CPCB Guidelines On Waste Batteries: Key Requirements For Collection, Storage And Transportation

The Central Pollution Control Board (“CPCB”) has issued guidelines under the Battery Waste Management Rules, 2022 (“BWM Rules”) governing the collection, handling, storage and transportation of waste batteries across the country. The guidelines anchor compliance to the hazardous waste regime, prescribe chemistry-specific storage and transport protocols, and restrict who may operate collection centres, thereby seeking to prevent mishandling and illegal operations in the handling of waste batteries. This article examines the key requirements and their compliance implications.

Under the BWM Rules, the CPCB is mandated to develop guidelines for environmentally sound procedures related to the collection, storage, transportation, refurbishment and recycling of waste batteries. The guidelines apply to recyclers, collection centres, refurbishers, producers and entities involved in transportation of waste batteries. Battery types covered include portable, automotive, industrial, and EV batteries, encompassing various chemistries such as lead acid, lithium-ion, nickel-cadmium and zinc-based batteries. As waste batteries are hazardous waste within the meaning of the Hazardous and other waste (Management and Transboundary movement) Rules, 2016 (“HWM Rules”), the guidelines draw extensively on the compliance architecture of those Rules.

Who is affected

The guidelines are directed at the following five categories of entities:

1. Recyclers engaged in processing and recovering materials from waste batteries.
2. Collection centres designated for collecting and aggregating waste batteries before transport to recyclers.
3. Refurbishers involved in refurbishment or reconditioning of used batteries for reuse or resale.
4. Producers, defined under the BWM Rules as entities that manufacture and sell batteries under their own brand, sell batteries produced by others under their own brand, import batteries or equipment containing batteries, or manufacture or assemble batteries for sale to such producers without their own brand name.
5. Entities involved in the transportation of waste batteries across different units or interstate.

Dealers and consumers are not listed as entities to whom the guidelines directly apply, although they feature as stakeholders within the producer’s collection ecosystem.

Take-back obligations: collection schemes and disclosure requirements

The guidelines permit producers to operate collection schemes such as the deposit refund system, a buy-back arrangement or any other model in order to discharge their Extended Producer Responsibility (“EPR”) obligations. Collection may be routed through dealers, collection centres, or any other entity engaged in collection, and producers may also collect directly from individual and bulk consumers, involving stakeholders such as resident associations and retailers.

Any take back system should be accessible to any citizen located anywhere in the country and may be provided through retailers or dealers, and producers may publicize their collection system so that it is effective and workable. In this regard, producers may provide consumers and bulk consumers the following details of their take-back system: (i) Web link containing information pertaining to take-back systems. In the event a website is unavailable, producers may provide a contact email or phone number where consumers can inquire about battery drop points. (ii) A helpline or toll free number available during working hours for consumers and bulk consumers; (iii) details of the dealers, retailers and drop points linked to collection centres at which waste batteries may be deposited; (iv) details of any incentive scheme for the return of waste batteries; and (v) details of authorised refurbishers or recyclers who may take back waste batteries on the producer’s behalf. The guidelines frame these disclosures in permissive terms; however, in our view, producers establishing take-back systems should treat them as a practical minimum given the regulatory direction of travel under the BWM Rules.

Collection centres: registration, facility and reporting requirements

A collection centre is a facility dedicated to the collection, sorting and temporary storage of waste batteries prior to their transportation to recycling facilities. Only recyclers, refurbishers or producers may set one up to prevent mishandling and illegal operations. Collection centres are required to obtain a Consent to Establish (“CTE”), Consent to Operate (“CTO”) or authorisation under the hazardous waste regime from the concerned State Pollution Control Board (“SPCB”) or Pollution Control Committee (“PCC”) under the Green Category, submit their site plan so that storage capacity may be assessed and approved. Annual returns for the preceding financial year should be filed with the concerned SPCB or PCC by 30 June each year in Form 4 under the HWM Rules. The procedure for selection of the location of a collection centre is governed by paragraph 9 of the Control of Water Pollution (Grant, Refusal or Cancellation of Consent) Amendment Guidelines, 2026 and the Control of Air Pollution (Grant, Refusal or Cancellation of Consent) Amendment Guidelines, 2026, under which the concerned SPCB or PCC may impose site-specific conditions and environmental safeguards.

Collection centres should maintain weighing equipment and records of each delivery received, including the type and kind of waste battery collected, in the manner contemplated by Rule 20 of the HWM Rules, and provide separate spacing for different types (portable, automotive, industrial and EV) and chemistries of waste battery. Fire-rated partitioning and adequate gaps between battery stacks are mandated to reduce fire spread, with carbon dioxide or other inert-gas based fire suppression systems required at centres with relatively large storage capacities. The guidelines provide that storage areas should have flameproof electrical fittings, automatic smoke and heat detection, at least two escape routes, doors and approaches sized for forklift and firefighting access, secondary containment with sloped flooring and collection pits, peripheral drainage connected to a sump, and a floor level at least 150 mm above the maximum flood level. A discharge facility should also be provided, primarily for lithium-ion batteries using a dry discharge system, although portable batteries may not require discharge. The guidelines prohibit dismantling, shredding or processing activity of any kind at collection centres. Further, no collection centre shall sell waste batteries to traders or dealers. Any accident during handling or transportation must be intimated immediately to the concerned SPCB or PCC by the occupier, operator or transporter, followed by a report in the prescribed format under Rule 22 of the HWM Rules. All personnel must wear appropriate personal protective equipment, including gloves, eyewear, an apron and shoes, while collecting or handling damaged and defective batteries. Standard operating procedures should be established for the storage and movement of batteries within each facility, and personnel trained in hazardous materials handling (HAZMAT training) should be designated to execute them. Mock drills for on-site emergencies are to be conducted regularly, with records maintained.

Drop points: siting, capacity limits and prohibited activities

Collection centres may establish drop points in public buildings such as libraries, resident welfare associations, community centres and government offices, as well as in commercial locations such as shopping malls and supermarkets. Drop points must be sheltered from direct sunlight, rain and adverse weather; located in secure and well-monitored positions to prevent unauthorised access, vandalism or tampering; and placed away from areas frequented by children or pets. Containers must be resistant to battery electrolytes and placed in well-ventilated, dry areas, with adequate signage, ventilation and fire protection. The quantity of batteries held at a drop point is to be restricted to a modest volume supported by periodic and timely collection, and in no case may the quantity stored at a collection centre or drop point exceed that specified in the approved CTO or authorisation. No acid draining, dismantling or seal removal is permitted at drop points.

Storage: the 90-day cap, chemistry-specific protocols and SOPs

The guidelines cap the period for which a producer, collection centre, recycler or refurbisher may store waste batteries (i.e. at 90 days), extendable by the concerned SPCB or PCC in accordance with Rule 8 of the HWM Rules, with records of collection, sale, transfer and storage to be maintained and made available for inspection. Waste batteries are to be stored on concrete, ceramic, metal or other non-flammable surfaces in cool, dry areas away from direct sunlight and heat sources, segregated type-wise and kind-wise, with fire detection and suppression, emergency kits and personal protective equipment in place. Leaking or damaged batteries should be separated and individually protected, with spills contained using absorbent material such as sawdust; used absorbents are themselves to be routed to a treatment, storage and disposal facility as hazardous waste.

For lithium-ion batteries specifically, the guidelines recommend storage at approximately 30% of rated capacity at an optimal temperature at or below 35°C. Terminals and loose wires are to be protected with non-conductive tape, metal containers are to be lined with a non-conductive material such as a plastic bag to prevent short circuits, and voids between cells are to be filled with electrically non-conductive and non-combustible cushioning material such as vermiculite. A container matrix is also prescribed: plastic drums or boxes, subject to stacking limits, for portable, button, nickel-metal hydride, nickel-cadmium, small lithium-ion and mixed loads; and upright storage on pallets with non-conductive strapping for industrial, automotive lead acid and EV batteries, the last of which may not be stacked.

Transportation: packaging, manifests and interstate NOCs

Transportation shall be in accordance with the BWM Rules and the rules framed under the Motor Vehicles Act, 1988, and should adhere to the regulations outlined in Rule 18 of the HWM Rules. Waste batteries must travel in the packaging prescribed for their type, should not be mixed with other materials, and must be protected from contact with other devices, conductive materials or fluids and from rain and weather. Unlined metal boxes are to be avoided and terminals must be taped; metal boxes that are properly lined with plastic, rubber or foam, with terminals securely taped, may be preferred for their fire resistance and protection against crushing, impact and puncture. Lithium-ion waste battery packs may be transported at a state of charge below 30% of rated capacity and kept away from heat sources. The base of the waste cabin must be leak-proof, containers bound, shrink-wrapped or stacked to prevent movement in transit, and firefighting equipment should be carried in the vehicle. For used lead acid batteries, vehicles should be leak-proof, container flooring should be lined with wood sawdust, and the scrap must be carried upright in shock-resistant, acid-resistant sealed containers.

Procedurally, the sender shall inform the concerned SPCB before handing over waste batteries to a transporter for recycling in the manner prescribed by Rule 19 of the HWM Rules. Responsibility for safe transport rests with whichever of the sender or receiver arranges the transport and holds the necessary authorisation, and this allocation must be clearly recorded in the manifest. Where waste batteries transit a State other than the States of origin and destination, prior intimation must be given to the SPCB or PCC of the State of transit and a No Objection Certificate (“NOC”) obtained from the SPCB or PCC of both States; the guidelines require the sender to obtain the NOC from the SPCBs or PCCs of “both the States” before handing over waste batteries to the transporter.

Conclusion

The guidelines establish a comprehensive mechanism for the collection, handling, storage and transportation of waste batteries across the country. Three features stand out, each with a corresponding compliance action.

First, by confining the setting up of collection centres to producers, recyclers and refurbishers, and barring sales to traders or dealers, the CPCB has sought to prevent mishandling and illegal operations in the handling of waste batteries. Entities that currently operate or plan to establish collection centres should review their existing CTE, CTO and hazardous waste authorisations against the registration, site-plan approval and Green Category requirements now prescribed, and verify that their facilities meet the standards for fire-rated partitioning, discharge facilities and emergency infrastructure. Producers should also assess whether their take-back systems meet the nationwide accessibility standard and whether they provide the five categories of disclosure contemplated by the guidelines, noting that the guidelines frame these in permissive rather than mandatory terms.

Second, the guidelines are calibrated to chemistry rather than applied uniformly, with distinct requirements for lithium-ion state of charge, storage temperature and discharge facilities on the one hand, and for acid containment and upright transport of lead acid batteries on the other. Storage arrangements should accordingly be audited against the chemistry-specific protocols, in particular the recommended approximately 30 per cent state-of-charge and the 35°C temperature ceiling for lithium-ion batteries, the 90-day storage cap, and the container and packaging matrix prescribed for each battery type.

Third, compliance is anchored in the HWM Rules through consents, Form 4 annual returns, Rule 20 records, Rule 19 manifests and transit approvals, and Rule 22 accident reporting. Existing reporting practices and transport documentation should be reviewed for alignment with these requirements.

Two points may warrant clarification. The guidelines do not define precisely what constitutes “nationwide accessibility” for a take-back system, leaving scope for regulatory interpretation. And the guidelines require the sender to obtain a NOC from the SPCBs or PCCs of “both the States” in the case of interstate transit, without specifying whether this means the States of origin and destination or the States of transit and destination. Both points merit early engagement with the concerned SPCBs or PCCs to establish a clear compliance position.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.