Bridging the gap: The role of the informal waste sector in EPR systems

Extended Producer Responsibility is a policy that, to be effective, needs to extend across the world. Very often, when we talk about sustainability, the circular economy, or environmental policies, we do so from a Eurocentric point of view. Since the challenges that made EPR urgent are global, solutions must be adaptable to every context.

Informal collectors are a crucial part of waste management in many countries, especially in the developing world. It is estimated that there is approximately one waste picker for every 250 citizens in Latin America, Africa, and Asia. So, when talking about the circular economy, the informal waste sector is a topic of major importance.

Who is the informal waste sector?

When individuals, families, or small companies are not linked to governments, recycling facilities, or Producer Responsibility Organizations, we are talking about informal collectors. They operate at every step of the waste management chain, though they are most heavily involved in collection.It is estimated that 60% of the world’s recyclable materials are collected by waste pickers, with even higher percentages in emerging markets. For example, Indonesia alone has approximately 1.3 million informal waste pickers. Overall, about 20 million waste pickers operate in the 150 countries lacking EPR regulations.There are two main streams of work:

Recyclable collectors: These workers collect recyclable materials directly from households, bulk waste generators, or other establishments. They sell the materials they collect to junk shops as a primary source of income and/or directly to formal recycling facilities.

Material pickers: These workers pick up recyclable waste from streets or open dumps rather than collecting it directly from the source. Picking waste material is very labour-intensive and dangerous, particularly at open dumps. In many countries, it is forbidden to enter landfills to collect recyclables.

In some cases, these collectors are professional or semi-professional self-employed workers who may form cooperatives to better organize their work. However, there are also vulnerable people who end up working in the informal waste sector because it offers an opportunity to make a living. This includes groups such as the elderly or unemployed. In some countries, women have limited job opportunities and often work in the informal waste sector, frequently under more precarious conditions than men.

The missed opportunity: Current disconnect between EPR systems and informal actors

When implementing EPR in a country, it’s crucial to understand the context. If policies are adapted to each country’s specific circumstances, their chances of success will be much higher. Among the factors to take into account, the extent and situation of informal collectors is one of the most decisive.

It can seem intuitive not to include the informal sector, since there is a potential negative impact. Informal “downstream” operations such as recycling and treatment of waste often use crude processes that are not environmentally sound and can also be dangerous for the workers.

But at the same time, discarding the involvement of informal collectors in EPR policy altogether can have regrettable consequences of its own. For example, when the informal sector is not considered, recycling rates can actually get worse. While in high-income countries the proportion of waste collected for recycling is rising in line with GDP growth, this is not the case in many low- and middle-income countries. One of the main reasons for this inverse correlation is reliance on the informal sector.

As countries and cities develop, the average cost of living increases, and collecting and selling, for example, PET bottles in the informal sector ceases to be economical. This forces workers to move on to other trades and jobs, which reduces the number of workers in informal waste management and pushes down the recycling rate. Unless this cycle is addressed, it can pose a real problem for the transition to sustainable waste management.

In addition, informal collectors are usually familiar with the types of waste common in their area, or with which businesses discard WEEE products, and they are experienced in handling materials. Excluding them is a waste of knowledge and leads to a significant loss of expertise and professional experience.

There is also a strong social component. On the one hand, informal collectors impact their communities economically and help raise awareness about waste management. On the other hand, as explained, workers in the informal sector are often in vulnerable situations: they lack legal working status and are exposed to hazardous substances without adequate protection.

Benefits of integration

Integration of the informal waste sector into EPR national systems would provide multiple advantages for both parties, and the collective of the local population:

For producers and PROs

Cost savings: Informal collectors already recover large volumes of recyclable material. By building on this existing system, PROs can reduce collection and sorting costs rather than creating new structures from scratch.
Local access: Informal workers have deep knowledge of waste flows, knowing which businesses, households, or streets yield specific recyclables. Their involvement can improve efficiency and ensure access to materials that would otherwise remain outside formal systems.
Community goodwill: Partnering with local collectors and cooperatives can increase public trust in EPR systems and avoid conflicts like those seen when foreign contractors displaced local pickers in Cairo.

For governments

Improved data: Formal agreements with waste picker organisations provide reliable data on volumes collected and recycled, which helps track compliance with EPR targets.
Recycling targets: Since waste pickers collect the majority of recyclables in many countries, their inclusion is key to achieving national recycling goals and avoiding gaps in material recovery.
Social equity: Recognition and integration of waste pickers into legal frameworks support a just transition, reduce vulnerability, and contribute to poverty alleviation.

For informal workers

Formal recognition: Integration provides legal identity cards, access to tenders, and protection from harassment, giving waste pickers recognition as legitimate service providers.
Stable income: Cooperatives and formal contracts reduce income volatility, ensuring regular payments instead of depending solely on fluctuating market prices.
Improved conditions: Workers gain access to protective equipment, training, social security, and better infrastructure, reducing health risks and improving living standards.

Key barriers to integration

Despite these benefits, integration is far from straightforward.

Legal exclusion or regulatory ambiguity: In many countries, informal workers are not recognised in waste legislation, making it difficult for them to participate in EPR schemes or compete for contracts.
Mistrust between formal and informal sectors: Waste pickers often fear losing autonomy or facing higher taxes, while PROs may hesitate to rely on actors perceived as unreliable or unsafe.
Lack of infrastructure and low bargaining power: Informal workers generally lack access to proper sorting facilities, vehicles, or safety equipment, which keeps them at a disadvantage in negotiations with PROs or municipalities.

The hidden cost of e-waste: Health, environment, and informal workers

The use of electrical and electronic equipment has grown exponentially in recent decades. Consequently, so has e-waste. Every year, the world produces around 44.7 million metric tonnes of e-waste.

Before the implementation of EPR regulations, much of this discarded equipment was exported to developing countries in Asia and Africa. Today, this practice is forbidden in many countries, but large amounts of waste still remain in massive landfills. Locally generated e-waste often ends up in the same places.

Agbogbloshie, in Ghana, is the world’s largest e-waste dump. People from across the country, and from neighboring Nigeria, travel to the town that has grown around the landfill. They collect e-waste from homes and businesses in Ghana, dismantle the equipment themselves, and resell the valuable materials contained in WEEE (gold, copper, aluminum, brass, etc.).

Unsafe e-waste recycling practices can release up to 1,000 toxic chemicals into the environment, contaminating the air, soil, and water, and entering the food chain. The hazardous fumes generated by these activities can travel significant distances, affecting even far-off communities.

Each year, improper disposal of electronic waste is estimated to release around 58,000 kg of mercury and 45 million kg of plastics containing brominated flame retardants into the environment. Informal e-waste workers frequently dismantle electronics on roadsides and riverbanks, exposing nearby areas, and themselves, to toxic substances. These rudimentary recycling methods are a major driver of environmental pollution and ecosystem degradation.

This is one of the reasons why EPR is especially important for WEEE and batteries, and why compliance is mandatory for producers of these products. The environmental and human impact of e-waste is unparalleled and will continue to grow unless producers, governments, and consumers make a joint effort toward circularity and sustainability.

Various local organizations and international NGOs have worked, and continue working, to improve the working conditions of informal WEEE collectors. Targeted education, adequate equipment, and better facilities are necessary for the informal waste sector to manage e-waste in a safe and sustainable way.

Examples of how different countries include informal collectors in their EPR system

Country	Legal / Policy Hook	How Inclusion Works	Benefits / Compensation	Example PRO / Initiative	Key Sources
South Africa	EPR Regulations under NEM:WA (2020)	PROs must integrate reclaimers into collection & reporting	PPE, training, buy-back support, improved pricing	PETCO (works with buy-back centres & reclaimer co-ops)	Govt Gazette – EPR Regulations (2020) DFFE – EPR Regulations & Registration PETCO – Buy-back centres
Chile	Ley REP (Law 20.920)	Certification of “recicladores de base” and inclusion in sistemas de gestión	Training, formal contracts, social benefits	Certified reciclador organisations contracted by compliance schemes	Ministerio del Medio Ambiente – Ley REP IEA Policy Profile – Ley REP
Brazil	PNRS (Law 12.305/2010) + Packaging Sectoral Agreement	Catadores & co-ops recognised as EPR actors and partners	Direct contracts, subsidies, equipment support	MNCR & municipal catador co-ops integrated with PROs	Packaging: Lei nº 12.305/2010 – PNRS Decreto nº 10.936/2022 – Regulamenta PNRS Informal sector: MNCR (Movimento Nacional dos Catadores)
Colombia	Decree 596/2016 + Resolution 1407/2018	“Recicladores de oficio” recognised as service providers; PROs coordinate with them	Tariff-based payments, registration, training	Recycler organisations participating in PAPGAREE compliance plans	Decreto 596 de 2016 – Normograma IGAC Resolución 1407 de 2018 – MinAmbiente (PDF)
Kenya	Sustainable Waste Management Act (2022) + PRO guidance	Informal pickers mapped/registered and supported by EPR schemes	PPE, training, price transparency, compensation	PETCO Kenya (collector training & price support); WEEE Centre	Sustainable Waste Management Act, No. 31 of 2022 (HTML) Official PDF – Act 31/2022 PAKPRO – Packaging PRO (Kenya) KEPRO – Extended PRO (Kenya) The WEEE Centre (Kenya)
Philippines	Republic Act 11898 (2022) + IRR (2023)	Partnerships with informal waste recovery sector count as compliant recovery	PPE, income opportunities, inclusion in collection initiatives	PROs partnering with junkshops & informal collectors	Republic Act 11898 – EPR Law (2022) DAO 2023-02 – EPR IRR (DENR, PDF)
India	E-Waste (Management) Rules (2016, amended 2022)	PROs and producers must channel e-waste through authorised recyclers; informal aggregators subcontracted for collection	Training, buy-back channels, integration into logistics	Karo Sambhav; Toxics Link	E-Waste (Management) Rules, 2022 – CPCB (PDF) Karo Sambhav – Resources
Ghana	Hazardous and Electronic Waste Control & Management Act (2016, Act 917)	Informal collectors integrated via training, registration and NGO/PRO support	PPE, safer practices, health services, income support	HP–GIZ Agbogbloshie pilot; City Waste Recycling partnerships	Act 917 (2016) – FAOLEX (PDF) IEA Policy Profile – Act 917 GIZ – E-Waste Project Ghana GIZ – Incentive Based Collection (PDF)
Nigeria	EPR Framework for Electrical/Electronic Sector (2019)	PROs integrate informal collectors through hubs and aggregator networks	Capacity building, PPE, purchase of e-waste	EPRON Nigeria (works with informal collectors & collection hubs)	NESREA – Laws & Regulations (EPR Framework) EPRON Nigeria – Official site

Towards inclusive circular systems

The success of Extended Producer Responsibility depends not only on financing and infrastructure, but also on people. In many countries, informal workers are fundamental for the process of collection and recycling waste. Ignoring them can jeopardize recycling rates, waste local expertise, and aggravate social inequalities. But if they are included, countries and local communities can accelerate the transition to sustainable waste management while ensuring that no one is left behind.

The way forward is for governments, producers, and Producer Responsibility Organisations to treat informal workers as partners, not outsiders. Trust, fair rules, and better working conditions can turn today’s disconnect into a shared opportunity. If done right, EPR is more than a policy instrument, it becomes a force for circularity and social justice alike.

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