environment which is already on the brink. At a time, when India is fully geared up to decarbonise its transport sector, especially road transport through various policy measures and instruments and in which the major focus has been the adoption of electric vehicles on a mass scale, we cannot forego the fact that a critical mass of internal combustion engine (ICE) vehicles will become obsolete adding to the already existing pool of ELVs. It, therefore, needs immediate attention for their management, handling, and disposal.
As the name suggests, ELV refers to all those vehicles which were there on the road at any point in time; and eventually become obsolete, for whatever the reason be. A vehicle when it attains its end of life demands equal attention, if not more, because a vehicle contains such materials and precious metals which are having high recyclable potential. Some of the major materials a standard vehicle contains are steel, plastic, aluminium, glass, rubber, lead, copper, zinc etc to name a few. Data shows, that an average car contains approximately 1089 kg of steel whereas for a Sports Utility Vehicle (SUV) the amount stands at 1360kg. According to the International Energy Agency (IEA), a standard-sized conventional car contains 22.3kg of copper, 11.2 kg of manganese, 0.1 kg of zinc and 0.3 kg of other minerals per vehicle. It is therefore, quite evident that a vehicle once reaches its end of life will have huge scrap value attached to it, which is required to be handled in an efficient and sound manner, so as to ensure optimum extraction and utilization of such valuable resources, because each of these materials and metals has its own environmental footprint – either in the form of mining or through primary or secondary processing.
How Voluminous is the Problem
An analysis of 2015 on the ELV sectors in India by the Central Pollution Control Board (CPCB) has claimed an estimated number of ELV at 87,31,185 in the year of 2015, which was further expected to grow to 2,18,95,439 by 2025.
This is however a conservative figure, because this very analysis did not take into account parallel development in the regulatory space. The order of the Principal Bench of National Green Tribunal (NGT) banning 15 years old petrol and 10 years old diesel vehicles from plying in a city like Delhi; the Ministry of Road Transport and Highways (MoRTH) directions cancelling registration of all government vehicles after their completion of fifteen years across India and India’s ambitious plan of becoming a part of the global EV30@30 campaign are some of the development worth mentioning in this context. Projections with regard to Indian Electric Vehicle (EV) market indicates that the Indian EV market which was valued at USD 2 billion in 2023 could surge to USD 7.09 billion by 2025. Another forecast by the Economic Survey of India shows a 49% compound annual growth rate (CAGR) in the domestic EV market in India between 2022 to 2030, with an annual estimated sale of 10 million by 2030. These combined will do nothing but increase the volume of ELVs at a much higher rate, as compared to what has been estimated by CPCB in the year 2015. To give an idea, the Delhi Transport Authority de-registered around 50 lakh vehicles since the ban was in effect from 2015 up to January 2023.
It is not only about the increase in the volume of ELVs but also a concern for its management and disposal, which are still very rudimentary in nature and largely controlled by the informal sector. One has to remember that besides having a solid nature of scrap from steel, aluminium, glass, rubber, lead, copper, zinc etc, an ELV contains a variety of liquid substances including waste oil, engine oil, brake fluid, hydraulic fluid and likewise. Dismantling a vehicle in such a rudimentary manner (the way it is being done at present) results in their disposal into the soil, which is damaging for both the soil as well as groundwater.
Talking about the individual sub-components of a vehicle, especially the waste batteries, waste tyres, used oil, and electronic waste are all covered separately under the respective Rules, which are in place in India. However, their existence will go in vain, as long as the vehicle dismantling and scrapping continues to be under the ambit of informal recyclers. First of all, none of these respective regulations is applicable to the informal facilities running such units. Secondly, considering their number and frequent presence, it is practically impossible to monitor their compliance on the ground.
So, to say, the current practice results in a series of environmental hazards ranging from toxic liquid waste disposal over soil and resultant contamination of soil and groundwater to emission of gaseous fumes into the atmosphere; in a word creating pollution hot spots across the cities.
A study by CPCB conducted in 2015, which was of its kind study focusing on ELV, highlights five such thriving markets of ELV across India, located in Kolkata, Chennai, Pune, Jamshedpur and Indore. These units are mostly located in the centre of the cities which is already causing exposure of such hazards to the public at large. The increasing volume of ELVs will further aggravate the present state of affairs. Having stated this, it is of utmost importance to come out with an updated estimate of ELVs, so as to assess the support required for their management.
India’s Preparedness to deal with
Considering the potential scarp value attached to an ELV, as well as the danger of environmental hazard associated with the mis-management of ELVs, it becomes important to look as to how ready India is to deal with its ever-increasing volume of ELVs and how environmentally sound and efficient is its recycling system.
It has to be noted that the ELV market potential in India is not just restricted to a vehicle only when it becomes completely obsolete; rather the interim refurbishment, repair and replacement of any parts of a vehicle also leads to the emergence of small-scale local dismantler, shop owners and connected chain of small-and large-scale traders. Hence, the control of ELV and various scraps generated out of it needs to have a broader spectrum, which must include all the different entities connected with various stages of automobile industries. This is somewhat still missing in the latest law related to vehicle scrapping facilities, which has been in force since 2021.
The MoRTH has come out with the Motor Vehicles (Registration and Functions of Vehicle Scrapping Facility) Rules, 2021 under the Motor Vehicles Act, 1988 to deal with all categories of vehicles and their last registered owners, automobile collection centres, automotive dismantling, scrapping and recycling facilities and recyclers of all types of automotive waste products, to ensure environmentally sound management of ELVs. It has defined the ‘End of Life Vehicles’ as those vehicles which are no longer validly registered or declared unfit through Automated Fitness Centres or whose registrations have been cancelled as per the due procedure laid down in the Motor Vehicles Act, 1988 or due to an order of a court of law or whose owner by himself has declared the vehicle as a waste vehicle. The said Rule has clearly stated that the Registered Vehicle Scrapping Facility (RVSF) will have to meet the minimum technical requirement for collection and dismantling centres as per the CPCB Guidelines; however, it remained silent about the operability of the existing scrap dealers in this space. It has not talked about anything on their (existing dismantler or scrap dealers) inclusivity in the RVSF.
The Motor Vehicles (Registration and Functions of Vehicle Scrapping Facility) Rules of 2021 when came into force, have had an obligation for location identification of RVSF. An entity to get registered as RVSF was needed to have an adequate usable area of land in the orange category industrial zone of the State or Union territory by way of ownership, sale or agreement for lease of a minimum period of three years. However, such a requirement has been omitted by virtue of a recent amendment dated 15th March 2024, which means that such RVSF can come up with a facility anywhere in the state and there will be no locational restrictions over them. It is highly likely that such leverage will result in the conversion of the existing informal dismantlers and local vehicle repairing units into an RVSF, thereby aggravating pollution hotspots across cities.
Not only causing pollution, these lack significantly in terms of knowledge, expertise and technology of how best a vehicle can be dismantled. One has to also understand that vehicle dismantling and recycling is not just a ‘one size fit for all’ approach because every vehicle brand has its own model and each of these models demands specific knowledge, equipment and support system to dismantle them and get the best out of it. Therefore, manufacturing companies’ looping in should ideally be the best approach to fill this knowledge gap which is required for the dismantling of a vehicle.
Such connections between the original manufacturers and the existing scrap dealers will also enhance channelization of valuable scrap or raw materials from the informal dismantling and recycling units to manufacturing units of automobile and spare parts. Connecting the bridge between manufacturers of the vehicles (post-manufacturing and consumer-driven marketing stage) and the existing informal vehicle dismantlers could actually enhance the process of dismantling and recycling procedure which is currently quite crude and inefficient and also environmentally unsound. This could also help in reducing the knowledge gap among the informal communities, engaged in the dismantling and recycling process.
Further, we should remember the livelihood dependency, of these informal dismantlers and recyclers at present. For the sake of regularizing a sector, our transition process should not become unjust for such a large volume of people. Therefore, from the very beginning, it is important to make a linkage between the existing vehicle scrappers, dismantlers and the RVSFs. Else there should at least be clarity as to how the existing dismantlers’ network can be best utilised or looped in the formal chain of vehicle scrapping and dismantling.
In a recent advancement, the Ministry of Environment, Forest and Climate Change (MoEFCC) has come out with the Draft End-of-Life Vehicles (Management) Rules, 2024 in January 2024, which has relied a lot on the RVSF and its responsibilities, starting from the collection and storage of ELVs till its dismantling, treatment, disposal and final channelisation of the recovered and segregated materials to registered recyclers or refurbishers and co-processors for recycling and reuse of components or materials. It means, that once implemented, these RVSFs are going to be a big player in the entire mechanism of ELV management and disposal. Therefore, any gaps between the informal units and RVSF are not at all desirable.
We should also remember that many of the original automobile manufacturers who were engaged in making the internal combustion engine (ICE) based vehicle have now started venturing into the EV spectrum and this obviously creates demand for many such metals which were there in the conventional ICE vehicles and are now needed for EVs. Though the percentage share would be less as compared to the conventional ICE vehicles, it still will not go in vain.
It is therefore essential to connect the dots between these important pillars of vehicle recycling and management, which are registered owners of the vehicle, automobile spare parts manufacturing units, the final manufacturers of the vehicle, the collection centre and the vehicle scrapping and dismantling facilities.
Resources are not Infinite
To make a few last words, I would go back to a very old and commonly used phrase in the environmental paradigm, i.e. “non-renewable resources in the earth is not infinite” and hence we cannot simply continue with the way we are currently extracting resources. The efficient dismantling and recycling if not considered for the sake of the environment, at least should be considered for ensuring ease of doing business. The automobile industries therefore cannot ignore the resource limitation as that will be impacting them the most, by causing resource crunch and increasing financial burden which may arise out of the import dependency for raw materials. So, the more efficient the dismantling, recycling and channelization of scrap materials, more will be the resource optimization. These together will invariably make a change in the environmental condition as compared to what is presently prevailing across these informal vehicle scrapping units.
Learn from the Unlearned Past
In India, we have had many experiences of dealing with waste materials in such a crude manner which has become a burden to the environment as well as to the public at large. We should not create a situation similar to what is there in Alang Shipbreaking yard of Gujarat coast, where the ignorance from the beginning has now deteriorated the environment to an extent that, there is hardly any scope for its restoration.
We have seen the failure of electronic waste management mechanism when we ignored the existence of informal sectors under whose control 95% of the country’s e-waste lies. The electronic waste management has already taught us the necessity of inclusion of informal sectors who can only be the last mile connector of collecting those wastes, and who could best facilitate the maximization of the collection of e-waste.
The same mistakes should not be repeated. India at present already has a well-established network of informal vehicle dismantlers and recyclers who should be tapped at its fullest and connected with the automobile and spare parts manufacturers for channelization of ELVs and scrapped vehicle parts. Without taking them in the supply chain, the creation of new RVSFs will just create the RVSFs on pen and paper, whereas the actual transfer of spare parts, scraps and valuables will take place somewhere else.
Suggestive Action
What is important is to bridge the gap between automobile manufacturers and vehicle scrap dealers which are largely controlled by the informal sector. We Indians do have a culture of repairing and refurbishing existing vehicles for optimization of their use. This in a way is a blessing but at the same time becomes a curse too. Such repair and refurbishment create numbers of local area-centric dismantlers and automobile repairers, making numerous polluting units difficult to monitor. However, the same entity can be turned into a blessing by connecting them with the automobile manufacturers, so that a logistic chain be developed between existing facility owners and original automobile manufacturers. At present, the flow of materials might be there for inbuilt scrap value of the materials, but owing to their numbers it is hardly possible to maintain a track and keep a watch on them. The result? Pollution hotspots across cities and inefficient resource extraction.
The latest Motor Vehicles (Registration and Functions of Vehicle Scrapping Facility) Rules of 2021 have dealt in detail with how to establish and run a Registered Vehicle Scrapping Facility (RVSF) but did not take these informal scrappers and dealers into consideration. Policy-level rethinking for bridging this gap would be beneficial for both – the optimization of resource extraction and the environment. The three important stakeholders, i.e. the user, the dismantler and the automobile and its spare parts manufacturers must synchronise with each other.
Globally, leading car manufacturers such as Benz, BMW, GM, Volvo, Toyota etc have been working on designs for disassembly and for enhanced recycling rates of different materials, which is also intended towards the betterment of the environment. The same needs to be initiated by the Indian manufacturers too, who run their plants in technical collaboration with many of these automobile giants. These plants besides meeting up these innovation challenges, should also trap the existing network of informal vehicle scrappers.
Only suggesting new RVSF may face difficulty of getting enough scrapped or end-of-life vehicles which would ultimately hinder their smooth running of businesses. Instead, the process may see better results, if these existing scrappers are improvised into a registered vehicle scrapper.
Conclusion
Vehicular waste or as it is called ‘End-of-Life Vehicle’ in India can no longer be treated as a stepchild; rather it needs urgent attention considering the ever-increasing fleet of end-of-life vehicles in India and its in-built resource value. An estimated projection made by CPCB in 2015 indicates an end-of-life vehicles fleet of 2,18,95,439 by 2025, which is a way too conservative figure, to say the least. The increasing shift towards electric vehicles and the recent ban on diesel and petrol vehicles will nothing but increase the volume of ELVs, which are required to be managed and disposed of in an environmentally sound manner.
The country at present is still lacking an efficient dismantling and recycling system for end-of-life vehicles, which could otherwise ensure resource optimisation as well as environmentally sound management of such vehicles. However, what the country poses is a well-established informal network of dismantlers of vehicles which deals with repairing damaged vehicles and dismantling and recycling vehicles which have reached their end of life. It is therefore essential to make use of such informal units and bring them into the entire supply chain of the formal recycling system.
The latest development in the regulatory landscape related to the management of end-of-life vehicles is no doubt a stepping stone towards their management; however, its silence on the inclusion of the existing informal units in the entire supply chain will leave behind a huge fleet of vehicles which remains under the control of these informal sectors. The same is applicable to automobile manufacturing units as well. These manufacturing units should also not remain averse to these informal units which can actually be beneficial for them, in terms of getting the damaged and end-of-life vehicles. There exists a huge disconnect between these informal sectors dismantlers and vehicle repairing units and the automobile manufacturing units.
It is therefore highly essential that past learning should not be ignored and the informal but well-established network should be optimally utilized. Or else, even the best-framed law will fail in effectively purposing it.
Author
Kankana Das is a Programme Lead at State Climate Action (WB & Odisha), Asar Social Impact Advisors, and also an LLB 1st year student at Sister Nivedita University.
Disclaimer
The opinion expressed here in this article is absolutely an individual view based on my working experience in the development sector for more than 15 years. My employer and my university do not have anything to do with these views. Suggestions proposed are always subject to practical trial and testing and hence not absolute and neither exhaustive.
Editorial Team:
Managing Editor: Naman Anand Editor in Chief: Abeer Tiwari & Muskan Singh Senior Editor: Harshita Tyagi Associate Editor: Parmi Banker Junior Editor: Anam Sadaf
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