Batteries: The Battery Waste Management Rules 2022

In one line

Every battery of every chemistry, a collection target measured against what was sold years earlier, and a rule that a waste battery may never be landfilled or burned.

In exam wording: the Battery Waste Management Rules 2022 apply to producers, dealers, consumers and every entity involved in the collection, segregation, transportation, refurbishment and recycling of waste batteries, and to all types of battery regardless of chemistry, shape, volume, weight, material composition or use; rule 4 imposes extended producer responsibility with the collection and recycling targets in Schedule II and a minimum-use-of-recycled-material obligation; rules 5 to 9 set out the functions of the consumer, the public waste management authorities, the collection and treatment entities, the refurbisher and the recycler; rule 10 provides for certificates and the recovery targets; rules 11 and 12 the functions of the Central and State Boards; rules 13 and 14 environmental compensation and the online portal; and rule 15 the Committee for Implementation.

What these Rules replaced

Older books teach the Batteries (Management and Handling) Rules 2001. Those Rules were confined to lead acidbatteries and worked through dealers and a deposit system. They were replaced in 2022.

Three differences.

All chemistries. Rule 2(1)(ii): all types of battery regardless of chemistry, shape, volume, weight, material composition and use. That brings in lithium-ion, nickel-cadmium and zinc, and it is the change that mattered, because the waste stream that is growing is not lead acid but lithium-ion from electric vehicles and consumer electronics.

Four categories, not one. Portable, automotive, industrial and electric vehicle batteries, each with its own targets.

Extended producer responsibility with certificates. The 2001 Rules used a dealer-based return system. These use registration, targets and traded certificates.

Two exclusions, in rule 2(2): batteries in equipment connected with essential security interests, including arms, ammunition and war material and equipment intended specifically for military purposes; and equipment designed to be sent into space.

Rules 1 to 3: the frame

Rule 1, short title and commencement. Rule 2, application, set out above. Rule 3, the definitions, including producer, dealer, consumer, refurbisher, recycler, waste battery and the four battery types.

Rule 4: the producer

The core obligation. A producer has extended producer responsibility for the batteries it introduces in the market, to ensure the attainment of the recycling or refurbishing obligations, and must meet the collection and recycling or refurbishment targets in Schedule II.

Rule 4(3) is the sentence to memorise.Waste battery collected by the producer shall be sent for recycling or refurbishing and shall not be sent for landfilling or incineration. That is an absolute prohibition and there is no equivalent in the plastic rules, which permit energy recovery, or in the used oil chapter, which prices burning at a quarter. A battery contains recoverable metal and, in the case of lithium, a strategically scarce one, and burning or burying it is forbidden outright.