E-cars can trigger circular economy with new Battery Waste Management Rules
Producers accountable for recycling own batteries; Rules miss out on enabling sustainability standards
Electric vehicles will be key to decarbonising transport. The recent Battery Waste Management Rules, 2022 notified by the Narendra Modi government govern the entire life cycle of batteries, bringing in an holistic approach and a circular economy.
One of the methods to achieve a reasonable amount of success with electric vehicles is to follow a cradle-to-cradle trajectory for the cars and their batteries. A circular economy entails markets that give incentives to reusing products, rather than scrapping them and then extracting new resources.
The recently released Battery Waste Management Rules 2022 by the Union Ministry of Environment Forest & Climate Change have the same aim — placing the producer and importer of batteries at the centre of battery recycling rules with extended producer responsibility (EPR) certificates.
The EPR certificates will be generated on a centralised portal managed by Central Pollution Control Board (CPCB). The parameters for the certificates will include the weight of battery processed, percentage fulfilment of material recovery targets for the specified year and geographical source of battery.
The current version battery waste rules cover electric vehicle batteries, as well as portable, automotive and industrial batteries.
It builds upon and replaces the Battery (Management and Handling) Rules, 2001 to comprehensively address the changing landscape of electric vehicles and advancements in battery technologies.
Under the new rules, the producers, including battery importers, will be responsible for collecting and recycling or refurbishing batteries it has introduced into the market.
The best part about the new Battery Waste Management Rules is that it is outcome-based and can be measurable, if implemented according to their intended design. They define mandatory targets for collection and recycling within a compliance timeframe.
An electric two-wheeler manufacturer has to meet a mandatory collection target of 70 per cent of batteries placed in the market in 2022-23 and has a seven-year compliance time frame starting 2026-27.
For electric three-wheeler manufacturers, the metre starts earlier in 2021-22, according to their introduction into the market and their compliance cycle starts in 2024-25. Electric four-wheelers have a longer compliance cycle at 14 years.
Producers have two ways to meet their targets. They either bear the responsibility of managing battery waste or use the EPR certificate by acquiring surplus certificates from producers of the same batteries category made available by recyclers or refurbishers.
The rules provide flexibility in managing EPR certificates by making them exchangeable and tradable for fulfilling EPR targets. There are provisions for information on the amount of waste batteries as part of the EPR obligations of producers.
However, it does not provide visibility into the auditing process undertaken for producers, recyclers and refurbishers.
The framed targets are fairly granular in nature and are differentiated by the type of batteries collected (lead-acid, lithium-ion, nickel-cadmium or zinc-based batteries. Non-compliance will be penalised with an environment compensation charge.
If that does not garner the intended response, the system will deploy a second line of deterrence in which names of defaulting entities will be made public on the CPCB website.
After processing, producers have to mandatorily use a minimum defined percentage of recycled materials recovered from old waste batteries to produce new ones.
However, the rules miss out on a huge opportunity to enable sustainability standards that have the potential to make India a benchmark for the global battery industry.
Limits and labels
The Rules list out limits and labelling requirements for batteries. Labels indicating limits on the use of heavy metals — cadmium, mercury and lead — and a picture of a crossed-out bin to indicate that the batteries cannot be binned and have to be handed out to a registered battery collector.
With lead-acid batteries, this can be a useful practice and will inform the recycling community about the presence of these metals and plan for their management while ensuring that the producer maintains limits on the quantum of heavy metals used.
But the labelling requirements only address lead-acid batteries used in internal combustion engine-driven vehicles. It misses out on requirements for lithium-ion batteries.
Information about lithium chemistries used in the battery on the label could enable more efficient recycling processes. Different materials require different kinds of treatment at the recycling stage.
Lack of information about chemistries would require the recycler to deploy additional resources to investigate the materials present in the spent battery feedstock before they can be processed.
The new rules also miss out on using labels as an opportunity to reflect the battery’s carbon footprint. This would make their environmental impact more transparent, especially if it covers the entire life of the battery as well as the percentage of recycled battery materials such as cobalt, lithium and nickel.
The deployment of such a practice could have multipronged benefits.
Using carbon footprint as a parameter for producer responsibility could trigger research and development of batteries upstream with lower footprint and materials sourced from within the country.
Lithium-ion batteries have a very high carbon footprint as they have materials sourced from various parts of the world (South America and Australia for lithium, Congo for cobalt and Indonesia for nickel).
It could also help track the source of materials and thus ensure identification and avoidance of a supply chain with human rights abuse history. About 15 per cent of cobalt sourced from Congo comes from artisanal mines that often use under-aged labour.
With such a tracking regulation in place, battery manufacturers must conduct due diligence exercises to address issues with sourcing, processing and trading raw materials, chemicals and secondary raw materials.
Such regulations could add to the cost of batteries. But versions of similar regulations in Europe, US and China have already initiated efforts at developing cobalt-free batteries with lithium iron phosphate and lithium titanate batteries, according to the Cobalt Institute, a United Kingdom-based trade association of cobalt producers and recyclers.
Cost continues to be an issue with lithium-ion batteries. With electric vehicle battery demand at a high, the cost of raw materials has increased, leading to supply issues. Going further, many mines will have to be developed to meet new demand.
That will have its own challenges considering the multiple geographic locations materials are sourced from — South America, the Democratic Republic of Congo and Australia, among others.
The Battery Waste Management Rules are intended to subsidise a part of that materials feed by building a stream of recycled battery materials for the new production cycle.
Larger sustainability standards built into battery waste management have the potential to strengthen rules for design, production and disposal of batteries in India. It will be more holistic in practice and govern the entire product life cycle, from the design phase to end-of-life.
If not implemented correctly, the rules could fail to promote a circular economy and even disrupt the country’s climate mitigation targets. Implemented right, it can become a platform to expand inputs to feedstock for battery manufacturing in the future. This will support future material supply security and offer cost benefits.
Recycled material is always cheaper than the fresh output from the mines. That is because the metals present in the black mass, an intermediate product derived after recycling batteries, contain battery-grade material that does not require complex extraction processes with mine output.
Cobalt is mined as a by-product in nickel and copper mines. Typically, such ores contain 2 per cent of cobalt, with 60 per cent copper and 70 per cent nickel.
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