Illegal E-Waste Recycling Units: How to Report Them

Under the E-Waste (Management) Rules, 2022, only recyclers and refurbishers registered on the CPCB's portal and holding consent from the State Pollution Control Board may dismantle, refurbish or recycle e-waste. A unit that strips circuit boards in acid, burns cables to recover copper, breaks monitors or dumps residues in a drain, without registration and consent, is operating illegally. Report it in writing to the State Board's regional office (DPCC in Delhi) with dated photos and the address, copy the municipal body and the District Magistrate, and bring in the police, fire department or labour department where there is a safety or child labour angle.

This guide is for residents who suspect that a house, godown or shed nearby is being used to break down electronics, and for businesses and landlords who want to make sure they are not part of the problem. It covers the legal position, the warning signs, who to report to, how to do it safely and what usually happens next.

Companies with obligations as producers should also read EPR certificates and target shortfall, because certificates from doubtful recyclers can be cancelled. For the rules on lawful refurbishing and collection, see e-waste rules for refurbishers and collection centres.

The essentials

What makes an e-waste recycling unit illegal?

The E-Waste (Management) Rules, 2022, which came into force in April 2023, set up a closed system. Manufacturers, producers, refurbishers and recyclers register on the CPCB's centralised portal. Recyclers, who dismantle and process e-waste to recover materials, must also hold consent to establish and operate from the State Pollution Control Board and work to the standards and guidelines the CPCB prescribes. Anyone outside that system who breaks down discarded electronics for profit is operating illegally.

Repair is different. A mobile or computer repair shop that fixes devices and hands its scrap to a registered channel is not an illegal recycler. Nor is a kabadiwala who collects old appliances and sells them on to a registered recycler. The line is crossed when someone starts dismantling, extracting metals or disposing of residues without registration, consent and proper facilities, which is what informal units do.

Illegality usually comes in layers. The same unit that lacks registration also tends to lack consent, operate from a residential or non-conforming plot, store acids without safety measures, employ workers without protection and sometimes children, and dump residues into drains or onto vacant land. That is useful for anyone reporting it, because several authorities each have a reason to act.

Signs of illegal e-waste processing in your area

The most visible sign is burning. Cables and wires are burnt to remove insulation and get at the copper, producing thick black smoke and a smell of burning plastic, often at night or early morning on open plots, drain banks or rooftops. Circuit boards may be heated over open flames to remove components. Ash and half-burnt wire left behind are tell-tale.

Acid work is less visible but more dangerous. Gold, silver and copper are recovered from circuit boards by soaking them in strong acids in plastic tubs, often inside rented rooms with the windows covered. Neighbours notice choking fumes, a yellow or reddish haze, green or blue water in the drain, corroded metal grilles and dead plants. Drums and jerry cans of acid carried in at odd hours are another sign.

Other signs include heaps of broken monitors, televisions and computer casings; sacks of circuit boards; children or workers sorting components by hand in a lane; tempos unloading at night; and fluorescent tubes or batteries being broken open. One sign alone may be innocent. Several together, around the same premises, are worth reporting.

Common illegal e-waste activities and the harm they cause

What lawful e-waste recycling looks like

It helps to know what a legitimate recycler looks like, because the difference is usually obvious. A registered recycler operates from an industrial plot with State Board consent, inside closed sheds with impervious floors. Devices are dismantled with hand tools and machines at workstations, and parts are sorted into marked bins: plastics, metals, circuit boards, glass, batteries, lamps. Hazardous parts are stored separately and sent to authorised facilities, and residues go to a treatment, storage and disposal facility with a manifest.

Metal recovery from circuit boards, where it happens at all, is done in controlled plants with fume collection and effluent treatment, not in plastic tubs in a back room. There is no open burning. Workers wear protective equipment. The unit keeps records of what comes in and goes out, files returns, and can be checked against the CPCB's register. If what you see near your home looks nothing like this, and especially if it happens in a house or a shed behind one, you are almost certainly looking at an illegal unit.

Lawful collection points and refurbishers are a separate category again. They gather and repair devices but do not dismantle for metal recovery, and they must pass what they cannot repair to registered recyclers.

The health and environmental harm

Electronics contain lead, mercury, cadmium, brominated flame retardants and other substances that are fairly safe while the device is intact and harmful when it is burnt, crushed or dissolved. Burning cables and plastic casings releases toxic smoke; acid baths release fumes and leave metal-laden liquid that ends up in drains, soil and eventually groundwater. Workers, often without gloves or masks, take the heaviest dose, followed by families living in the same building or lane.

Contamination outlasts the unit. Soil around long-running informal sites can carry metals for years, and drains that receive acid waste carry it to ponds, fields and rivers. That is one reason boards and the tribunal are interested even in small units, and why residents should not wait for visible illness before reporting. Our guide on proving groundwater contamination from industry explains how longer-term damage is investigated.

Who should you report illegal e-waste recycling to?

Start with the State Pollution Control Board, through its regional office for your district. In Delhi that is the DPCC; in Uttar Pradesh the UPPCB; in Haryana the HSPCB. The board enforces the E-Waste Rules within the state and has the power to inspect, seize material, order closure and have electricity and water disconnected. Send a copy to the CPCB, which runs the national registration system and can check whether the unit claims to be registered.

The municipal body or development authority deals with the misuse of residential or non-conforming premises for industrial work and can seal the property. The fire department can act on storage of acids, plastics and lithium batteries that create a fire risk. The police can act on immediate dangers, on theft where stolen cable or equipment is involved, and on noise at night. If children are working at the unit, the labour department and the police should be told; employing children in hazardous processes is a serious offence in its own right.

The SDM can order removal of a public nuisance under section 152 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which suits a case where smoke and fumes affect a whole locality. And under section 19 of the EP Act, a citizen can complain to a criminal court after giving at least 60 days' notice to the board or government. Most residents will not need to go that far, but sending the notice puts the authorities on formal record.

Evidence that makes a complaint work

How to report an illegal e-waste unit

Reporting safely

People who run illegal e-waste units are sometimes local and well connected, and residents worry about confrontation. Keep your involvement to observation and paperwork. Take photos from your own property or the street, do not trespass, do not handle materials, and do not argue with the workers or owner. Your complaint should describe facts, not accuse anyone of crimes you cannot prove.

If you are worried about being identified, a complaint signed by an RWA, a group of neighbours or a local organisation spreads the risk. Anonymous complaints can trigger an inspection, but they are harder to follow up and cannot be used to show the authorities were told. If you face threats, report them to the police in writing at once.

What happens after a complaint

If the board inspects and finds an illegal unit, the usual sequence is a seizure of e-waste and chemicals, a closure direction under section 5 of the EP Act or the Water and Air Acts, and a request to the electricity company to disconnect supply. Environmental compensation may be levied under the board's formula-based method. The municipal body may seal the premises. After the Jan Vishwas (Amendment of Provisions) Act, 2023, many contraventions lead to monetary penalties through an adjudicating officer, while matters such as theft, child labour or fire endanger lives and remain for the police and courts.

The commonest problem is that illegal units move. A unit closed in one lane reopens a few streets away, sometimes within weeks. When reporting a reopened unit, cite the earlier complaint and inspection and ask the board to link the cases, so that the second action is not treated as a fresh first offence.

In e-waste complaints that Advocate B.K. Singh has handled for residents, the cases that moved fastest were the ones where the board and the municipal body acted together, with the property sealed as well as disconnected. A closure order on paper, with the owner free to reconnect power through another meter, achieves very little.

Landlords and building owners

Many illegal units operate from rented rooms, basements and godowns, and the landlord is often the easiest person for the authorities to find. Letting premises for a use that is plainly illegal can expose the owner to sealing, compensation claims and a role in any tribunal case, even if the rent agreement describes the use as storage. Check what tenants are actually doing, and act on complaints from neighbours promptly.

If your premises have been sealed because of a tenant's e-waste work, the route back usually involves removing all material through authorised channels, terminating the tenancy, and applying to the board and the municipal body with proof. Our guide on hazardous waste dumping covers clean-up where residues have been left behind.

Businesses: make sure you are not feeding the illegal trade

Informal units survive on supply. A large share of that supply comes from offices, institutions and shops that auction old computers, servers, cables and appliances to the highest bidder without asking where they go. The 2022 Rules require bulk consumers to hand over their e-waste only to a registered producer, refurbisher or recycler. Selling it to an unregistered scrap dealer is a breach of that duty, and the trail can lead back to you if the material turns up at an illegal site.

Practical steps are simple: check the buyer's registration on the portal and its consent, get a receipt that records quantities and destination, keep the records, and include e-waste in your environmental compliance audits. Producers should apply the same scrutiny to recyclers supplying their EPR certificates. Our page on e-waste EPR for producers and the guide on e-waste EPR for importers explain the producer side.

When the NGT is the right forum

A single unit is usually best handled through the board, the municipal body and the police. The NGT becomes the right forum when the authorities do not act despite complaints, when units keep reopening, or when a whole area has become a cluster for informal processing with drains, soil and groundwater affected. Such disputes raise substantial questions under the EP Act and its rules, the Water Act and the Air Act, so the tribunal can hear them under section 14 of the NGT Act, generally within six months of the cause of action first arising, with continuing violations often giving a fresh cause.

The tribunal commonly asks a joint committee to inspect and report, then directs the authorities to close illegal units, clean up contaminated sites, and monitor the area, with compensation under the polluter pays principle. Claims for damage to health or property fall under section 15, with a five-year limit. Our guide on how to file a case in the NGT explains the process, and our pollution complaint team can help prepare the complaint record that makes such a case strong.

Before you report

Related guides

Old batteries are often handled by the same informal networks; see lead-acid battery recycling pollution. For residues and industrial waste more generally, see our page on hazardous waste authorisation.