HCFI Round Table Environment Expert Zoom Meeting on “Battery Waste Management Rules 2022”

September 4, 2022, Sunday; 12 noon - 1 pm

• Battery waste is hazardous waste as it contains heavy metals such as lead, cadmium, mercury, which may be harmful if not disposed of in a scientific manner.
• These rules were first notified in 2001 as Batteries (Management and Handling) Rules. But these rules did not cover several types of batteries and had implementation issues.
• On 24th August, 2022, the Ministry of Environment, Forest and Climate Change, Government of India notified the Battery Waste Management Rules, 2022 to ensure environmentally sound management of waste batteries. 
• The scope of the battery rules has been enlarged and the new rules cover all types of batteries such as electric vehicle batteries, portable batteries, automotive batteries and industrial batteries. This is a good step.
• The new rules apply to battery producers, dealers, consumers and all those involved in their recycling, including those involved in collection, segregation and transportation.
• These rules will function on the concept of Extended Producer Responsibility (EPR) where the producers (including importers) of batteries are responsible for collection and recycling/refurbishment of waste batteries and use of recovered materials from wastes into new batteries.
• “EPR mandates that all waste batteries to be collected and sent for recycling/refurbishment, and its prohibits disposal in landfills and incineration. To meet the EPR obligations, producers may engage themselves or authorize any other entity for collection, recycling or refurbishment of waste batteries.
• The rules will enable setting up a mechanism and centralized online portal for exchange of EPR certificates between producers and recyclers/refurbishers to fulfil the obligations of producers.
• The rules promote setting up of new industries and entrepreneurship in collection and recycling/refurbishment of waste batteries.” 
• A committee has been formed to implement these rules and auditing of the battery waste generated.
• There will be an environmental compensation charge on the polluter principle for non-fulfilment of EPR targets.
• Despite these provisions, implementing them will be a huge challenge.
• Storage of the waste before it is collected by the producer is a problem. Power plant batteries should be disposed of immediately. Rules must have provisions and guidelines for storage of the waste batteries. 
• Awareness of the consumers is important as these rules have also assigned responsibility to the consumer, who have to discard the battery waste separately from other domestic waste, especially the mixed waste. Awareness has to be created through newspapers or other media.
• The consumer has the responsibility to ensure that the battery is disposed in an environmentally sound manner. This again is a big challenge.
• There has to be a mechanism in place for the utilization of the money collected as environment compensation charge. It must be utilized for the same cause for which it has been applied e.g., ecorestoration of water body, which become contaminated when lead acid batteries are discarded there.
• EPR has been broadly included, but the amount of responsibility under EPR has not been well-specified. 
• There is not enough trained manpower to implement the rules.
• The rules have defined public waste management authority as “Village Panchayat, Municipal Corporation, Municipality and agencies engaged on their behalf”. So, according to the rules, the municipal bodies have the authority to collect battery waste and hand over the waste to the producer or the handler. But the municipal solid waste does not include battery waste. The two have to be integrated in the guideline.
• Unless we look into all aspects, it will not be possible to control the impact of this waste. The system has to be visualized on the ground to be effectively rolled out on the ground. The system has to be developed holistically.
• The CPCB and the concerned SPSB has to issue some guidelines for all stakeholders.
• The consumers should know where to give the waste after segregation.
• Instead of a top-down approach, bottoms-up approach should be adopted before formulating any rule.
• Accountability, auditing and reconciliation are important as are devotion to work and motivation.
• In 2016, six rules were modified and notified. They are yet to be reviewed as to what is their present status.
• All the environment rules must be inter-linked. Domestic hazardous waste is mentioned in solid waste rules, but not in hazardous waste rules. Harmony among different rules is lacking.
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Participants

Dr Anil Kumar

Mr RN Jindal 

Mr Sanjiv Kumar

Mr Rajeev Sharma

Prof Meenakshi Dhote

Mr Pradeep Khandelwal

Mr Neeraj Tyagi

Mr Yash Sharma

Mr Ramesh Kr BN

Mr SC Kollur

Dr S Sharma