The Illusion Of Circularity: Rethinking Extended Producer Responsibility In India's E- Waste Governance

Extended Producer Responsibility (EPR) has become the foundation of India's e-waste management and is often depicted as a crucial tool for promoting circular economy goals. India has implemented a digitally centralized, target-oriented, and certificate-based Extended Producer Responsibility (EPR) framework through consecutive legislative reforms, including the E-Waste (Management) Rules, 2022, aimed at improving producer accountability and resource recovery. This article critically examines whether India's Extended Producer Responsibility (EPR) framework functions as a revolutionary mechanism for a circular economy or primarily as a compliance-driven system focused on downstream waste management. This paper assesses the development, implementation, and institutional framework of Extended Producer Responsibility (EPR) in India through a doctrinal legal analysis and a governance-oriented evaluation of the country's e-waste regulatory structure. It contends that although India's Extended Producer Responsibility framework has excelled in agenda-setting, formalization, and regulatory monitoring, these accomplishments are predominantly normative rather than substantive. Ongoing deficiencies in enforcement, insufficient upstream engagement in product design, inadequate incorporation of the informal sector, and disjointed institutional coordination indicate a more profound governance issue. The objectives of the circular economy are formally integrated into the legislative framework; yet, operational practices still prioritize target achievement, documentation, and certificate trading over systemic reform. The paper defines this disjunction as an "illusion of circularity," in which legal frameworks and language imply circular progress, while actual material flows and industrial systems are inherently linear. By reconceptualizing Extended Producer Responsibility (EPR) as a governance mechanism rather than a mere compliance instrument, the study enhances discussions on environmental regulation in the Global South. It highlights the inherent limitations of target-oriented regulatory frameworks in achieving substantial outcomes in the circular economy.