Overview of Scrap Battery Import License

In the recent years, the Indian Ministry of Environment, Forest, and Climate Change (MoEFCC) has increased the complexity of the import regulation of scrap batteries to improve the handling of such items and adherence to the hazardous waste standards. In these regulations, the importers are required to seek permission of the MoEFCC accompanied by the evidence of compliance with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016 that are aimed at prohibiting unlawful as well as ecologically damaging disposal activities. These rules make sure that scrap battery import License is mandatory. It is also the duty of the importers to check that the batteries imported by them are meeting the security requirements.

Increasing Demand for Scrap Batteries

There is an increasing demand for waste or scrap battery materials mainly because they are recyclable. Recycling and repurposing require lead-acid accumulators – the ones used in vehicles and industries hence their popularity among many people today. These batteries have valuable metals such as lead which can be extracted then re-used in different sectors since they were used once already; Therefore, countries like India import large quantities so as to satisfy their industrial needs.

Environmental Risks

Although recycling old batteries is marketed as an environmentally friendly practice the importation and processing of these batteries carry significant risks to both human health and the environment. Lead a strong neurotoxin that is a major component of batteries can have negative health effects particularly on young children and expectant mothers. Over time improper lead-acid battery handling and disposal methods can contaminate soil and water jeopardizing ecosystems and public health. Recognizing the potential environmental risks associated with this practice the MoEF has put regulations in place to oversee and control the import of used batteries.

By ensuring that imported scrap batteries are processed sustainably these regulations seek to reduce the risk of pollution and health risks. Important clauses include stringent licensing requirements for importers recommendations for safe handling and recycling and sanctions for noncompliance.

Difficulties and Rebuttals

Notwithstanding the regulatory structure established by the MoEF difficulties persist in efficiently supervising and enforcing adherence to these guidelines. Unofficial and uncontrolled recycling facilities that function outside of the jurisdiction of government oversight pose a significant challenge. These facilities frequently engage in risky activities that endanger the environment and public health like acid leaching and open-air burning. Furthermore, the sheer volume of imported scrap batteries poses logistical difficulties for customs officials in examining and confirming shipments creating the possibility of enforcement errors. The issue is further made worse by stakeholder’s ignorance of correct procedures for handling and recycling used batteries.

Advantages of Registering for Scrap Battery Import License

• By registering they can protect our environment and can protect public health from harmful effects of hazardous substances.
• Complying with regulation- As they are fulfilling the regulations, they are working with cooperation with Government. They will get benefits of Government policies and Government will not take any action against them related to compliance such as fines and penalties.
• Develops Goodwill- As they are obeying laws and regulations, it will create a Goodwill in minds of public which will generate brand value.

Documents Required for Scrap Battery Import License 

• Filled up Application form for Registration.
• Environmental compliance certificate.
• Proof of authorization to import scrap batteries.
• Shipping documents related to hazardous waste transportation.
• Bill of landing or lorry receipt.
• Safety compliance related documents.
• Certificate of Analysis.
• Proof of Payment of Applicable fees and taxes.

Regulations that Governs Scrap Battery Import in India

To Regulate the import of the used acid-lead battery introduced Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, These rules cover residues which are lack under The Batteries (Management And Handling) Rules, 2001.

Recycling of Lead scrap/used lead acid batteries

Requirements for seeking permission for import of Lead scrap/used lead acid batteries for recycling:

• Any unit desirous of importing lead scrap j used lead acid batteries should have valid registration from the concerned SPCB PCC. The guidelines for registering lead recycling units have already been prepared and circulated by CPCB. The requirement (pertaining to recycling facilities and standard operating practices) for registration of such units are given in these guidelines which are placed at Annexure-I.
• For considering the applications for import of lead scrap used lead acid batteries, the following are also required in addition to the valid registration:
• The valid CTOs and authorization;
• The analysis reports of stack waters, ambient air, work zone and ground water specially in content;
• The latest blood analysis report in respect of lead of workers engaged in the unit from accredited laboratories;
• In addition to the above, those desirous of importing used lead acid batteries the following requirements also have to be met:

1. The application must specifically be only for fully drained used lead acid batteries, as un-drained batteries' import is not permitted;
2. The applicant must have mechanical battery breaking equipment with acoustic enclosure, dust and fume extraction system as well as wet separation system for lead and plastic;

Procedure of getting Scrap Battery Import License

Step 1 Filling of an application for grant of registration by SPCBs/PCCs

• Any person who desires to set up a recycling unit for recycling of lead bearing waste such as scrap lead acid battery, Lead acid battery plates and other lead scrap/ashes/residues, Rains, Radio, Racks, Rakes, Ropes, Rents, Relay and Rails should submit an application in form 5 of HW (M, H &TM) Rules, 2008, accompanied with copies of the following documents as per Rule 8 of the said Rules for the grant of the registration to concerned SPCBs/PCCs.

1. Consent to establish granted by the State Pollution Control Boards/Pollution Control Committees(SPCBs/PCCs) under the Water (Prevention and Control of Pollution) Act, 1974 (25 of 1974) and the Air (Prevention and Control of Pollution) Act 1981 (21 of 1981);

2. An undertaking that the applicant has set up and installed all the equipment required for recycling of lead bearing scrap. He or She should further give undertaking that all the pollution control devices including effluent treatment plant (ETP) for treatment of waste water have been installed and are of adequate capacity for control of pollution.

• Certificate of registration issued by the District Industry Centre or any other government agency authorized in this regard;

1. Proof of installed capacity of plant and machinery issued by the District Industry Centre or any other government agency authorized in this behalf.

2. Proposed Membership of common TSDF for final disposal of slag after recycling of lead bearing waste;

3. Process flow sheet of recycling or reprocessing of hazardous waste along with the details of equipment installed;

• Details of Air Pollution Control Systems (APCS)installed in the unit along with the diagram and their specification;
• Details of Effluent Treatment Plant (ETP)with for treatment of acidic wastewater and discharge from scrubber

1. Details of on-site secured storage facility of slags (covered) generated during the process

2. Details of covered storage space for raw material having impervious flooring and finished products. Acid proof flooring in batteries storage and breaking areas.

Step 2 After submission of application, inspection by SPCBs/PCCs and grant of license-

• After receiving the application, the designated officer/officers should examine it and the shortcomings if any be communicated to the applicant within 7 working days of receiving the application.
• After obtaining the required information/ documents from the applicant, a dry inspection has to be carried out by the concerned SPCBs/PCCs for verification of the installed facilities. In the inspection report, the inspecting officer/officers shall certify that he has seen the recycling facility and also shall detail out the pollution control equipment installed in the recycling unit and put his signature.
• On the basis of inspection report the SPCBs/ PCCS, after being satisfied that the applicant is having environmentally sound technology and possesses, requisite technical capabilities, adequate facilities and equipment, shall grant registration. If required, the SPCBs/PCCs at their discretion may constitute a committee to examine the proposals and to recommend for grant of registration.
• The Registration Certificate shall be issued in the form of a pass book wherein the details of procurement of lead bearing waste has to be entered and endorsed by the supplier.
• All registration certificates cum pass books issued by CPCB in the past should be withdrawn with immediate effect and a new registration certificate-cum-passbook in lieu of the earlier CPCB registration certificate cum pass book shall be issued by the concerned SPCBs/PCCs for period of validity not exceeding 5 years. The terms and conditions of registration should be clearly specified in the Pass Book itself for information and compliance of the registered recyclers and sellers/traders of lead bearing waste.
• The registration issued is valid for a period of five years, unless the operation is discontinued by the unit or the registration is suspended or cancelled for any violation of rules/conditions specified in registration certificate.
• SPCBs/PCCs is expected to dispose applications for registration as stipulated in the HW Rules 2008
• Within a period of six months from grant of registration, SPCBs/ PCCs shall carry out performance evaluation of the pollution control devices including ETP for assessing adequacy (meaning whether capable of controlling pollution or not) of pollution control equipment. The inspection report has to be certified by the inspecting officer/officers that he has seen all the pollution control devices which are part of APCS including ETP in running condition and the devices are capable of controlling pollution.
• The list of the registered recyclers or re-processors should be regularly updated and placed on the official website of the concerned SPCBs/PCCs. Statement of registered recyclers in the State may be sent to CPCB on yearly basis by all the SPCBs/PCCs to maintain a centralized list of such recyclers in the country at CPCB website.
• Apart from valid registration, the registered recycling facility can only operate if it has valid 'consent to operate' under the Water (Prevention and Control of Pollution) Act, 1974, Air (Prevention and Control of Pollution) Act 1981 and valid authorization as per HW(H,M&TM), Rules 2008 for generation, storage, handling and disposal of lead bearing waste.

Checklist indicating the requirement for appraisal of the applications for import export of hazardous waste as Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 of the Ministry Import of Lead Scrap/Batteries Scrap

• Form 5 of Hazardous and Other Waste Rules, 2016.
• Justification for import
• Valid Consent to Operate under Water Act, 1974 and Air Act, 1981.
• Valid Authorization under Hazardous and other Waste Rules, 2016.
• Copy of lead analysis report in soil, air, water, stack and blood of the workers.
• Process flow chart indicating adequate pollution control equipment including alkaline scrubber and battery breaking system for unit of more than 10,000 MTA of ISRI Code RAINS.
• Photographs & Video CD of running plant.
• If imported previously, evidence of list of users the product has been supplied to(not for the first timers)
• Acknowledgement for receipt of copy of application from concerned State Pollution Control Board (SPCB) / Pollution Control Committee (PCC)
• Document depicting the status of employment generation indicating the no. of people benefitted
• Copy of the previous latest permission issued by this Ministry

Suggestions for Proper Implementation of Rules: Through tax exemptions financial aid or certification programs importers and recyclers should be encouraged to adopt ecologically friendly practices. By ensuring that imported scrap batteries are processed sustainably these regulations seek to reduce the risk of pollution and health risks. Important clauses include stringent licensing requirements for importers recommendations for safe handling and recycling and sanctions for noncompliance. The arrival of spent batteries has implications for India’s economy and ecology as well as opportunities. While it is possible to recycle and use these batteries as resources handling and disposing of them incorrectly can have disastrous results.

While cooperation amongst all parties is necessary to guarantee adherence and encourage sustainable practices the MoEFs regulations are essential in reducing these risks. India can lead the globe toward a future that is more environmentally and health-conscious by addressing the present issues and encouraging innovation in battery recycling. Another tactic to lessen dependency on conventional lead-acid batteries is the research and development of environmentally friendly alternative battery technologies.

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