2^nd January & 9^th January, 2022, Sunday

12noon - 1pm

• The government has published the draft Battery Waste Management Rules, 2020 in February, which will supersede the Batteries (Management and Handling) Rules, 2001.
• The Ministry of Environment, Forest and Climate Change put the draft rules in public domain for public opinion. The rules are still being finalized.
• These rules cover almost all types of batteries - primary (non-rechargeable) and secondary (chargeable) cells - except for electronic devices, which are covered in e-waste.
• There is no provision for disposal of small batteries in the draft Rules. Presently, they are being disposed randomly and injudiciously mostly in municipal solid waste. Battery cells are collected by unauthorized rag pickers and sold to unauthorized recyclers.
• The responsibility of consumer/bulk consumer has been defined in the draft rules. But the relationship between the consumer and the disposer, which is the need of the hour, is not established or obligated.
• “(v) Consumer or Bulk Consumer : It shall be the responsibility of a consumer & bulk consumer to

1. Consumers are required to ensure that used batteries are not disposed of in any manner other than depositing with the seller or in demarcated areas form whom the consumer has bought the new battery;
2. The consumer shall take proper GST invoice in respect of new battery purchased from the dealer. Additionally Consumer shall receive an invoice from the dealer in respect of every used battery sold under section 31 (3) (f) along with payment voucher under section 31(3) (g) for tax paid under subsection (3) or sub-section (4) from dealer under CGST Act, 2017
3. The bulk consumer shall get registered with State Pollution Control Board. It shall be the responsibility of bulk consumer that scrap batteries are not disposed of in any manner other than depositing it to registered recyclers.”

• The rules have clearly defined the responsibilities of different people. But no means/methods of disposal is mentioned. Recycling is the last step. 
• There is a need to know how to manage the battery waste in an environmentally sound way.
• Batteries are defined in four different rules: Hazardous waste management rules, e-waste management rules, domestic hazardous waste management rules and battery waste management rules itself. These rules are not integrated.
• Lead acid batteries are covered in Battery Waste Management Rules notified in 2005. But there is no mechanism for collection and recycling of other batteries. The consumer does not know where and how to dispose of them.
• Lead acid batteries are being recycled. The person who sells these batteries takes back the old battery. It is his responsibility how he sends it back to the manufacturer or to an authorized recycling center. This is also convenient to the consumer. There are more than 50 recyclers for lead acid batteries across the country. 
• Provisions in the draft rules like the consumer has to deposit the battery with the seller from “whom the consumer has bought the new battery” are not very clear and create confusion for the consumer. Instead, this should be “persons authorised to sell such items”. The consumer cannot go back to the market to sell it to an authorized seller. There should be a list of authorized sellers, which the public should know about.
• There is a need for recyclers who will extract materials from the batteries and reuse them as metals or any other form. There is no clarity on this in the draft rules.
• There should be a provision in housing societies for weekly or fortnightly or as scheduled collection of used batteries for disposal. 
• Collection should be ensured in such a manner that the consumer is responsible only to put it at a defined place within the society where he lives for collection.
• The question also arises whether we are technically prepared to handle those cells in a safe manner and get the best out of them. 
• We don’t have a very sound system for managing batteries. There is a need for more research in this not just from scientists or engineers, but also from management aspects. Research must also focus on how to recover valuable items from the battery waste and convert them into value-added items.
• The ground reality should be taken into consideration when formulating new rules and guidelines.
• There are very few industries authorized by CPCB/SPCB for dismantling or recycling of batteries. 
• Presently they are being handled in an unauthorized manner, which is causing harm to the environment and to the society. Their infrastructure is very poor and therefore the people working there are at a very high risk. There are many unethical practices in this field which need to be rectified. Regulatory authorities should give “consent to dismantle” to recyclers only after careful consideration of infrastructure etc.
• It is being proposed that the e-waste recyclers can also be authorized for battery waste disposal.
• The Paris Climate Conference in 2015 had foreseen that by 2030, 40% of power would be nonfossil fuel. We are likely to meet the target of 400 MW power by 2030; for 500 MW power, it will need to be stored in batteries. Hence, there must be lot of focus on batteries for storage, which will become available in huge numbers and require proper disposal mechanism. Hence, this is an area of concern.
• There are many rules for waste management. At present, everybody is working in isolation due to lack of integration and therefore implementation often fails.
• E-waste and plastic waste management rules have provision for EPR (extended producer responsibility).
• Consumer behavior plays a major role in achieving compliance to the rules.
• Rules often do not give due attention to safety. Social aspects, if any, are not even touched  upon. Commercial aspects, social aspects, institutional aspects should be linked to each other.
• Relation between the consumer and the manufacturer with authorization issued or linked to it can be a solution.
• A collection chain management needs to be established just like the supply chain management.
• The manufacturer should have a detailed disposal management plan ready at the time of introduction of the product in the market - “cradle-to-grave” disposal. There should be Environment Impact Assessment (EIA) and environmental management plan (EMP) for each product as part of environmental clearance.
• A buyback price should be fixed at the time of buying new batteries. The buyback scheme at present is only for car batteries and inverter batteries.
• There is a need to study and clarify how the law has to be applied to this particular activity, which rule should be applied to it and which systems need to be strengthened.
• The legal, operational and technical aspects should be comprehensively discussed individually. 
• Battery waste should be part of e-waste rather than as separate battery rules. Only then integration can be achieved. 
• Most button batteries are fitted in electronic equipments. There is a need to harmonize battery and e-waste.
• Button cells, small cells should be part of the domestic hazardous waste and be the responsibility of municipality to be managed as solid waste.
• Incentives at the time of buying and a helpline number for collection similar to road assistance can be other solutions.
• The burden should not be on the consumer, but on the producer/manufacturer.
• We have to understand the entire cycle; what has been added, what is to be recovered and how the economic value will benefit people.
• Quantification of batteries must be done. City-wise quantification can be done.
• Service centers can collect button cells, laptop batteries, mobile phone batteries etc.
• Sellers selling batteries should also be educated.
• There should be a collection and segregation center close to the dedicated disposal site so that any waste which has been left out in domestic segregation is segregated at the last point.
• Responsibility of the producer should be maximum in waste management and not the consumer. The producer has to set up facilities for the ultimate disposal of the waste emanating from his product.
• Rules for different categories of waste came in 2016. They need to be revisited.
• The disposal and recycling process should be first decided before implementing the rules.
• EPR has been brought in e-waste and plastic waste management rules but has not been implemented so far.
• Problems in implementation has to be looked into seriously.
• Cost can be borne by the consumer but not the liability.
• Municipal bodies lack funds to adequately manage waste 
• CPCB has published SOPs for lead acid batteries. 
• A separate Ministry should be established to handle waste management, circular economy and recycling at the center as well as the state level.

Participants

Dr Anil Kumar

Mr Vivek Kumar

Mr Paritosh Tyagi

Dr Dipankar Saha

Mr RN Jindal

Mr Arun Kumar

Mr Neeraj Tyagi

Mr Sanjiv Kumar

Dr SK Gupta

Dr M Dwarakanath

Mr Ashish Jain

Mr Pradeep Khandelwal

Mr Ankit Sethi

Mr Varun Singh

Mr Vikas Singh

Ms Rinku Das

Ms Ira Gupta

Dr S Sharma