EPR for Battery waste

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What is EPR for Battery waste?

EPR for battery waste means extended producer responsibility of a producer for management of battery waste in such a manner to protect human health and environment against any adverse effect, which may result from any substance contained in waste Battery.

Battery waste ( Management ) Rules 2022 cast obligation on producers through EPR which requires all waste batteries to be collected and sent for recycling, refurbishing and its prohibits disposal in land fields & incineration. To meet the EPR obligation a producer may engage themselves or authorise any other entity for collection, recycling or refurbishment of waste batteries.

*Recycling – Recycling means recycling of battery materials such as lead, nickel, lithium, cobalt, plastic, rubber, glass, etc.

*Refurbishment – Refurbishment means repairing, re-conditioning, re-purposing of used Battery for its second life.

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*Recycling – Recycling means recycling of battery materials such as lead, nickel, lithium, cobalt, plastic, rubber, glass, etc.

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*Refurbishment – Refurbishment means repairing, re-conditioning, re-purposing of used Battery for its second life.

What does battery waste mean?

The term batteries wastes includes

Used and / or end of life battery and / or its components or spare or parts or consumables.(*Here end of life battery means which have been used, completed its intended use and is not meant for refurbishment.)
Pre –consumer off-spec Battery and its components or spares or parts or consumables,
Battery whose date of appropriate use has expired
Battery which have been discarded by the user

What are the types of batteries as per Batteries waste (Management) Rules?

Battery waste (management) covers all types of batteries and classified into four major category

Automotive battery: – It means any battery used only for automotive starter, lighting, or ignition power.
Electrical Vehicle battery:- It means any battery specifically designed to provide traction to hybrid and electric vehicles for road transport
Industrial battery: – It means any battery which has been designed for industrial uses, excluding Portable batteries, Electrical Vehicle batteries, and automotive batteries. These may include sealed batteries (excluding portable batteries), unsealed batteries (excluding automotive Battery), and energy storage system battery
Portable battery: – It means a battery that is sealed, less than five kilograms not made for industrial purpose, electrical vehicles or to be use as an automotive battery.

Which type of batteries are covered under EPR obligation?

As per Battery waste (Management) Rules, under EPR obligation all types of batteries has been covered irrespective of its chemistry, shape, volume, weight, material composition and use.

Who is required to obtain EPR registration??

Every producer is required to obtain the EPR authorisation from Central pollution control Board (CPCB).

How much application / Annual processing fee for EPR registration for battery waste?

The application / Annual processing fees are as follows

SL. No.	Annual Turnover	Application fee
1.	Less than Rs. 5 Cr.	Rs.10000
2.	Rs.5 Cr.to 50 Cr.	Rs.20000
3.	More than Rs. 50 Cr.	Rs.40000

Who is producer as per Battery waste (Management) Rule?

Producer means any 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 manufacture or suppliers or,
Import of battery as well as equipment containing battery.

procedure for Licence

What is the obligation of producer?

Following are the responsibility of producer as per Battery waste (Management) Rules

Producer shall have the obligation of extended producer responsibility for battery that they introduce in the market to ensure the attainment of the recycling or refurbishing obligation.
Producer shall meet the collection and recycling and / or refurbishment targets as mentioned in schedule II for battery made available in the market.
Producer shall provide extended producer Responsibility plan in the Form 1C to central pollution control Board by 30^th June of every year for the battery manufactured in the preceding financial year.
Producer shall file annual return in Form -3 regarding the waste battery collected and recycled or refurbished towards fulfilling obligation under Extended producer responsibility with the CPCB and concerned State pollution control Board in Form 3 by 30 the June of the Next financial year . The details of the registered recycler from whom the extended producer Responsibility certificates have been procured shall also be provided.

Whether a producer may authorised any entity on its behalf to meet the obligation of EPR?

In order to meet the obligation of EPR, The producer may engage itself or authorise any other entity for collection, recycling or refurbishment of waste battery. However the obligation of meeting the EPR Targets shall remain with the producer.

Whether there is any obligation for producers to use domestically recycled material in a new battery?

As per Battery waste (Management) Rules 2022, producer shall have the obligation with respect to minimum use of domestically recycled materials in new battery .the assessment of the minimum use of recycled materials in Battery shall be in respect of the total dry weight of battery. In case of imported battery, the producer shall have to meet the obligation of the minimum use by way of getting such quantity of recycled materials utilised by other businesses or by way of exporting such quantity of recycled materials.

Following targets has been set for minimum use of domestically recycled material in new battery :

SL. NO	Type of Battery	Minimum use of the recycled materials out of total dry weight of a Battery ( In percentage )
		2027-28	2028-29	2029-30	2030-31 and onwards
1.	Portable	5%	10%	15%	20%
2.	Electrical Vehicle	5%	10%	15%	20%
		2024-25	2025-26	2026-27	2027-28 and onwards
3.	Automobile	35%	35%	40%	40%
4.	Industrial	35%	35%	40%	40%

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What is labeling requirements on battery by a producer?

As per schedule I of plastic waste (management) Rules 2022

Producer shall ensure that all Battery or Battery packs are appropriately marked with requisite labeling requirements as per standards prescribed by the Bureau of Indian standards (BIS)
All requisite labels and symbols shall be printed visibly, legibly, and indelibly.
No person shall place on the market any Battery or Battery pack unless it is marked with the “Crossed out Wheeled bin symbol” (covering at least 3% of the area of the largest side of the Battery or Battery pack, up to a maximum size of 5cm*5cm). In the case of cylindrical cells, the crossed-out wheeled bin symbol shall cover at least 1.5 of the surface area of the Battery or Battery pack, up to a Maximum size of 5cm*5cm.
Where the size of the Battery or Battery pack is such that the crossed-out wheeled bin symbol would be smaller than 0.5cm*0.5cm, the Battery or Battery pack need not be marked but a crossed-out wheeled bin symbol measuring at least 1cm*1c shall be printed on the packaging.
No person shall place on the market a Battery or a button cell containing mercury, cadmium, or lead unless it is marked with the respective chemical symbol “Hg”, Cd” or “Pb”. The symbol of the heavy metal shall
1. Be printed beneath
2. Cover an area of at least one-quarter the size of the crossed-out wheeled bin symbol.

How can we help you?

We assist persons in obtaining EPR authorisation by providing specialized services. We have an expert team that deals with these matters and provide proper guidance to our clients without manipulating the facts and make ensure to deliver the certificate and licence within a reasonable time period.