Off the Books, On the Ground: What India’s C&D Recycling Rate Leaves Out
India's Construction and Demolition (C&D) Waste Management Rules complete ten years in 2026, and the timing could not have been more significant. A new set of rules, the Environment (C&D) Waste Management Rules 2025, enters into full force this year, introducing Extended Producer Responsibility (EPR) targets and digital compliance monitoring. Across the past decade, this policy architecture has looked well-equipped on paper: technical standards updated to permit recycled aggregates in concrete and roads, along with the local bodies required to use recycled C&D material in a share of government contracts. Yet India's official C&D recycling rate stands at roughly 5% of the 150 to 500 million tonnes of the total C&D waste that India annually produces as per the estimates of the Ministry of Housing and Urban Affairs (MoHUA).
The standard explanation, involving weak enforcement, low awareness, and poor infrastructure, accounts only for a fraction of that gap. But it seems to be missing something more fundamental: the 5% figure only measures what the formal system can see. What happens outside this system is a different story altogether.
What the Five Percent Doesn't Count
According to the 2016 Rules, state governments and local authorities are required to make the procurement of C&D waste-based materials mandatory for 10-20% of the materials used in all municipal and government contracts, subject to quality control. The 5% sits in contrast to this mandate.
The 5% figure reflects a specific conceptual boundary; it primarily accounts for materials that pass through authorised, formal processing facilities. This creates a significant measurement gap, as the official statistics are typically derived from data captured at formal weigh-bridges or through the reporting portals of registered recyclers.
In reality, a parallel circular economy is already operating upstream, much before waste is officially collected or hauled to a processing plant. High-value commodities are systematically salvaged at the source or during the demolition process itself as they possess immediate secondary market value. Furthermore, traditional regional practices often facilitate the in-situ reuse of intact materials like bricks and doors, which are diverted directly back into local construction projects.
Crucially, even the latest regulatory frameworks maintain this measurement gap: reusable or resalable materials are specifically not counted toward formal recycling targets, meaning that their recovery remains invisible to the official record. Consequently, while formal data ends up focused on the bulky rubble that cities struggle to manage, a vast network of informal actors is quietly closing material loops in the vital space between the waste generator and the formal municipal system.
Salvaged Before It's Waste
The generators actively engage in on-site salvaging. Demolition in the informal market is frequently treated as a commercial transaction. Contractors often pay building owners for the right to demolish, effectively buying the resale value of the steel and timber inside the building. Homeowners and developers alike hand material to informal salvagers to avoid the hassle of user fees and transportation charges mandated for formal municipal facilities. The formal system doesn't lose this material through leakage since it never receives it in the first place.
The Technology Information, Forecasting and Assessment Council (TIFAC) data helps frame the measurement gap honestly: metals account for roughly 5% and wood roughly 2%, totalling to 7% of total C&D waste by weight. This is a small fraction of the overall stream, but it carries the highest circularity value. In metropolitan cities with bigger markets and workforce, salvaged C&D materials from across the region flow into markets like Seelampur, where these high-value, reusable materials (such as steel rods, pipes, and fittings) are sorted and passed back into the supply chain. This system is clearly visible to everyone except the policy-measuring circularity.
Making the Invisible Count
India's 2025 C&D Rules introduce EPR targets and digital compliance portals, but both instruments are calibrated to formal processing plants. Closing the circularity gap requires two targeted changes to that architecture.
Firstly, expand EPR definitions to count upstream salvage intercepted before the rubble stage towards a project's circularity credits, and route scrap dealers’ transaction data into the 2025 Rules' digital portals. Second, recognise and protect the workforce doing this work: identity cards issued to salvagers convert informal workers from legally vulnerable scavengers into recognised service providers, providing access to occupational safety training and social security schemes. Pune's SWaCH cooperative shows this integration is possible in which the workers retained the rights to recyclables while the city handled residual waste. This shows that the model exists, all it needs is to travel from municipal solid waste to C&D.
Until it does, India's circularity metrics will keep measuring the 5% that the formal system processes while ignoring the upstream economy that already captures the most valuable fraction of the stream. And the workers powering that economy will remain the most circular actors in India's built environment, with the least protection to show for it.
Written By: Ritika Singh Thakur Edited by: Nilanjan Jha
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