Here’s all that you need to know about scrap battery import in India

Scrap Battery Import - Overview

The scrap battery import and their processing to generate secondary materials like lead seem to be the only sustainable option for meeting the demand for lead and lithium in India. Scrap battery import in India is permitted only to the registered recyclers to the extent of 1/3rd of the recycling capacity, subject to obtaining an import permit from the MoEF&CC. Used and scrap lead acid battery Import is allowed only those recyclers who have installed automatic battery breaker units. In addition to the MoEFCC's permission and rules like these, here are some other details related to the scrap battery import in India.

Battery Waste Management Rules, 2022

BWM rules, 2022 apply to -

(i) Importer, producer (involved in import) and other entities engaged in transportation, segregation, recycling and collection of waste battery;

(ii) all types of batteries regardless of volume, shape, chemistry, material composition, weight and use.

These rules don’t apply to batteries used in

(i) tools related to the protection of essential security interests such as ammunition, arms, war material and those designed specifically for military purposes;

(ii) equipment intended to be sent into space.

Definitions

The battery pack is any module or set of cells and/or batteries that are encapsulated or connected within an outer casing to create a whole unit that the end user is not seeking to open or split up;

An importer is a person who imports lead acid batteries or components having lead thereof for the purpose of sale (as per BWM Rules, 2001);

Battery materials are materials contained in the battery such as metals like cobalt, nickel, lead, lithium and other materials like paper, plastics, etc.;

A designated collection centre is set up jointly or individually by one or more importers, manufacturers, assemblers and re-conditioners in pursuance of their responsibilities stated under battery waste management rules.

Environmentally sound management is the management of waste batteries to safeguard the environment and human health against any severe effects resulting from any material contained in the waste batteries. These may include recycling/refurbishment; and

A producer is an entity involved in the import of batteries and equipment having batteries.

Types of battery

An automotive battery is used for lighting, automotive starter or ignition power.

A battery is a new or refurbished battery/cell/their component, such as an accumulator, which is any source of electrical energy produced by direct conversion of chemical energy and includes a disposable primary or secondary battery.

An end-of-life battery is a battery that has been utilised, completed its intended use and is not created for refurbishment.

An industrial battery is any battery intended for industrial uses, except portable, EV and automotive batteries. These can include sealed batteries (except potable batteries), unsealed batteries (except automotive batteries), and energy storage system batteries.

A used battery is a battery along with its components that have been used, have residual life and are ideal for refurbishment

Waste battery includes:

• Used/end-of-life battery or its spares/components/parts/consumables, which may not or may be hazardous;
• Pre-consumer off-spec battery and its spares/components/parts/consumables;
• Battery whose date for appropriate use has expired;
• A battery that the user has discarded.

Prohibitions and labelling requirements

1. Prohibitions on heavy metal content in the battery

(i) Battery with up to 0.0005% (5 ppm) of mercury by weight can only be placed till 2025.

(ii) Battery with up to 0.002% (2000 ppm) of cadmium by weight can only be placed.

(iii) paragraph (1)(i) must not apply to button zinc silver oxide battery with a mercury content less than 2% and button zinc-air battery with a mercury content less than 2% by weight.

(iv) prohibition in paragraph (1)(ii) must not apply to a portable battery designed for use in –

• A. alarm systems and emergency, including emergency lighting;
• B. medical equipment

Standard Operating Procedure (SOPs) for registration of Importers via the Online Portal under BWM Rules, 2022

Guidance for filing of applications by the importers

The process of applying begins with signing up by the importers under the category of producers on the web portal www.eprbatterycpcb.in, followed by applying to 6 parts, namely -

• (A) General information of Producer
• (B) Information on the Type of Battery
• (C) Addition of Sales Data
• (D) Addition of Battery Material
• (E) Uploading of required Documents and
• (F) Payment of Fees

Applicability of SOP

The SOP must apply to all the importers intending registration under BWM Rules, 2022. The scrap battery importers must fill out the online application along with the relevant documents, information and application fees for registration. Applications under process for grant of registration must subsequently be processed at https://egovernancecpcb.co.in/battery/ portal created by the CPCB according to the norms of this SOP.

Procedure for signing up

On opening the portal, the used battery importer must create an account by furnishing the required details.

Submission of Application

After creating the account, the applicant must log in to start the registration process. However, before filling application form, it must be ensured that a copy of the following documents in pdf formats only is readily available:

• 1. Company GST Certificate
• 2. PAN Card of the company
• 3. Corporate Identification Number (CIN) document
• 4. Consent Issued by SPCBs/PCCs (CTE and CTO)
• 5. Import Export Certificate (in case of importers)
• 6. District Industries Center (DIC) registration (if the unit is registered with DIC)

Daily Sales Data

The producer must make daily sales entries and furnish the following details: The producer must fill in the name of the equipment having a battery if the producer is selling and/or importing the battery contained in the equipment.

Battery Waste Management Rules, 2010

Functions of an importer

(1) to guarantee that the used and scrap lithium-ion battery is collected back according to the schedule against new batteries sold except those sold to original equipment manufacturer (OEM) and bulk consumer(s);

(2) to guarantee that the used and scrap lead acid battery collected back are of the same type & specifications as that of the new batteries sold;

(3) to submit a half-yearly return of their sales and buy-back to the SPCB in Form I (Annexure-I) latest by 30th June and 31st December annually;

(4) to establish collection centres either jointly or individually at various sites for the collection of used and scrap lithium-ion batteries from consumers or dealers;

(5) to guarantee that used and scrap lead acid batteries collected are sent to the registered recyclers only;

(6) to guarantee that necessary arrangements are made with dealers for safe transportation from collection centres to the location of registered recyclers;

(7) to guarantee that no damage to the environment occurs during transportation;

(8) to create public awareness via publications, advertisements, posters or by other means concerning the following -

• lead hazards;
• responsibility of consumers to give back their used batteries only to the dealers at designated collection centres;
• addresses of designated collection centres and dealers;
• use the international recycling sign on the batteries;
• buy recycled lead only from registered recyclers; and
• bring to the notice of the MoEF&CC or SPCB any violation by the dealers.

Registration of Importers

(i) The importers must get registered according to Form I with the CPCB for five years and a provision of cancellation for failure in the collection of the required count of used and scrap lithium-ion batteries according to the said rules, non-submission of timely half-yearly returns to the SPCBs with a copy to the CPCB, renewal of the registration must be according to the compliance status: Given that the registration granted to the importer must not be cancelled unless he has been offered a reasonable opportunity of hearing;

(ii) an appeal must lie against any order of cancellation or suspension, or refusal of registration passed by the CPCB or any other authorised officer;

(iii) the appeal must be filed in writing & must be attached with a copy of the order appealed against. It must be made within thirty days from the date of passing of the order.

Functions of producer

1. In the case of imported batteries, the producer shall meet the obligation of the minimum use by getting such quantity of recycled materials used by other businesses or exporting such quantity of recycled materials.

Batteries (Management and Handling) Rules, 2001

Battery Waste Management rules apply to every importer and other entities engaged in the manufacture, sale, processing, purchase and use of batteries or components thereof.

Battery Registration Management System (BRMS)

The web-based software streamlines the process of an application filed by lead acid battery importers to grant registration certificates by verifying the mandated documents enclosed by importers while applying for a fresh registration certificate.

Grant of Fresh Registration

The following procedure must be followed for acceptance of applications for grant of certificates to importers of lead acid batteries;

• i. The applicant must apply for the grant of registration via online web-portal www.cpcbbrms.nic.in
• ii. After filing the online application, the applicant must also file a physical copy of the application on their letterhead, enclosing the following documents;

a. Printouts of Form II and Form III taken out from the online application with their stamp and signature on the same.

b. Self-attested copy of Import-Export certificate

iii. The complete application is processed within seven days from receipt of the manual /hard copy.

iv. Registration is issued only on the corporate or branch address mentioned on [EC certificate.

v. In-Charge HWM Division grants the registration to importers of lead-acid batteries.

vi. The importer registered earlier by MoEF&CC, seeking to get registered with CPCB, can apply for the same as above. However, the importer must surrender the original registration certificate issued by the Ministry and the application.

Documents to be verified

Online submission of Fresh/Renewal of the registration by the lead acid battery importers. Incomplete applicants must be informed to submit the required document for further processing.

Online submission of half-yearly returns by importers according to the rule and verification of returns by the CPCB officials/Port authority.

• Generation of various reports according to the user requirement.
• To keep provision for future expandability/integration with any national policy for implementing battery waste management rules in India.

Mechanism of the project and deliverables

The BRMS is web-based and user-friendly. The following activities must be included in the system:

• Online registration of scrap battery importers
• Submission of half-yearly return by battery importers
• Processing and verification of fresh/renewal applications depending on half-yearly returns received
• Issue of Rejection/Grant letter by CPCB to importers
• Producing reports such as application status details, half-yearly returns, follow of actions and other reports per the CPCB's requirements.
• Online status of application received, registration granted, details of incomplete applications and application rejected.
• Access to port authorities to verify the registration status and evaluation of half-yearly returns filed by the importers of batteries.

Frequently Asked Questions