The Missing Link in India’s Battery Waste Management

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Context

India's aim of decarbonization and Net Zero by 2070 depends on rapid electrification, primarily through EV and BESS uptake. Due to exponential battery garbage growth, electrification is threatening the environment.

What is E-Waste?

E-waste refers to any abandoned electrical or electronic equipment. This covers both working and broken things that are discarded or donated to a charity reseller. If an item does not sell in a store, it is frequently discarded. E-waste is especially hazardous because of the poisonous compounds that naturally leach from the metals therein when buried.

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Source: ResearchGate

How is battery waste a part of e-waste?

Battery waste is a significant and growing component of electronic waste (e-waste).
E-waste refers to discarded electronic and electrical devices, and since most modern electronics like smartphones, laptops, and remote controls rely on batteries, their disposal naturally includes battery waste.
Batteries contain hazardous substances such as lead, mercury, cadmium, and lithium, which can leak into the environment if not handled properly. When electronic devices are thrown away, the batteries inside them also become part of the waste stream.
Improper disposal of these batteries can lead to soil and water pollution and pose serious health risks. Moreover, the rise in electric vehicles and rechargeable electronics has drastically increased the volume of used batteries.
As such, effective battery waste management is critical within the broader e-waste framework. Recycling and safe disposal are essential to minimize environmental harm and recover valuable materials like lithium and cobalt for reuse.

Current Scenario of E-Waste in India

Source: Amulya Charan

India is the third-largest generator of e-waste globally, after China and the USA.
In FY 2023-24, India generated approximately 3.8 million metric tonnes (MMT) of e-waste.
E-waste generation in India rose by 151.03% between 2017 and 2024.
65 cities are responsible for over 60% of the total e-waste generated.
10 states account for 70% of India’s total e-waste.
The sharpest increase in e-waste occurred between 2019-20 and 2020-21, mainly due to the rise in electronic consumption during the COVID-19 pandemic (work-from-home and online learning).

E-Waste (Management) Rules

E-Waste (Management) Rules, 2022

Introduced Extended Producer Responsibility (EPR): Producers must meet annual recycling targets through registered recyclers.
Product Coverage Expanded: From 21 to 106 Electrical and Electronic Equipment (EEE) categories from FY 2023-24.
Bulk Consumers Integrated: Public institutions and government offices must dispose of e-waste through registered recyclers or refurbishers.

Second Amendment Rules, 2023

Rule 5 of the 2022 rules was amended to ensure safe and sustainable refrigerant management in refrigeration and air-conditioning manufacturing.

Amendment Rules, 2024

Government may set up platforms for trading EPR certificates.
The Central Pollution Control Board (CPCB) has fixed a price range for EPR certificates:

Maximum: 100% of environmental compensation
Minimum: 30% of environmental compensation

The Growing Challenge of Battery Waste in India

Rising EV Battery Demand

The demand for EV lithium-ion batteries is growing rapidly due to India's push towards electric mobility.
It is projected to rise from 4 GWh in 2023 to almost 139 GWh by 2035.
This massive increase poses a serious waste management challenge in the near future.

E-Waste Surge

In 2022, India produced 1.6 million metric tonnes of e-waste.
Lithium batteries alone contributed 700,000 tonnes, highlighting their large share in total e-waste.
The lack of proper recycling and disposal infrastructure increases the burden on the environment.

Toxic Chemical Hazards

Used lithium batteries contain toxic heavy metals like cobalt, lithium, and nickel.
If not handled correctly, these hazardous substances leak into the soil and water bodies, causing environmental contamination.

Health and Agricultural Risks

Leaked toxic materials can result in serious health issues, such as:

Cancer
Neurological disorders

Contamination also damages agricultural land, affecting crop health and food safety.

Battery Waste Management Rules, 2022 – Provisions and Amendments

Notified on August 22, 2022: Replacing the Battery (Management and Handling) Rules, 2001, these new rules aim for a comprehensive and modern regulatory framework.
Extended Producer Responsibility (EPR): Makes it mandatory for producers to collect and recycle or refurbish 100% of the used batteries they introduce into the market.
Prohibition on Landfilling and Incineration: Disposal of used batteries in landfills or by incineration is banned to prevent environmental harm.
Use of Recycled Materials: Manufacturers are required to use a minimum percentage of recycled materials in new batteries to promote circularity.
Online Portal for EPR Compliance: An EPR portal is created for registration, reporting, and tracking of collection targets and compliance.
Incentives and Penalties: Provision for environmental compensation charges for non-compliance and incentives for entities exceeding their targets.
Battery Types Covered: Applies to all types of batteries, portable, automotive, industrial, and electric vehicle batteries.
Annual Reports and Audits: Mandates annual performance reports by producers and independent audits to ensure transparency and accountability.

Extended Producer Responsibility (EPR) under Battery Waste Management Rules, 2022

The Battery Waste Management Rules (BWMR), 2022, were introduced by the Government of India to regulate battery recycling.
A key feature of these rules is the Extended Producer Responsibility (EPR).

What is EPR?

EPR makes producers legally responsible for funding the collection and recycling of their used batteries.
Most producers depend on third-party recyclers, as they lack the infrastructure and logistics to handle waste batteries themselves.

EPR Certificates and Floor Price

Recyclers issue EPR certificates to prove that producers have met their recycling obligations.
In return, recyclers are supposed to receive a minimum compensation called the EPR floor price.
This price helps recyclers recover costs spent on:

Infrastructure
Research & Development
Labour
Advanced technology

The Flaw in the System

The major issue is that the EPR floor price is set too low.
Safe recycling of lithium batteries is costly due to:

Use of advanced technology
Need for safe transportation
Hiring of skilled labour

When the compensation doesn’t cover these costs, genuine recycling becomes unviable.

Consequences of a Low EPR Floor Price

Rise of Fraudulent Recyclers

Legitimate recyclers can’t survive, allowing informal and fraudulent players to dominate.
These entities may:

Issue fake certificates
Illegally dump hazardous waste

Similar patterns were earlier observed in India’s plastic waste management sector.

Threat to Circular Economy

A circular economy depends on efficient recycling and reuse.
A low EPR floor price disrupts this cycle, making sustainability goals unachievable.

Environmental Impact

Improper recycling leads to environmental degradation.
Dumped waste pollutes soil and water ecosystems, posing serious health risks.

Economic Loss

Poor battery recycling could result in over $1 billion in foreign exchange losses by 2030, due to dependence on imported materials.

Producer Resistance & Consumer Impact

Many OEMs resist compliance, especially in developing countries.
They follow double standards, showing more responsibility in developed nations.
The claim that raising the EPR price will raise consumer prices is misleading:

Global metal prices have dropped, but OEMs haven’t reduced consumer prices.
OEMs can absorb increased recycling costs without burdening consumers.

Challenges in E-Waste Management in India

Source: Amulya Charan

Weak Enforcement Mechanisms

The enforcement of e-waste recycling regulations is inadequate.
There is a lack of audit systems, poor tracking of Extended Producer Responsibility (EPR) certificates, and weak penalties.
Repair as a preventive strategy receives limited attention under the E-Waste (Management) Rules, 2022.
Illegal recycling is widespread due to poor enforcement.

In 2023, a CPCB audit found over 600,000 fake plastic recycling certificates issued in Gujarat, Maharashtra, and Karnataka.

Inadequate EPR Floor Price & Market Distortions

The EPR system lacks a sustainable floor price, making it economically unviable for genuine recyclers.
As a result, the system is exploited by informal actors who issue false certificates or illegally dump hazardous waste.
These actions distort the recycling market and weaken India’s circular economy goals.

Resistance to Compliance by Large Manufacturers

Some large companies resist recycling mandates.

In April 2025, Daikin, Hitachi, and Samsung filed lawsuits opposing a policy requiring minimum payment to recyclers.

This resistance slows down policy implementation and weakens compliance.

Unaccounted Financial and Resource Losses

Improper battery recycling could lead to USD 1 billion in forex losses by 2030.
Inefficient systems lead to loss of valuable materials like lithium, cobalt, nickel, copper, gold, and silver.
Formal recycling can recover these materials but is often expensive and not widely practiced.

Illegal E-Waste Imports

India faces illegal e-waste imports from developed countries.
Between 2019 and 2022, 29 cases of illegal imports were identified in states like Tamil Nadu, Maharashtra, Gujarat, West Bengal, and Uttar Pradesh.

Infrastructure Gaps and Regional Disparities

There is a shortage of recycling infrastructure, technical expertise, and safe disposal mechanisms.
While states like Telangana have made progress, others like Chandigarh lag behind.
This causes regional imbalance in e-waste management.

Limited Public Awareness

Most consumers are unaware of correct disposal methods.

A 2021 Delhi study showed:

70% of repair workers and 79% of scrap dealers didn’t know about e-waste.
Only 13–17% were aware of related legislation.

Unclear Roles for Stakeholders

Roles of producers, recyclers, and consumers are poorly defined under the current framework.
This confusion weakens coordination and hampers the creation of an effective and accountable system.

Need for Battery Waste Management

Rising Use of Batteries: With the growth of electric vehicles (EVs), consumer electronics, and renewable energy storage systems, battery usage has surged, leading to a proportional increase in battery waste.
Toxic Components: Batteries contain hazardous metals like lead, cadmium, mercury, and lithium, which can contaminate soil, water, and air, posing a risk to human health and the environment.
Resource Recovery: Efficient management enables recovery of valuable materials (like lithium and cobalt), reducing dependence on imported raw materials and encouraging circular economy practices.
Unregulated Disposal: A large portion of battery waste, especially from the informal sector, is handled without safety norms, leading to pollution and health hazards.

Battery Waste Management Governance in India

Polluter Pays Principle: Governance is anchored in Extended Producer Responsibility (EPR), where producers are responsible for the collection, recycling, and disposal of used batteries.
Regulatory Bodies: The Ministry of Environment, Forest and Climate Change (MoEF&CC) oversees battery waste management, while CPCB and SPCBs monitor implementation and compliance.
Role of Informal Sector: Governance mechanisms increasingly aim to formalize and integrate the informal sector, providing them with training, technology, and recognition.
Alignment with Global Goals: India's policies align with the Sustainable Development Goals (SDGs), particularly SDG 12 (Responsible Consumption and Production) and SDG 13 (Climate Action).

Way Forward

Formalizing the Informal Sector

A large share of India’s e-waste is handled by the informal sector using unsafe methods, harming health and the environment.
Efforts must focus on training, infrastructure support, and certification to integrate this sector.
Rag pickers can become “e-waste heroes” by being formally included and recognized.
Incentives like tax rebates and subsidies for both producers and consumers can boost participation.
Making collection and return processes simpler will encourage broader involvement.

Strengthening Regulation and Enforcement

A fair EPR floor price (Extended Producer Responsibility) helps recyclers recover costs and discourages unsafe practices.
Enforce compliance through digital tracking, audits, and strict penalties for fraud and violations.
India can adopt elements from South Korea’s model, where producers collect most e-waste.
The E-Waste (Management) Rules must be better implemented with active monitoring.
Local bodies, along with MoEFCC and CPCB, should be empowered to enforce rules, especially in urban and industrial regions.

Raising Consumer Awareness

Public education is vital for proper e-waste disposal.
Government and NGOs must lead awareness campaigns on environmental hazards and responsible recycling.
Engage RWAs and SHGs to promote safe disposal in communities.
Spread knowledge about collection points and recycling systems to change consumer behavior.

Promoting Safe Materials and Design

Reduce hazardous materials like lead, mercury, and cadmium in electronics.
Encourage Design-for-Environment (DfE) practices and use non-toxic materials, e.g., lead-free solders like SAC alloys.
Invest in battery recycling R&D to improve recovery of valuable materials and reduce risks.

Encouraging a Circular Economy

Promote systems that recover materials from spent batteries to reduce import dependency.
These efforts align with Mission LiFE, promoting sustainable lifestyles and consumption.

Expanding Infrastructure and Right to Repair

Build more e-waste collection centers and modernize existing ones.
Replicate models like Delhi’s eco-park, Bhopal’s e-waste clinic, and global E-Waste Banks.
Strengthen India’s Right to Repair portal by mandating affordable access to spare parts and restricting repair-blocking techniques used by manufacturers.

Setting National Targets

Adopt national e-waste collection goals, similar to the EU’s per capita targets, to improve accountability and recycling rates.

Practice Question

Q. Discuss the key issues in battery waste management in India. Suggest measures to ensure sustainable recycling to promote the circular economy.