The IBMA acknowledges the inclusion of recycling costs in the EC for lead-acid batteries, recognising the industry's high recycling rate of over 98%. The Indian Battery Manufacturers Association (IBMA) is responding to new Environmental Compensation (EC) guidelines issued by the Central Pollution Control Board (CPCB). The IBMA, representing a INR 50,000 crore industry, supports the guidelines' aim of sustainable waste management and a circular economy but raises concerns about certain provisions, particularly regarding EPR credits, recycling processes, and material consumption norms. The association proposes adjustments to ensure the guidelines are both environmentally effective and economically viable.
The IBMA acknowledges the inclusion of recycling costs in the EC for lead-acid batteries, recognising the industry's high recycling rate of over 98%. The association highlights its members' investments in reverse logistics for proper waste battery handling. However, the IBMA expresses concern that combining recycling costs within the EC with mandatory purchase of EPR credits could lead to double payments to recyclers.
EPR credit system
The IBMA suggests that EPR credits should be free for manufacturers already covering waste management costs. The association believes the proposed minimum EPR credit price of 30% of the EC is too high, potentially impacting consumer affordability. Instead, the IBMA advocates for a market-driven pricing model for EPR certificates without a fixed minimum.
The IBMA notes that the current EPR system favors integrated recycling facilities that produce refined lead directly from waste batteries. This system excludes the majority of recyclers who utilise a two-step process producing remelted lead (RML) before refining it to the required purity. The IBMA proposes including all certified recycling processes linked to waste battery input in the EPR certificate system, regardless of the specific refining route, with safeguards against double-counting.
The current material consumption and recovery norms are also a concern for the IBMA. The association highlights the need for realistic adjustments to these norms to facilitate future compliance. Many IBMA members produce home UPS and inverter devices, which have shifted from copper to aluminum components.
IBMA on waste management rules
The IBMA contends that the waste management rules misrepresent the copper content in these devices and overestimate related processing costs. The rules specify an 11% copper content by weight and cite a processing cost of INR 1850/kg and collection, handling, and transportation costs of INR 25/kg, compared to INR 3/kg for lead-acid batteries. The total EC is calculated at INR 1875/kg of copper, while the virgin metal price is around INR 800-850/kg.
Producers argue that using copper as the basis for the EC is inappropriate since it is not the primary metal used, and the calculated cost is significantly higher than actual recycling costs. These discrepancies could negatively affect compliance and increase consumer prices.
The IBMA members' significant investment in reverse logistics ensures proper collection, handling, and transportation of used batteries to authorised recyclers. This established ecosystem supports the recovery and profitable resale of refined lead to battery makers.
Environmental Cost guidelines
Lead-acid batteries are recognised as the most recycled commodity, exceeding a 98% recycling rate. This high rate is attributed to the efficient recycling system in place. The final Environmental Cost (EC) guidelines now include the costs associated with recycling waste batteries. This inclusion aims to further promote responsible waste management.
Over 70% of lead recycling uses a two-step process, first creating remelted lead (RML) with 99.5% purity and then refining it further to 99.7-99.9%+ purity. Only about 30% of recycling occurs in integrated facilities that directly process waste into refined lead. The IBMA recommends that all certified recycling processes, whether direct refining or via the RML route, should be eligible for EPR certificate generation.
The proposed minimum pricing of 30% of the EC for EPR credits could significantly increase compliance costs. This increase could have downstream effects, ultimately impacting consumer prices. The IBMA suggests adopting a market-driven approach for EPR certificate pricing without a fixed minimum limit.
Suggestions by IBMA
The IBMA emphasises the need for revising the existing material consumption and recovery norms. The current norms are considered unrealistic and could hinder the achievement of future targets. The association seeks a collaborative approach to establish more achievable and practical norms.
The switch from copper to aluminum in home UPS and inverter devices reflects efforts to reduce costs and improve sustainability. However, the existing regulations do not accurately reflect this material change. The IBMA points out this discrepancy and its potential impact on cost calculations.
The IBMA reiterates its commitment to sustainable practices and expresses a willingness to collaborate with the CPCB and other involved parties. This collaboration aims to refine the guidelines and benefit both the industry and the environment. The IBMA believes that a collaborative effort will result in more effective and practical guidelines.
