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# India cannot build a critical mineral industry without upgrading informal scrap yards

4 Nov 2026·4 min read

Stefan de LindeFounder & CEO

India cannot secure domestic critical minerals for clean technology and electronics manufacturing without working directly with the informal scrap sector. End-of-life electronics hold high concentrations of copper, lithium, cobalt, and rare earths, yet the formal recycling system cannot access this material at scale. Over ninety percent of collected electronics moves through informal scrap aggregators who manage direct collection across households and businesses in every tier of the economy. Bypassing these grassroots collectors leaves domestic processing plants starved of feedstock. Unlocking India's critical raw material potential requires upgrading this informal foundation into verified processing.

#### The gap between registered capacity and ground reality

Official registries list 322 authorized e-waste processing units with an annual capacity of 2.2 million metric tonnes. That figure gives an illusion of operational readiness that conflicts with real plant activity. Most electronic scrap stays with over one million informal workers who dismantle hardware manually, as documented by the [Springs project](https://springs-rec.org/recycling-cultures-in-india/). Formal facilities struggle to secure physical inventory and often survive by purchasing paper compliance credits under extended producer responsibility regulations. Audits conducted by environmental authorities uncovered more than [600,000 fraudulent certificates](https://www.thehindu.com/sci-tech/energy-and-environment/6-lakh-fake-pollution-trading-certificates-unearthed-in-three-states/article68401068.ece) in plastic waste trading across multiple states. Trading administrative paperwork without auditing physical intake exposes e-waste systems to the exact same failure.

#### Mandatory traceability in global supply chains

International buyers and electronics brands face stricter corporate governance rules that make self-declared compliance impossible. The European Union Corporate Sustainability Due Diligence Directive and the Critical Raw Materials Act require manufacturers to prove that secondary metals come from lawful, ethical sources without double counting. Indian processors attempting to secure long-term purchase agreements or attract institutional capital cannot rely on informal receipts. Sourcing partners and investors require auditable digital proof showing where materials originated and validating physical recovery yields through mass-balance accounting.

#### Building verifiable aggregation hubs

Connecting informal collection to formal industrial demand requires setting up compliant aggregation hubs. These local hubs purchase scrap from informal collectors, record inventory upon delivery, and prepare sorted materials for advanced hydrometallurgical refiners. Facilities do not need heavy enterprise software to manage intake data. Accessible digital tools allow operators to calculate inbound scrap weights against separated material fractions quickly. Capturing physical data directly at the yard level converts undocumented scrap into traceable industrial feedstock.

#### How Minimise supports transparent operations

* Minimise equips facilities with lightweight mass-balance software to balance intake weights against recovered fractions
* Minimise logs scrap purchases from informal collectors at facility gates to generate verified digital records
* Minimise prevents duplicate compliance claims through batch-level material tracking
* Minimise produces audit-ready chain of custody records aligned with European due diligence regulations

#### Operational trials with E\[co\]work

We tested this operational approach in our ongoing project with E\[co\]work in New Delhi. The program trains informal sector workers on occupational safety, hazard control, and non-destructive dismantling methods. At the same time, the facility uses our data tools to record inbound deliveries and assign batch numbers to sorted components. This setup verifies physical mass balance during routine facility workflows. The [Council on Energy, Environment and Water](https://www.ceew.in/electrical-and-electronic-waste-recycling) provides additional analysis on why this operational integration is necessary for India's recycling infrastructure.

#### Presenting practical execution at WCEF

During the urban mining accelerator session at the World Circular Economy Forum in Gandhinagar, we presented these operational methods alongside Landbell GreenForest Solutions, GIZ India, and the Material Recycling Association of India. Recyclers, manufacturers, and regulators at the session showed strong interest in securing traceable domestic secondary minerals. The conceptual debate over the value of urban mining is settled. The current barrier is operational execution across regional yards, where facilities must replace paper documentation with verified mass-balance records.

#### Industry perspectives in EcoTech Talks

For further reading on India's critical mineral policy and secondary recovery, review the November 2026 special knowledge edition of EcoTech Talks published by H.M.E-Waste Management. You can access the publication and subscribe to future editions [here](www.hmegreen.com/Newsletter).