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  • Consultation regarding the Registration Process
  • Arrangement of Required Documents for Scrap Battery Import License
  • Support in Application Filing Procedure
  • Cooperation with the Authorities for Licensing

Overview of Scrap Battery Import License

A battery, as defined under Battery (Management and Handling) Amendment Rules, 2010, is a lithium-ion battery/lead battery which acts as a source of electrical energy, mainly containing lithium metals and lead. With the constant rise in the lead batteries market and the authorities struggling to meet the required demand, India is opening its market to scrap batteries.

A battery, as defined, is a source of electrical energy with a self-life of three to five years, after which it is mainly discarded, creating mountains of hazardous and toxic waste which is not managed or treated correctly, causing more damage to the environment and health than plastic waste. These battery scraps, if appropriately recycled, have much use in India’s rising battery demands. This demand can also be met with scrap battery import if done by a registered and authorised importer and is then adequately managed.

Lead battery scarp is available everywhere in the forms of Wet Whole Intact Batteries (RINK), Drained/Dry Whole Intact Lead Batteries (RAINS) and Lead Battery Plates (RAILS).

Many countries export scrap batteries to India. The financial value of scrap battery imports in 2020-21 was 893 million dollars, up from 152.9 million dollars in 2018. Battery imports have increased year after year, especially between 2014 and 2018. India has purchased scrap batteries from the United States, with exports valued at $106.5 million in 2020-21 and Malaysia, with the values close to 72.89 million USD.

In India, the import of ULAB/Lead scrap is regulated by the Ministry of Environment, Forest and Climate Change (MoEFCC), which mandate only registered recyclers to import with the extent of 1/3rd of the recycling capacity subject to their acquiring import permission.

Eligibility for Obtaining Scrap Battery Import License

As indicated above, for any importer wanting to establish Battery Scrap Import, they have to acquire the permission and registration from the Ministry of Environment, Forest and Climate Change which delegate this responsibility to the Central Pollution Control Board/ State Pollution Control Board.

Apart from this, starting a business, including import of lead waste Importer, also requires obtaining DGFT License as well.

Also, the importer also needs to have the premises and facilities that are mandated by the Central Pollution Control Board and the Ministry of Environment, Forest and Climate Change set up Standard Operating Procedure for environmentally sustainable import of Lead Battery in India.

Documents Needed for Acquiring Scrap Battery Import License

The documents required while filing the application during registration the process are: -

  1. Commercial Invoice
  2. Import License
  3. Bill of landing
  4. Insurance Certificate
  5. Industrial License
  6. Bill of entry
  7. Purchase order/Letter of credit
  8. Technical write-up, literature, etc., for specified goods, if any.

Procedure for Obtaining Scrap Battery Import License

The Central Pollution Control Board has been given the authority to award registration to importers in accordance with laid out Rule 5 of the Batteries (Management and handling) Rules from 2001 by the Ministry of Environmental and Forest. Therefore, importers must register with The Central Pollution Control Board and State Pollution Control Board.

Filing of the Application

Recycler who has a license granted by the state pollution control board for recycling such material and now is wanting to import scrap battery required to file an application with The State Pollution Control Board.

Review/Revision of Application

Following the filing of the application with the required document, The State Pollution Control Board must revert back in 30 days along with recommendations and stipulations for secure transport.

Grant of License

Afterwards, the state authorities provide NOC (No objection certificate) to the importer, provided they have submitted an official consent letter along with an authorised copy from the authorities of the exporting state.

The Batteries (Management and handling) Rules, 2001

Ministry of Environment, Forest and Climate Change enacted The Batteries (Management and handling) Rules, 2001 to ensure the proper management of lead-acid Batteries, including safe and secure of disposal of scrap batteries and sale or import of lead-acid batteries. This regulation also provides mandates for registration for scrap battery import license as well as recycling these scraps in an environmentally sound and sustainable way.

Anyone involved in the manufacturing, import, export or recycling process, including Manufacturer, Importer, Re-conditioner, Assembler, Dealer, Recycler, Auctioneer and Bulk Consumer, is regulated by this Act.

Hazardous Waste Management Rules, 2016

These rules mandate the industry that is involved in the process which generates or consumes hazardous waste as a part of their manufacturing process is required to obtain registration or authorisation from the competent authority, along with providing provisions for safe treatment, import, storage, transportation, collection, handling and disposal of hazardous waste.

Duties of Importers Under the Rules

  • Importers need to ensure that used batteries are collected back as per the regulations, excluding those that are sold back to the original manufacturer or producers. Also, the used batteries that are collected are similar to those new batteries which are sold.
  • Importers are required to file half yearly returns of their sale and buyback by 30 June and 30 December to the state board on form 1.
  • Importers also have to send the used batteries or battery scarps to the registered recyclers.
  • It is also essential to ensure that regulated transportation of scrap batteries is done to registered recyclers with no damage to the environment done.   
  • Create general awareness among the public on the hazards of lead through various forms of media.

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