STEEL SCRAP RECYCLING POLICY, 2019
PRIYADARSHINI VENKATESH & NAYANA JM
Students, School of Law, Christ (Deemed to be University)
The Ministry of Steel recently passed the Steel Scrap Recycling Policy of 2019 which promotes the establishment of Metal Scraping Centers in India which facilitate recycling of ferrous, non-ferrous and other non-metallic scraps. The vision of the Policy is to further the role envisaged in the National Steel Policy 2017 which aims to develop a globally competitive steel industry by creating 300 Million TPA Steel production capacity by 2030 with a contribution of 35-40% from EAF/IF route. The proposed policy imposes certain compliances like increased registration charges for private vehicles and increased fitness certification charges for transport vehicles to de-incentivise such vehicles.
Special Features of the Policy
Circular economy of steel sector – The primary feature of this policy is to promote the use and re-use of good quality scrap and a secondary source (primary source being iron ore). The use of one ton of scrap would save around 1.1 ton of iron ore, 630kg of coking coal and 55kg of limestone. It also reduces the water consumption and GHG emission by 40% and 58% respectively. In order to achieve the aim of the National Steel Policy, the level of steel scrap must be increased to 70 million tons by 2030. This would minimize the dependency of India on import of scrap and substitute the import of high end steel, making India self-sufficient in scrap availability.
6 R’s – The next feature is the promotion of the 6Rs which are Reduce, Reuse, Recycle, Recover, Redesign and Remanufacture. This is adopted to minimise the greenhouse gases and strengthen the foundation of sustainable development. This ensures the re-use of scrap as a main raw material which helps in the conservation of vital natural resources besides other benefits.
Scrap Processing Center and Collection and Dismantling Centers – The next feature is the guidelines provided for the establishment of Scrap Processing Center and Collection and Dismantling Centers. The dismantling facilities should be set up in a large area having adequate space for vehicular movement, storage for the products received and recyclable material so recovered. The materials should be handled by machine with minimum to create safe workplaces. Scrap Processing Center should ensure that the facility should have appropriate equipment and use the best available technology and manage such a facility in a safe and environmentally friendly manner with trained and competent manpower.
Shared Responsibility – The final and most important feature is the shared responsibility system which would enable the development of appropriate ecosystem in terms of setting up of Collection, Dismantling centers and Scrap processing centers, either by independent entrepreneurs or through Joint Ventures between Corporate entities and/or PSUs. The responsibility is shared among five stakeholders.
- Aggregators – Aggregators are entities, individuals, local scrap dealers and distributors facilitating the collection of end of life vehicles, white goods and other scraps. They segregate and sort the scraps in a safe and environmentally sound manner.
- Dismantling & Scrap Processing Centers (SCs) – The scrapping centre may develop facilities, to segregate the processed scrap, based on its composition or chemical analysis, which would facilitate the downstream industries with quality scraps.
- Government – The policy places a responsibility on the MOEF&CC to prepare a Standard Operating Procedures (SOP), codify and compile the procedures and clearances of all the Acts and Rules required for setting up collecting, dismantling and scrap centres and establish a Single Window Clearance System to ensure smoother and faster setting up of centers and promote Ease of Doing Business (EoDB). This has to be done within 3 months. Ministry of Road Transport & Highways (MoRTH) must formulate an Automobile Fitness Certification Policy to prevent plying of unfit and polluting vehicles. The collection, aggregator and/or dismantling centre will verify with the credentials of vehicles received for recycling with the Vahan Database (National Register e-services of registered vehicles).
- Manufacturers and Extended Producer Responsibility – The MoRTH and Department of Heavy Industry (DHI) work towards “Extended Producer Responsibility” by requiring the vehicle manufacturers to incentivize the owners of ELVs to voluntarily gives their vehicles for scrapping in exchange for price discounts for purchase of new vehicles. This will also provide for the required feed to the scrapping centres. The collection and dismantling center and scrap processing center must issue a Certificate of Destruction (COD) / Proof of scrappage to the owner of the End of Life Vehicle. The engine parts arising out of the end of life vehicles should be defaced, or drilled with 6” hole, by the scrapping centres, such that the same may not be reused in the secondary market.
- Owner of ELV and White goods – The owner must hand over for scrapping vehicles that do not meet the fitness criterion for the vehicles with the relevant documents. The Owner or white goods shall give a self-certified undertaking that he/she is the legitimate owner of the white good and provides his consent for its recycling. White goods include household appliances and large electrical goods such as refrigerators, washing machines, Ovens, Air Conditioners, stoves, cookers, etc.
Comparison between the Steel Scrap and Recycling Policy of 2019 and National Steel Policy 2005
To understand the various nuances of the Scrap Policy 2019, it is necessary to understand and compare it with the policy that preceded it, i.e., The National Steel Policy 2005. The policy was introduced in 2005, with a vision of ‘providing a roadmap for the efficient and productive growth of steel industry’. Due to passage of time and changing needs a new steel policy was introduced in 2017 (Steel Policy 2019), which aimed at ‘empowering steel industry to gain its full potential through a holistic inter-sectoral growth.’ And then, in 2019, the Scrap Policy came forward to make the Indian steel industry self-sufficient. 
The objectives of the National Steel Policy 2005 included:
- Prepare and implement an action plan for achieving the strategic goal of 110 mT of steel production by 2019-20, with separate plans for the growth of flats and long products.
- Prepare and implement road maps for technological and productivity improvements benchmarking them to global standards.
- Conduct reviews to remove infrastructural, procedural and institutional bottlenecks and to achieve policy coordination among central Ministries and State Governments.
- Provide a single-window clearance for large projects, to be followed by statutory clearances by the concerned ministries.
- Monitor the implementation of the National Steel Policy.
The objectives of the Scrap Policy 2019 includes:
- To promote circular economy in the steel sector
- To promote a formal and scientific collection, dismantling and processing activities for end of life products that are sources of recyclable (ferrous, non-ferrous and other non-metallic) scraps which will lead to resource conservation and energy savings and setting up of an environmentally sound management system for handling ferrous scrap.
- Processing and recycling of products in an organized, safe and environment friendly manner.
- To evolve a responsive ecosystem by involving all stakeholders.
- To promote 6R’s principles of Reduce, Reuse, Recycle, Recover, Redesign and Remanufacture through scientific handling, processing and disposal of all types of recyclable scraps including nonferrous scraps, through authorized centers/facility.
- To create a mechanism for treating waste streams and residues produced from dismantling and shredding facilities in compliance to Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 issued by MoEF & CC.
Use and treatment of Hazardous substances and waste
One of the primary objectives of the Policy is to ensure that the waste streams and residues which is produced from the dismantling and shredding facilities is treated in compliance with the Hazardous & Other Wastes (Management & Transboundary Movement ) Rules of 2016 and relevant health and safety regulations. The responsibility to reduce the use of hazardous substances and treatment of waste generated is two-fold. The responsibility of the Centers should promote a zero discharge system with a depollution system for processing the end of life goods and scraps. It shall also have storage for hazardous substances like batteries, PCB/PCT-containing condensers. In case they don’t have adequate facilities to recycle hazardous waste, it should be sold to authorized recyclers who have adequate capability through a government authorized e-commerce/auction portal. The responsibility of the automobile manufacturers is to ensure that the use of lead, mercury, cadmium and other hazardous materials and substances of concern should be avoided as they do not become a part of the residue and cause air and water pollution. Thus, the use of recycled materials in the new products should be promoted to keeping in mind the recyclability of the end of life vehicle. Manufacturers should also undertake responsibility to make adequate provisions relating to the classification, packaging, labeling and color scheme for dangerous substances
Impact on Environmental Principles
The centers deal with ferrous and nonferrous scraps, and ELVs which should produced hazardous waste impacting the environment. Thus, the Policy provides for the adoption of state-of-the-art environmentally friendly technologies. The centers should strictly adhere to the statutes and rules issued by the Ministry of Environment, Forest and Climate Change like Environment (Protection) Act, 1986, Water and Air (Prevention and Control of Pollution) Acts, Guidelines for environmentally sound management of ELVs, 2016 laid down by Central Pollution Control Board (CPCB)- AIS 219, Waste regulations notified by the Ministry of Environment Forest (MoEF&CC), as applicable for the management and recycling of ELVs, etc.
You may access the Notification issued by the Ministry of Steel here https://steel.gov.in/sites/default/files/213770.pdf3
Image attached sourced from Blomberg Quint
 Vehicle scrappage policy may bring in stricter fitness norms for pre-2005 built vehicles, The Economic Times,
 The Steel Scrap Policy: India’s Way To A Greener Tomorrow?, LexQuest, https://lexquest.in/the-steel-scrap-policy-indias-way-to-a-greener-tomorrow/#:~:targetText=In%202005%2C%20the%20much%20needed,growth%20of%20the%20steel%20industry.
 National Steel Policy 2005, https://steel.gov.in/sites/default/files/nspolicy2005.pdf
 The Scrap Policy 2019, The Gazette of India, https://steel.gov.in/sites/default/files/213770.pdf