IBMA Argues Against Inclusion of Recycling Cost In Guidelines From CPCB

The Indian Battery Manufacturers Association (IBMA), representing an industry with a significant annual turnover of Rs. 50,000 Crores, while acknowledging the introduction of new Environmental Compensation (EC) guidelines by the Central Pollution Control Board (CPCB) has made a case for some key changes needed in it. These guidelines are crucial for advancing sustainable waste management practices and promoting a circular economy within the battery industry.

The final Environmental Cost (EC) guidelines for Lead now incorporate the costs of recycling waste batteries, highlighting the robust recycling system of lead-acid batteries. With a recycling rate exceeding 98%, lead-acid batteries are the most recycled commodity, supported by an established ecosystem that facilitates the recovery and profitable resale of valuable refined Lead to battery makers.

IBMA claims that members have significantly invested in reverse logistics to ensure proper collection, handling, and transportation of used waste batteries to authorized recyclers. Including the cost of recycling in the EC and the requirement to buy EPR credits indexed at this inflated price could lead to double reimbursement to recyclers.  IBMA thus proposes that EPR credits be available at no charge to manufacturers who have incurred costs through all stages of waste management.

The guidelines propose a minimum pricing for EPR credits at 30% of the EC, potentially raising compliance costs to unsustainable levels and impacting consumer prices. IBMA advocates for market-driven pricing for EPR certificates without a fixed limit, to ensure economic viability for manufacturers and affordability for consumers.

Only about 30% of recycling is conducted in integrated facilities that process waste directly into refined Lead, while over 70% involves a two-step process producing remelted Lead (RML), in the first step to 99.5% purity which then must be refined to 99.7-99.9%+ purity. Current rules restrict EPR certificate issuance to facilities that process battery waste directly from waste batteries to refined Lead, excluding the majority that go through the RML route. IBMA recommends that all certified recycling processes with proper linkage to waste battery input, regardless of the route, be eligible for generation of EPR certificates. Safeguards can be built in to prevent double-accounting of EPR certificates.  This will prevent a shortage of available credits and ensure compliance.  Despite substantial compliance efforts, IBMA highlights the need for revising current material consumption and recovery norms to realistic levels to meet future targets effectively.

Many IBMA members are leading manufacturers of home UPS and inverter devices, which have transitioned from using Copper to Aluminium, reducing costs and enhancing sustainability. They claim that the waste management rules incorrectly specify an 11% Copper content by weight and overestimate the costs associated with processing waste Copper at Rs. 1850/kg and collection, handling, and transportation costs at Rs. 25/kg, compared to just Rs. 3/kg for lead-acid batteries. The total EC is thus reckoned at Rs. 1875/ kg of Copper when the price of virgin metal is just about Rs. 800-850/ kg.

Producers argue that CPCB has specified EC in terms of Copper which, in the first place, is not the primary metal. Therefore, it is completely out of line with the costs of recycling. These discrepancies could hinder compliance and lead to higher consumer prices.

Ms. Preeti Bajaj, President of IBMA, emphasizes the critical importance of collaboration, stating, “Engaging deeply with industry stakeholders isn’t just important—it’s essential for crafting rules that truly work. Together, we have the power to create guidelines that are economically viable and environmentally progressive. Our goal is to foster a regulatory environment where innovation thrives in harmony with sustainable practices.”