THE POLICY EDGE
Expert Commentary

10 March 2026

Circular Economy Must Move Beyond Waste Regulation

Advisory action plans and waste rules cannot substitute for an integrated economic and governance framework

SDG 12: Responsible Consumption and Production | SDG 11: Sustainable Cities and Communities

Ministry of Environment, Forest and Climate Change MoEFCC | Ministry of Commerce and Industry MoCI

Views are personal.

India’s circular economy push has gathered visible momentum. Sector-specific waste rules have expanded in scope, Extended Producer Responsibility (EPR) regimes have been formalised, and policy institutions, including NITI Aayog, have articulated action plans across multiple material streams. The direction of travel is clear: resource efficiency is now firmly on the policy agenda.

Yet the architecture remains compliance-led. The system manages waste streams, but it does little to influence how materials are produced, used or reused in the first place. Circularity is treated largely as an environmental obligation – to be administered through rules, reporting portals and producer liabilities – rather than as an organising economic principle. The structural question, therefore, is not whether India supports circular economy in intent, but whether the present governance design can translate that intent into an integrated resource strategy.

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Fragmented Governance and Siloed Regulation

Over the past decade, India has built a dense regulatory landscape covering municipal solid waste, plastics, e-waste, batteries and other streams. EPR frameworks have clarified producer responsibilities, and digital portals have attempted to improve traceability. In principle, these measures extend accountability across product life cycles.

In practice, however, governance remains fragmented. Different waste streams are governed by separate rules and administrative silos. Enforcement capacity varies across states and municipalities and data reliability is uneven. Advisory action plans coexist with binding rules, but without a unifying statutory mechanism that aligns targets, incentives and monitoring across sectors.

This fragmentation produces a structural imbalance: end-of-life compliance is emphasised, while upstream design standards, recycled content mandates, durability requirements and repair incentives remain limited or inconsistent. Municipal bodies – tasked with implementation – face persistent financial and technical constraints. Meanwhile, the informal recycling sector, which recovers a substantial share of materials, remains only partially integrated into formal compliance systems.

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The Incentive Gap in Circular Governance

At the heart of this architecture lies an incentive gap.

EPR, while necessary, cannot by itself deliver systemic circularity. It assigns responsibility at the end-of-life stage. It does not automatically create markets for secondary materials, nor does it ensure upstream redesign. Without harmonised traceability standards and consistent enforcement across states, EPR risks functioning as a compliance marketplace rather than as a lever for systemic transformation.

Fiscal instruments, procurement policy and product standards remain only loosely connected to circular objectives. There are few cross-sector benchmarks for resource productivity, and limited coordination between environmental regulation and industrial policy. As a result, the system processes waste after it is generated, but does not sufficiently reshape how products are designed, manufactured and circulated in the first place.

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Why Circularity Is Now Economic Policy

The urgency of this shift is not environmental alone. India’s growth trajectory is materially intensive, placing sustained pressure on land, infrastructure and waste management systems. Urban land constraints, rising landfill burdens and pollution costs impose visible pressures. At the same time, strategic dependence on imported raw materials and critical minerals underscores the economic stakes of resource productivity.

As global supply chains reorganise around sustainability standards and traceability requirements, and material efficiency, industrial competitiveness increasingly intersects with circularity. Resource efficiency shapes cost resilience, manufacturing depth and access to export markets. Circular economy policy, in this context, is not only about waste reduction but about securing inputs, stabilising production and reducing exposure to external shocks.

Fragmented regulation is poorly suited to these challenges. Without institutional coherence, circularity remains disconnected from industrial strategy, fiscal architecture and centre–state coordination. The result is a gap between regulatory intent and economic outcomes.

From Initiative to Framework

Moving beyond waste regulation does not require dismantling existing rules. It requires embedding them within a unifying framework.

First, measurable national targets for resource productivity and material recovery could anchor policy direction across sectors. Second, EPR regimes across materials should be harmonised through common digital traceability standards and transparent enforcement mechanisms. Third, public procurement and fiscal instruments must be leveraged to create stable demand for recycled and refurbished products. Fourth, institutional coordination – across ministries and between the Union and states – must shift from consultation to structured alignment.

Such steps would signal that circularity is not an environmental add-on but a component of economic governance.

India has demonstrated regulatory initiative in advancing circular economy objectives. The next phase demands integration. The question is no longer the presence of circularity in policy discourse, but whether it is institutionalised as a coherent economic framework rather than a collection of well-intentioned waste rules. Waste can be regulated in fragments. Material transformation cannot.


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