EPR Registration for New Battery Waste Management Rules, 2022

With the advent of electronic vehicles and the rising use of electric batteries, the Ministry of Environment, Forest and Climate Change has issued a notification launching “Battery Waste Management Rules, 2022”. These rules replaced the Batteries (Management and Handling) Rules, 2001. What are the new rules about batteries and is EPR registration for battery waste mandatory?

Applicability of New Battery Waste Management Rules, 2022

All the producers, manufacturers, traders, dealers, consumers, assemblers and other establishments that are involved in the collection, segregation, reprocessing, transportation and recycling of waste batteries shall be governed by these rules. Extended Producer Responsibility (EPR) plays an important role in this regard. It places responsibility on the producers, including importers, for proper management of the waste products. In the case of battery waste management, EPR holds producers and importers responsible for refurbishing, recycling and collection of waste batteries.

What are Waste Batteries?

The Battery Waste Management Rules, 2022 broadly lays down as to what should be included in waste batteries. Following are the batteries that should be categorised as waste batteries:

1. End of life or used batteries including their hazardous and non-hazardous components;
2. Discarded batteries;
3. Batteries that are diverted at the time of manufacturing process.

It includes all the categories of batteries like electric vehicle batteries, automotive batteries, portable batteries and industrial batteries.

Key Highlights of the New Battery Waste Management Rules

Following are the EPR responsibilities under battery waste management rules, 2022:

1. As per the provisions and EPR rules, all the waste batteries are required to be collected and must be sent for recycling. Disposal of batteries in incineration or landfills is prohibited. 
2. Producers can delegate their EPR responsibilities and activities relating to waste battery recycling, collection or refurbishment to other entities.
3. The EPR certificates can be exchanged through the online portal between the producers, refurbishers and recyclers so that they can fulfill the necessary producers’ obligations. 
4. The new rules require a minimum % of recovery of certain materials from the waste batteries. This will lead to technological advancements and will open up newer business opportunities.
5. The new Battery Waste Management Rules encourages new entrepreneurs and industrialists in the collection, refurbishing and recycling of waste batteries.
6. Environmental compensation shall be imposed in case of failure to meet the obligations and EPR targets. This is in line with the Polluter Pay Principle.

Effects of EPR for Battery Waste Management Rules

The following are the notable effects of EPR for battery waste management rules:

• Extended Producer Responsibility

The new battery waste management rules have placed responsibility on the producers for the purpose of making arrangements for the restoration, collection and recycling of the used batteries. The EPR targets vary according to the type of batteries including lead-acid batteries, lithium-ion batteries etc. Further, the act also requires a certain minimal use of recycled battery components like nickel, lithium and cobalt for producing new batteries.

• Battery Swapping Policies

Our finance minister Nirmala Sitharaman presented a future strategy in the Budget 2023 for batteries used in the electric vehicles. The introduction of battery swap policy encouraged the private sector for sustainable development. It promoted the ‘Battery as a Service’ model that not only enhanced the usage of electric vehicles but also fostered a beneficial and sustainable ecosystem. This policy was introduced keeping in mind the lack of space in the urban areas for meeting the charging needs of electric vehicles.

• Centralised Online Portal for Management of Battery Waste

In order to standardise and ensure effective implementation of the battery waste management rules in India, the CPCB (Central Pollution Control Board) has implemented a centralised portal for the purpose of registration and submission of the battery waste returns. This portal will also facilitate the generation and exchange of EPR certification by recyclers, producers and refurbishers.

• Labelling Requirements

1. The producers are required to follow the guidelines of the Bureau of Indian Standards (BIS) for all the batteries and packs.
2. Batteries that contain heavy metals like cadmium (Cd), mercury (Hg) or lead (Pb) should be marked along with their respective symbols.
3. All the labels and symbols should be printed in visible, indelible and legible form. 

EPR Compliances for Waste Battery

Following are some of the key responsibilities placed on the producers, manufacturers, importers and refurbishers:

1. The producer that introduces the batteries in the market is primarily responsible to ensure the fulfillment of EPR responsibilites of refurbishing and recycling of the batteries. He shall comply with the Schedule II of this act for collection, recycling and refurbishing targets.
2. The waste batteries should be sent for refurbishment or recycling and not incineration. The producers shall register themselves by filing Form 1(A) with the CPCB. They will receive the EPR registration certificate in Form 1(B).
3. Producers shall intimate the necessary information in case of any change in the EPR registration particulars. 
4. EPR plan in Form 1(C) should be submitted to the CPCB by 30th June each year for the batteries that were manufactured in the previous year.
5. The producer shall be responsible for adhering to all the labelling and prohibition requirements.
6. Producers should also ensure that the new batteries contain a minimum % of domestically recycled materials.

In a Nutshell

The new Battery Waste Management Rules, 2022 is an environmentally friendly and key legislation to ensure that we move from oil to electric in a sustainable and eco-friendly manner. By placing EPR registration for battery waste requirements, it ensures that those dealing with electric batteries ensure proper environmentally friendly behaviour. Producers, recyclers as well as refurbishers need to ensure that they adhere to all the EPR compliances for battery waste. In case you need any assistance in relation to battery waste EPR registration and compliances, feel free to contact the ASC Group. 

Also Read:

EPR Registration Rules for Plastic Waste Management

New Rules for EPR E-waste Management 2022-23

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