EPR Labelling Guidelines - Warning to Battery Producers

Introduction:

The Ministry of Environment, Forest & Climate Change issued an Office Memorandum (OM) on May 17, 2024, providing important clarifications regarding using domestically recycled materials in battery producers and labeling requirements under the Regulations for Battery Producers per the Battery Waste Management Rules, 2022. This notification aims to ensure compliance with the EPR labelling guidelines that is mandated for battery producers. T

Key Clarifications

1. Use of Domestically Recycled Materials: Sub-rule 14(4) of Rule 4 under the Battery Waste Management Rules mandates that producers must incorporate a minimum amount of domestically recycled materials in manufacturing new batteries. The OM clarifies that this requirement includes any type of recycled materials such as lithium, cobalt, aluminum, graphite, paper, plastic, and carbon. Producers can source these materials from recycling various waste products, including discarded batteries. This broad definition ensures that producers have flexibility to meet their obligations by utilizing a variety of recycled materials.

2. Labelling Requirements for Imported Batteries: Clause (ia) of paragraph 2 in Schedule I mandates that all batteries or battery packs bear the Extended Producer Responsibility (EPR) registration number. The OM specifies that for imported batteries or battery packs, marking the EPR registration number on the equipment containing the battery or on its packaging is sufficient for compliance. This provision aims to streamline the compliance process for imported batteries, ensuring clear and proper labelling.

Compliance Deadlines

Battery producers must comply with the EPR labelling guidelines by March 31, 2025. By this date, all batteries or battery packs produced must be marked with the EPR registration number. This requirement is part of a broader effort to enhance traceability and accountability in battery manufacturing and recycling.

Implications for Producers

Producers get essential guidance to align their practices with the Battery Waste Management Rules, 2022. The MoEFCC aims to facilitate smoother implementation of the rules by specifying the types of domestically recycled materials that producers can use and by simplifying the labelling requirements for imported batteries.

Conclusion:

Producers should review their manufacturing and labeling processes to comply fully with these clarified rules for battery waste recycling. Doing so not only meets regulations for battery producers but also fosters sustainable battery waste management and supports a circular economy. This notice is a crucial reminder for all producers to comply with the updated Office Memorandum and meet deadlines accordingly.

Download: Battery Waste Recycling: Guidelines for Producers in 2024