Rational regulation: India's battery-recycling norms must evolve with tech

The Battery Waste Management Rules, 2022, makes battery producers (including importers) accountable for collecting end-of-life batteries, ensuring their recycling or refurbishment, and encouraging the use of recovered materials in new batteries. However, as the Society of Indian Automobile Manufacturers (Siam) recently flagged to the Central Pollution Control Board, compliance with the framework could increase electric-vehicle (EV) prices by 3-5 per cent, and add ₹8,000 to ₹25,000 to the cost of an average 35-40 kilowatt-hour (Kwh) battery pack. At a time when EV penetration in India remains modest at 2-3 per cent for passenger cars, though much higher in two- and three-wheelers, regulations that raise costs risk slowing consumer adoption and undermining the government’s broader decarbonisation goals. Battery manufacturers, on the other hand, worry that a one-size-fits-all compliance regime could undermine the commercial viability of domestic battery production. Panasonic Energy India has warned that the current rules could force the closure of its only dry-cell zinc-carbon battery-manufacturing facility in India, because compliance costs could exceed profits and, in some cases, recycling obligations could cost more than the value of the materials recovered. The company has also pointed out that the rules do not adequately distinguish between battery categories with different chemistries. Besides, there is no robust mechanism to collect small-sized batteries. 

The concern of the auto sector is that the current rules require manufacturers to begin collecting 70 per cent of batteries after eight years of use. However, lithium iron phosphate (LFP) batteries, which are increasingly becoming the preferred chemistry for affordable EVs, retain 70-80 per cent of their original capacity even after eight years and can continue serving in vehicles or be repurposed for stationary energy storage. Mandating collection based solely on age rather than actual battery health ignores technological progress and may create the false impression that batteries must be replaced even when they remain perfectly usable. India’s recycling policy must, therefore, take into account the position on the ground and technological developments. Similarly, the pricing of EPR (extended producer responsibility) certificates should be linked to the amount needed to make battery recycling economically viable, instead of being linked to environmental compensation (penalties), thereby ensuring predictable compliance costs and encouraging investment in recycling infrastructure. 

Such reforms are becoming increasingly important as India’s battery ecosystem expands. The NITI Aayog estimates that demand for advanced chemistry batteries could exceed 260 Gigawatt-hour (Gwh) annually by 2030, while the International Energy Agency projects that global demand for critical minerals could grow by more than three times by 2050. Recovering these materials through efficient recycling is, therefore, a strategic necessity for reducing import dependence and strengthening supply-chain resilience. The European Union’s Battery Regulation has introduced digital-battery passports that record a battery’s composition, health and lifecycle, enabling informed decisions on reuse, refurbishment and recycling. The United States is investing through the Department of Energy’s ReCell programme in advanced recycling technologies that maximise material recovery and support battery designs that are easier to recycle. The way forward lies in battery traceability through digital tracking, expanding authorised recycling capacity, stronger monitoring of informal recycling, and periodic revision of technical standards based on evolving battery technologies. A flexible, science-based recycling framework will better support India’s clean-mobility ambitions, strengthen critical mineral security, and build a truly circular battery system.