Is India Ready for Extended BWG Responsibility?

Sourabh Manuja and Tanya Rastogi delve into the gaps, challenges, and roadblocks in India’s Solid Waste Management Rules 2024 and the Extended Bulk Waste Generator Responsibility framework, questioning whether the system is truly ready for implementation.


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Waste Management
 
April 1 2025
 
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With India’s vision to become Viksit Bharat by 2047, we are witnessing a shift towards a more decentralized governance mechanism that promotes greater accountability at the local level. The policy landscape is also evolving. The Solid Waste Management Rules 2014 introduced a strong focus on processing municipal waste in cities. The Swachh Bharat Mission 2.0 further emphasized waste processing, urging cities to become garbage-free and eliminate waste sent to landfills. To advance this goal, the Solid Waste Management Rules 2024 (Draft) now place greater responsibility on Bulk Waste Generators (BWGs), introducing an Extended BWG Responsibility (EBWGR) framework.

The draft SWM Rules 2024, set to be implemented in October 2025, classify BWGs as institutional, residential, or commercial entities generating more than 100 kg of waste per day or consuming more than 5,000 litres of water daily, or covering 20,000 sqm or more. This expanded definition aims to bring more waste generators under the BWG category, helping cities track and manage waste effectively. However, under the earlier rule, where only those generating 100 kg/day were considered BWGs, urban local bodies (ULBs) found it challenging to identify and regulate them, as they rarely monitor waste generation per individual entity.

Larger ULBs, such as Gurugram and Agra, have attempted to map BWGs within their jurisdictions, but smaller cities lag behind. Gurugram reports 614 BWGs, while Agra claims 2,136. In contrast, Jaipur has only 108 BWGs, and Jodhpur reports a mere 4 BWGs. Some smaller ULBs, such as Nainital Nagar Palika and Kota, have only listed hospitality and educational institutions as significant waste generators, yet formal classification and compliance with BWG responsibilities remain uncertain. 

Under the SWM Rules 2014, BWGs were required to segregate waste at source, manage organic waste on their own, and hand over dry waste to authorized collectors or recyclers. The new SWM Rules 2024 now impose additional obligations, requiring BWGs not only to handle wet waste onsite but also to register on a centralized digital portal and file annual returns (by June 30th). If existing BWGs are unable to manage organic waste onsite due to space constraints, they must purchase credits from ULB operators or processing facilities as compensation for their share of waste management. Dry waste, special care waste, and sanitary waste must be collected and handed over exclusively to authorized agencies or local bodies.

The critical question remains—do BWGs, particularly in Tier 2 and Tier 3 cities, have the capacity to manage waste in a decentralized manner? Do ULBs have the necessary authorized agencies to assist BWGs? At present, ULBs are responsible only for special care waste and sanitary waste management, leaving other waste streams to be handled by BWGs themselves.

According to the Central Pollution Control Board (CPCB) Report 2021-22, urban India generates 170,339 tonnes of waste per day, of which 54% is processed, while 24% is disposed of. The question remains—are ULBs capable of identifying and registering BWGs on the digital portal? This is particularly challenging in cities with unauthorized areas, where ULBs struggle to collect property taxes from residents. Many smaller cities also have households with private borewells, making it difficult to track daily water consumption. Furthermore, the ‘Pay As You Throw’ principle is yet to be implemented in any ULB, as waste generation at the user level is not being monitored.

To effectively implement the EBWGR framework, ULBs will require substantial support for survey and audit agencies to conduct thorough mapping exercises, identify BWGs, facilitate registration on the digital portal, and establish a monitoring and service delivery plan to achieve garbage-free cities.

Another major question arises—what is this digital portal? If CPCB oversees monitoring, how will ULBs manage it at their level? India has faced integration challenges when digital portals created by one ministry are implemented across others. Why has CPCB not categorized BWGs as entities requiring consent to operate, similar to industrial units? Is the country’s regulatory body unprepared to take on such a significant monitoring task? If not, how will manpower-deficient ULBs—already struggling with limited resources—ensure the successful implementation of these new rules?

Are we prepared for this comprehensive and complex BWG responsibility, or is this merely another case of green washing, shifting responsibilities to private players? While the Polluter Pays Principle is a step towards sustainable development, the capacities and capabilities of stakeholders across all levels must be taken into account.

On a positive note, for EBWGR to succeed, governments must build the capacities of agencies that can serve as service providers for waste management at the BWG level. A few startups and NGOs currently operate in mega and metro cities, but similar enterprises must be encouraged in Tier 1 and Tier 2 cities as well. In addition to strengthening BWG support mechanisms, a strict monitoring and penalty system should be introduced.

In the long run, ULBs will benefit as BWGs handle organic waste at the source and achieve better source segregation, transforming waste into wealth. BWGs that still rely on ULBs for organic waste processing will need to purchase EBWGR credits, thereby reducing the financial burden on municipal bodies. However, the success of implementation will depend largely on political will, public cooperation, effective policies, and strong monitoring, review, and verification systems. Clearly, India needs more than just the Solid Waste Management Rules 2024—a robust framework for execution is equally crucial.

Sourabh Manuja is the co-founder of Global Green Envirosystems and a national solid waste management expert.

Tanya Rastogi is an Associate – SWM at Global Green Envirosystems.

Disclaimer:

The opinions and perspectives expressed in this article are solely those of the authors and do not necessarily reflect the views, policies, or positions of any organization or affiliated group.