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EPR for Battery Waste

Transforming Producers and Recyclers responsibility

WASTE MANAGEMENT/POLLUTION - EPR For Battery Waste

Keeping Battery
Compliance Simple

Battery Waste Management Rules, 2022 was notified on August 24, 2022, which replaces the Batteries (Management and Handling) Rules, 2001 (which related only to lead acid batteries). These Rules extend to various types of batteries, including electric vehicle batteries, portable batteries, automotive batteries and industrial batteries.
Extended Producer Responsibility (EPR) is based on the principle of “Polluter Pays”.

EPR is a concept to promote environmental sustainability and ensure the responsible management of waste generated by products throughout their lifecycle. In India, EPR is primarily governed by the E-Waste (Management) Rules, 2022, the Plastic Waste Management Rules, 2016, the Battery Waste Management Rules, 2022, Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022. These rules are implemented by the Ministry of Environment, Forest and Climate Change (MoEF&CC) and regulated by the Central Pollution Control Board (CPCB) at the national level. State Pollution Control Board (SPCB) is the State-level body to implement EPR and monitor activities related to that.

Overview

The Battery Waste Management Rules obligates the “Producer” which includes an entity manufacturing or selling new and refurbished batteries or importing batteries including equipment comprising such batteries, to ensure environmentally friendly management of batteries. The 2022 Rules prohibit the Producer from disposing waste batteries in landfills and incinerators and instead the Producer is obligated to recycle, refurbish or re-purpose waste batteries. It provides for targets which a Producer has to meet in order to fulfil its EPR obligations.

The Producer also has an obligation to ensure a minimum set out quantity of recycled material in the manufactured battery. The Producer can engage any other entity for recycling or refurbishment, in order to meet its EPR obligations. Any entity engaged in recycling or refurbishing of batteries will be assigned an EPR certificates by the Central Pollution Control Board (CPCB) based on the recycled or refurbished quantity of waste. These entities can then sell the assigned EPR certificates to a Producer in exchange of waste batteries.

How
Mind Sync
Can Help?

Our dedicated team is here to assist you in navigating the complexities of waste management compliance for your business. With our expertise, we ensure a smooth and efficient process, from comprehending regulatory requirements to managing documentation and submissions. Our aim is to simplify the registration process, ultimately saving you valuable time and effort while ensuring compliance.

Registration with CPCB or SPCB

Producers
(Manufacturers & Importers)

All Producers (Manufacturers, Importer) are required to obtain registration from CPCB and to submit EPR Plan as well as Annual Returns.

Producer has the obligation of Extended Producer Responsibility (EPR) for the Battery that they introduce in the market. Producers have two ways to meet their EPR targets, either they bear the responsibility of managing battery waste or use the EPR certificate by acquiring surplus certificates from producers of the same battery category made available by recyclers or refurbishers.

Recyclers

Waste Battery Recyclers shall have to register with concerned SPCBs/PCCs under Battery Waste Management Rules, 2022.

Recycling of Waste Battery means recycling of Battery materials such as lead, nickel, lithium, nickel, cobalt, plastics, rubber, glass, etc.

QUICK ANSWERS

All types of batteries regardless of chemistry, shape, volume, weight, material composition and use.
  • Producer (Importers comes under the definition of Producer as per Rules)
  • Manufacturers of Battery
  • Recyclers and Refurbishers
EPR target is the quantity of battery placed in the market by the Producer/Manufacturers. Details are given in Schedule II of the Battery Waste Management Rules, 2022.
‘Producer’ means an entity who engages in:
  • manufacture and sale of Battery including refurbished Battery, including in equipment, under its own brand; or
  • sale of Battery including refurbished Battery, including in equipment, under its own brand produced by other manufacturers or suppliers;
  • import of Battery as well as equipment containing Battery.
Importers shall have EPR Obligations under the following conditions:
  • Importers who sale the imported battery in the market under their own brand name.
  • Importers supplying the imported battery to other manufactures/dealers and the manufacturers/dealers is selling those batteries in the market under the brand name provided by the importer.
  • Importers supplying the imported battery directly to bulk consumers.
  • Importers selling the imported battery in the market under the name of the brand imported.
Importers shall not have EPR obligations when importers supplying the imported battery to other manufactures/dealers and the manufacturers/dealers are selling those batteries in the market under their own brand name.
  • If the dealer purchases the battery from a manufacturer or a producer and sales the battery under its own brand name, in this case, the dealer will be called a Producer and will have to register with CPCB. The Dealer will also have EPR obligations as per rules.
  • If the dealer purchases or supplies the battery from manufacturer/s or a producer and sale them under the brand name provided by the manufacturer or producer, then the Dealer is not required to obtain CPCB or SPCB.
Central Pollution Control Board (CPCB) State Pollution Control
Board (SPCB)/Pollution Control Committee (PCC)

Do you have any queries?

This information is in summary form and is therefore intended for general guidance only. It is not intended to be a substitute for detailed research or the exercise of professional judgment. Mind Sync does not accept any responsibility for loss occasioned to any person acting or refraining from action as a result of any information provided herein. On any specific matter, reference should be made to the appropriate advisor.

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