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Drafting Battery Waste Recycling Guidelines

Despite strong policies in place to ensure the scientific treatment of waste from batteries, especially that of electric vehicles, on-ground implementation has been weak. With the growing penetration of electric vehicles in Delhi, particularly after the launch of the Delhi EV Policy 2020, the problem of scientific disposal and recycling of batteries is expected to assume significant proportions very soon.

In March 2021, in partnership with GIZ, the Dialogue and Development Commission of Delhi (DDC) initiated a comprehensive review of operating systems in place to enforce existing policies governing the recycling of battery waste. DDC studied model policies in India and globally and devised detailed recommendations/model operating guidelines so that Delhi can emerge as the leading state with a target to ensure 100% recycling of battery waste.

DDC framed the Operational Guidelines for Recycling of 'end-of-life' EV Batteries within the NCT of Delhi in October 2021 based on the overall policy direction provided by the Delhi EV Policy and the draft Battery Waste Management Rules 2020 (BWMR) notified by the Ministry of Environment, Forest, and Climate Change (MOEFCC). The guidelines are currently under consultation with the Environment and Transport departments of GNCTD.

Once notified, these guidelines will be applicable to every producer, collection centre, dismantler, dealer, and recycler located within the NCT of Delhi and involved in the manufacture, sale, purchase, collection, storage, re-processing, and use of EV batteries. Any battery or battery pack which is used as a source of power for propulsion in an electric vehicle, regardless of its shape, volume, weight, and material composition are covered in the guidelines. Delhi Pollution Control Committee (DPCC) will be the prescribed authority for ensuring compliance with these guidelines.

Key Features Of The Guidelines 

A. Registration 

The guidelines formulated by DDC mandate dealers, collection centres, and dismantlers to make an application to the DPCC for a grant of one-time registration for five years (with a provision of cancellation for non-compliance). Anyone manufacturing or offering to sell EVs or EV batteries has to ensure that the new batteries and electric vehicles with batteries are sold only to dealers registered with the DPCC. 

B. Authorization

Every producer of an EV battery/or an electric vehicle, with operations within the NCT of Delhi (i.e., manufacturing and/or sales operations), shall make an application to DPCC for an Extended Producer Responsibility (EPR) authorization within a period of three months starting from the date of notification of these guidelines. 

The application for EPR Authorization shall include a detailed scheme (i.e. an EPR Plan) for the collection of end-of-life EV batteries placed in the market earlier whether directly or through any authorised agency and channelizing the end-of-life EV batteries so collected to registered recyclers or for re-use as stationary storage batteries.

The EPR Plan should tabulate annual targets for the collection of end-of-life EV batteries generated as indicated in the EPR Plan for a five-year period. For lead acid batteries, collection targets during the first two years of the implementation of these guidelines will be 90% of the number of new batteries placed in the market (individually or as part of an EV) and 100% during the subsequent three years.

Producers of EVs who do not have a valid EPR Authorisation or EVs using EV batteries manufactured/imported by producers without an EPR authorisation will not be eligible for any incentives granted under the Delhi Electric Vehicles Policy, 2020. Battery swapping operators who use EV batteries manufactured/imported by a producer without a valid EPR authorisation will similarly be ineligible for any incentives granted under the Delhi Electric Vehicle Policy 2020.

C. Collections Centers 

Producers or Producer Responsibility Organisations (on behalf of multiple producers) shall set up end-of-life battery collection centres or designate trade partners like EV dealers/showrooms, and authorised service centres to act as collection centres. These (along with EV battery dealers) will operate as collection points for end-of-life batteries.

D. Dealers 

Every EV battery dealer shall collect end-of-life batteries through a take-back system on behalf of producers. Dealers shall ensure that end-of-life batteries collected are stored in a secured manner till it they are sent to a registered dismantler or registered recycler as the case may be and that no damage is caused to the environment during storage and transportation of batteries and no acid should be drained in case of lead-acid batteries. 

E. Dismantlers

Dealers and collection centres shall be permitted to send end-of-life batteries only to registered dismantlers. Registered dismantlers shall ensure that the dismantling processes does not have any adverse effect on the health and the environment, that dismantled battery waste is segregated and sent to the registered recycling facilities for recovery of materials, and that non-recyclable or non-recoverable component are sent to authorised treatment storage and disposal facilities and maintain a record of battery waste collected, dismantled and sent to the authorised recycler.

F. Monitoring of compliance

Compliance with EPR Plans and conditions for registration will be monitored annually by DPCC. Non-compliance will result in the cancellation of EPR authorisation or registration.