OMI Policy Submission | Draft Battery Waste Management Rules 2020
By Shilpi Samantray and Snehil Singh
A. Background
The Ministry of Environment, Forest and Climate Change (MoEFCC) released the draft Battery Waste Management Rules 2020 through a notification dated 20.02.2020, seeking public comments and suggestions. The draft rules are a revised version of the Batteries (Management & Handling) Rules 2001. The updated draft rules include batteries of all kinds irrespective of their shape, volume, weight, material composition or use. The rules are applicable to every manufacturer, producer, collection center, importer, re-conditioner, refurbisher, dismantler, assembler, dealer, recycler, auctioneer, vehicle service center, consumer and bulk consumers involved in manufacturing, processing, sale, purchase, collection, storage, re-processing and use of batteries or components thereof including their components, consumables and spare parts which make the product operational. These rules have been drafted in a manner that ensures greater accountability from each of these stakeholders for safe and formalised recycling of the batteries.
B. Introduction
OMI highly appreciates the timely notification of the proposed rules by the Ministry of Environment, Forest and Climate Change (MoEFCC) and believes it is the right step towards converting “waste into wealth”.
Recent studies state that with rapid improvements in battery technology and reduction in cost, battery-based applications will become cost-competitive in the near term for both stationary and mobile applications. With the drive to transition to electric vehicles (EVs), expansion of the Indian renewable energy industry and the exponential rise in demand for EVs has led to increased usage of batteries. The enforcement of these rules will ensure an integrated management system that addresses concerns of electronic waste (w.r.t. batteries) and enable monitoring and controlling the increased usage of batteries. The collaborative efforts of battery and auto manufacturers and the government will ensure that battery price fluctuations are controlled and battery manufacturing is encouraged through the implementation of these rules.
The shift to utilising ‘waste as a resource’ and efforts towards finding sustainable ways to go beyond waste prevention are imperative to build a resource efficient economy that feeds into the circular economy. Globally, countries are recognising waste management has a critical component of the circular economy. Battery reuse and recycling is one such way through which secondary resources can be fed back into the production process. The secondary use cases of batteries have shown that a battery with even 80% original reduced capacity can be used in energy storage applications.
As per the OMI study titled “Beyond Nagpur: The Promise of Electric Mobility”, batteries can be treated as decentralised electricity storage solutions. India has a huge economic opportunity in the secondary market-use by utilising the battery waste. Currently, Karnataka and Kerala are the two states whose EV policies have included battery storage as the focus area and plan to create a secondary market for batteries. A recent study by JMK research found that India’s recycling market has a $1000 million potential.
It also projects that from 2022 onwards the batteries from electric vehicles would contribute to the majority of the recycling market with public transport leading at almost 75% of the total recycling market. A stringent enforcement and adoption of the draft Battery Waste Management rules will enable India to further harness this economic opportunity.
C. Section wise Comments and Recommendations
The table below enlists section wise comments and recommendations on the draft rules:
D. Additional comments and recommendations:
- Guidelines for estimating the value of the used batteries can be included in the draft rules.
Example: Few cities in India like Chandigarh have their own guidelines for disposal of electronic equipment (which includes batteries) that clearly mentions about the useful life and calculating the rate of depreciation of such equipment/batteries.
In a similar manner, the central ministry may also provide detailed guidelines on estimating the value of the used batteries will help the users (especially in the commercial segment).
2. Transportation of the used batteries is imperative to ensure a safe waste management process. The government may provide detailed guidelines and instructions for suppliers, consumers and transporters on the transportation of battery waste.
Currently, the rules only state that transportation should be safe, however, it doesn’t mention the process of how recyclers have to ensure safe transportation, especially if the vehicles are not owned/ operated by them.
Example : Germany follows a simple collection and transportation method wherein GRS Batterien Foundation4 (GRS) supply containers nationwide, and at no cost, to retail outlets, local authorities, public institutions and commercial end users for battery collection and transport. Post that, GRS transports these containers to sorting facilities where they are segregated according to their electrochemical class in a manner that valuable materials such as iron, nickel can be recovered and the metals such as lead and cadmium can be reused in battery production.
3. To ensure greater end-user engagement and ownership, the government may provide consumers with the flexibility to dispose of used batteries with any authorized dealer.
Example: California conducts battery collection events. The details of the upcoming collection events and authorized disposal centres are available online which gives the consumers the flexibility to dispose of used batteries to authorised dealers.
4. The Battery waste management guidelines should also look at the potential benefits from convergence of electronic waste (w.r.t. batteries) with urban mining to ensure supply chain and demand fix for metals and link it to the broader concept of the future green circular economy. Studies have shown high correlation of generation of e-waste and the GDP and GDP Purchasing Power Parity (PPP) in South American countries of Brazil, Chile etc. making them competitive in the global market for base and precious metals.
Further, in 2016, a report by Korea Institute of Industrial Technology stated that $18.38 billion worth of metals were extracted from recycled materials in South Korea, meeting 22% metal demand of the country.
India too has a huge potential to become competitive in the global market for metals through implementation and consolidation of these draft rules on battery waste management and circular economy practices.
References
- https://rmi.org/wp-content/uploads/2019/10/rmi_breakthrough_batteries.pdf
- https://www.sciencedirect.com/science/article/pii/S2405844019347012
- https://olawebcdn.com/ola-institute/nagpur-report.pdf
- http://www3.weforum.org/docs/WEF_EV_Ready_India.pdf
- https://jmkresearch.com/report-solar-ev-india/recycling-of-lithium-ion-batteries-in-india-1000-million-opportunity/
- http://chandigarh.gov.in/pdf/guidelines-obsolete.pdf
- The GRS Batterien Foundation operates the common collection scheme for portable batteries as specified by the German Federal Ministry for the Environment under Section 6 of the German Batteries Act (BattG).
- http://www.grs-batterien.com/
