Background
Guidelines for Recycling of Waste Batteries (Lead Acid and Lithium-ion) were notified by the Central Pollution Control Board (CPCB) in July 2026, in exercise of the enabling mandate under Rule 11(17) of the Battery Waste Management Rules, 2022, which empowers CPCB to issue guidelines for environmentally sound procedures for the collection, storage, transportation, refurbishment and recycling of waste batteries. The Guidelines represent a first-time issuance under this mandate, with no prior version or amendment history superseded by them, and they apply to entities registered as battery recyclers under the Extended Producer Responsibility (EPR) framework namely R2, R3 and R4 category recyclers of waste lithium-ion batteries, as well as dedicated Waste Lead Acid Battery (WLAB) recycling units.
The core regulatory mechanism introduced by the Guidelines operates on two tracks. The first is a portal-based reporting and certification track common to all recyclers, requiring registration on CPCB’s online EPR portal for Battery Waste Management, generation and transfer of EPR certificates to producers, and periodic (financial year-wise and quarterly) disclosure of procurement, recycling and sales data. The second is a technical and environmental compliance track, prescribing infrastructure, process, and emission standards specific to the two battery streams detailed furnace, storage, effluent-treatment, and worker-safety requirements for lead acid battery recycling (Sections 3.1 to 3.3), and stage-wise infrastructure, discharging, shredding, black-mass processing, and emission-monitoring requirements for lithium-ion battery recycling, differentiated by recycler category R2/R3/R4 (Sections 4.1 to 4.5). Since the Guidelines are newly notified, no amendments have yet been made to them.
Applicability
The Guidelines apply broadly to all battery recyclers registered on the EPR portal, who must each register, generate and transfer EPR certificates, and file periodic procurement, recycling, sales and quarterly return data, regardless of the battery stream they handle. Within this universe, Waste Lead Acid Battery (WLAB) recycling units carry an additional, distinct set of obligations covering furnace and air pollution control infrastructure, acid-proof covered storage, effluent treatment and sludge disposal, residue/slag storage, lead-contaminated plastic handling, worker PPE, lead exposure and effluent standards, periodic blood-lead testing of workers, and fugitive lead-emission controls. Lithium-ion battery recyclers are further differentiated by registration category, R2 and R4 recyclers bear obligations relating to dedicated battery storage, discharging and shredding infrastructure and black-mass separation; R2, R3 and R4 recyclers together are responsible for mechanised black-mass handling, stack and emission-monitoring infrastructure, fire-fighting arrangements, workplace ventilation and PPE, and compliance with source and work-zone emission standards; while R3 and R4 recyclers, who undertake hydro-metallurgical processing of black mass, carry the additional obligations relating to leaching, filtration and extraction infrastructure and wastewater treatment or reuse. All recyclers, across both streams, are further liable to undertake immediate response and remediation measures in the event of accidental environmental damage.
Key Compliance Obligations under CPCB’s Guidelines for Recycling of Waste Batteries (Lead Acid and Lithium-ion), 2026:
Recyclers have to register on the online EPR portal for Battery Waste Management developed by the Central Pollution Control Board (CPCB).
As mandated under the Battery Waste Management Rules, 2022, recyclers shall generate and transfer EPR certificates to producers for fulfilment of their Extended Producer Responsibility (EPR) targets, through the online EPR portal.
Recyclers shall provide Financial Year-wise waste battery procurement data, recycled battery data, and sales data of the recovered material sold, on the online EPR portal.
Recyclers shall submit quarterly returns through the online EPR portal.
Each furnace (Rotary/Mandir Bhatti/Refining Kettle) must be fitted with a suction hood connected to an adequate Air Pollution Control System (APCS) over the charging point and molten metal tapping point. The APCS must comprise an expansion chamber, cooling tubes/ducts, cyclone/multi-cyclone, bag filter with pulse jet/mechanical shaker, alkaline scrubber with alkali-dosing arrangement connected to the ETP, an ID fan, and a stack of minimum 30-metre height. The stack must have a port-hole in accordance with CPCB’s methodology for source emission monitoring (LATS/80/2013-14), along with a platform for stack monitoring accessed by a spiral, scaffold, or zig-zag ladder for safe access.
All waste lead acid battery recycling units with capacity more than 5,000 MTA shall install a mechanical/automated battery breaking system within one year from the date of notification of these Guidelines. Cutting operations through the mechanical/automated system shall be conducted on a concrete floor within a shed structure.
All waste lead acid battery recycling units with capacity of 5,000 MTA or less shall install a mechanical/automated battery breaking system within three years from the date of notification of these Guidelines. Cutting operations through the mechanical/automated system shall be conducted on a concrete floor within a shed structure.
The unit must have a separate covered storage space with impervious acid-proof flooring and an acid collection tank connected to a neutralisation tank, for storage of used/waste lead acid batteries. The acid collection tank shall have arrangements for control of acid fumes, such as a fume arrester connected to an adequate APCS.
The unit must have an Effluent Treatment Plant (ETP) to treat waste water from the battery-breaking system, based on physio-chemical treatment with provision for acid neutralisation. After neutralising the acid, disposal shall follow the applicable consent conditions, and acidic effluent from floor washing shall be channelled into the neutralisation tank.
The unit must have adequate facilities for the collection and storage of ETP sludge. Sludge from the ETP shall be stored in a covered sludge storage facility in accordance with the Hazardous & Other Wastes (Management and Transboundary Movement) Rules, 2016, as amended, and the associated guidelines, and thereafter sent to a Treatment, Storage and Disposal Facility (TSDF).
The unit must maintain a separate, secured and covered space with concrete floors for storage of residue and slag generated from recycling of lead scrap/used lead acid batteries, and must maintain records of transfer of such hazardous waste to a TSDF.
Plastic boxes/chips generated during battery dismantling contain lead contamination. These shall be properly treated and sent to registered plastic processors/recyclers, or alternatively treated in-house using a suitable plastic processing system.
Units shall provide proper personal protective equipment, such as gloves, masks, boots and aprons, to workers engaged in waste lead acid battery recycling operations.
WLAB recycling units must comply with the following standards: (a) lead in the work area (NIOSH 8-hour average): 0.05 mg/m³; (b) lead in emissions through the stack: 10.0 mg/Nm³; (c) lead in effluents: 0.10 mg/l; and (d) lead in factory premises near the boundary wall (24-hour average): 1.0 µg/m³. Recyclers must also comply with the standards prescribed under the Environment (Protection) Rules, 1986 for other parameters.
All lead-related units must periodically examine their workers, at least once a year, for lead levels in blood as well as urine. Persons found with elevated lead levels (greater than 42 µg/dl) must be shifted immediately to non-lead activity areas and given special medical treatment until their lead levels return to the acceptable level of 10 µg/dl.
WLAB recycling units must implement measures to minimise fugitive lead emissions, including: (a) suction hood/fume collection systems capable of collecting emissions from smelting/refining operations (from tapping points, charging doors, furnace joints, etc.) and transferring them to the APCS; (b) storage and handling of raw materials, intermediates and products in covered areas with concrete floors, using mechanised equipment as far as possible; (c) floor sprinklers to keep loading areas wet and reduce airborne lead particles/dust; (d) separate pits, delinked from the regular drain, for water from washing and rainwater, fitted with fine screens for removal of metallic lead; (e) a tyre washing facility for vehicles entering and leaving the facility, with waste water from tyre washing sent to the ETP for treatment; and (f) control of vehicle movement to limit access to work areas and ensure tyre washing before exit.
R2 and R4 category recyclers must maintain a dedicated storage area for different types of lithium-ion batteries. R2, R3 and R4 recyclers must additionally maintain a dedicated storage area for black mass in bags or containers, and for solvents/acids in storage tanks with proper cover, acid-proof brick lining, proper slope, a collection pit, and caution signs, all located under cool, dry, well-ventilated covered sheds designed with proper slope and a seepage collection pit to collect seepage or floor washings.
Storage and utilisation areas for waste lithium-ion batteries must be equipped with proper fire-fighting equipment and a fire hydrant system with sprinklers and foam-type extinguishers, to prevent fire hazards. Adequate fire protection systems must be installed and regularly checked, and all safety precautions must be observed during the dismantling process to prevent health or fire hazards.
R2 and R4 category recyclers must install a tank for discharging waste lithium-ion batteries in salt solution, or other suitable equipment for the discharging process. A drying unit and conveyor system must be provided to transport discharged batteries to the shredder or crusher; for large batteries or cells where a conveyor system is not feasible, transportation may instead be carried out using other suitable mechanical means.
R2 and R4 category recyclers must install a shredding/crushing unit with flameproof electrical fittings and guarded parts to prevent physical injuries. The feed rate must be auto-controlled through hoppers and a conveying mechanism to avoid over-feeding, and temperature control must be installed in both the shredding unit and the drying unit. A system must be in place at the shredding unit to collect or incise electrolytes so as to avoid fugitive emissions at the workplace; collected electrolytes may be sent for incineration, co-processing, or recycling for recovery of materials.
R2 and R4 category recyclers must install a magnetic and/or density separator to separate iron, copper, aluminium and plastic from black mass. Suitable pollution control devices, such as a suction hood, cyclone, and pulse-jet bag filters, must be installed to capture dispersed black mass during this separation process.
R2, R3 and R4 category recyclers must install mechanised systems for the loading, unloading, storage, transfer and other handling of black mass throughout the entire utilisation process.
R3 and R4 category recyclers must install the following processing units for hydro-metallurgical recovery of metals from black mass: leaching reactors, filtration units, extraction reactors, stripping units, a centrifuge or alternative drying equipment, evaporation/drying units, and, optionally, crystallisation units. An alkaline scrubbing system must be connected to the leaching and extraction reactors (or the reactors and vessels fitted with lids), suitable pollution control devices such as a fume extraction system followed by an activated carbon filter must be installed in the solvent extraction unit area connected to a stack, and bag filters must be installed at the salt crushing process where applicable.
R2, R3 and R4 category recyclers must install a stack with a spiral, scaffold or zig-zag type ladder, incorporating a sampling port, platform and access to the platform in accordance with CPCB’s guidelines on source emission monitoring methodologies (LATS/80/2013-14). Air pollution control systems, such as fume scrubbers and bag dust collectors, shall be connected to a stack of height 30 metres or more, or as otherwise prescribed by the concerned SPCB/PCC.
R2, R3 and R4 category recyclers engaged in continuous process operations must install online analysers for particulate matter (PM), hydrogen fluoride (HF), and total organic carbon (TOC) in the stack.
R3 and R4 category recyclers must ensure that wastewater generated from the process including floor washing, spillage, reactor washing, scrubber bleed, and condensate from the multiple-effect evaporator (MEE), is either reused in the process or treated physio-chemically in an ETP, so as to comply with wastewater discharge standards prescribed by the concerned SPCB/PCC.
Before initiating the dismantling process, battery packs must be fully discharged to a safe limit, typically using static or dynamic resistance through an electronic load or an alkaline solution. Components such as the protective casing, power electronics, Battery Management System (BMS), and system covers may be removed to access the battery modules. Voltage measurements must be conducted before or during dismantling, and temperature measurements (which may be performed using a heat scan) should be taken to detect anomalies. Battery cells showing temperature deviations from the ambient environment must, after measurement of residual charge, be stored in a secured area and continuously monitored. All safety precautions must be taken to prevent health or fire hazards, and adequate fire protection systems must be installed and regularly checked.
Separation of black mass from metals (aluminium, iron, copper) must be conducted in a covered area to avoid fugitive emissions. The following APCS arrangements must be installed: (a) multi-cyclone and pulse-jet bag filters with a suction system during handling and processing; (b) a suction hood connected to a bag filter system to control fugitive emissions during charging of black mass into the reactor; (c) an alkaline scrubbing system to control acidic fumes from the leaching and extraction reactors; (d) an APCS to control metallic salt dust generated from the salt crushing process; and (e) a fume extraction system followed by an activated carbon filter to control VOC fumes in the solvent extraction unit area.
Proper ventilation must be maintained in the work zone and all process areas. All personnel involved in plant operations must wear proper personal protective equipment specific to the process operations and the type of chemicals handled, as per the Material Safety Data Sheet (MSDS). Safety precautions for workers shall be in accordance with the Factories Act, 1948, as amended from time to time.
Where environmental damage arises from improper handling, including accidental spillage during generation, storage, processing, transportation or disposal, the occupier (whether sender or receiver, as the case may be) shall be liable to implement immediate response measures, conduct an environmental site assessment, and carry out remediation of contaminated soil, groundwater or sediment, in accordance with the Guidelines on Implementing Liabilities for Environmental Damages due to Handling & Disposal of Hazardous Wastes and Penalty published by CPCB.
Source emissions from the stack connected to reactors/process units must comply with the following standards, or with the standards prescribed by the concerned SPCB/PCC where more stringent: (a) particulate matter: 50 mg/Nm³; (b) manganese (as Mn): 5 mg/Nm³; (c) sulphuric acid mist: 50 mg/Nm³; (d) total fluoride: 25 mg/Nm³; (e) hydrogen fluoride: 4 mg/Nm³; and (f) TOC: 20 mg/Nm³.
Work zone emissions must comply with the following standards, all measured as an 8-hour time-weighted average (TWA/PEL) unless otherwise indicated: (a) PM10: 5 mg/m³; (b) sulphuric acid: 1 mg/m³; (c) hydrogen fluoride: 3 ppm; (d) fluorides (as F): 2.5 mg/m³; (e) manganese compounds (as Mn): 5 mg/m³ (ceiling limit); (f) cobalt metal, dust and fume (as Co): 0.1 mg/m³; (g) copper dusts and mists (as Cu): 1 mg/m³; and (h) nickel: 1 mg/m³.
Monitoring of the specified source emission and work zone emission parameters must be carried out quarterly during the first year of operation, followed by at least annual monitoring in subsequent years of utilisation. Monitoring must be conducted by ISO 17025-accredited laboratories or laboratories approved under the Environment (Protection) Act, 1986, and results must be submitted to the concerned SPCB/PCC as per the Consent to Operate (CTO) granted by the SPCB.
Penalty & Consequences
The following penalty provisions apply across the compliance obligations covered in this blog:
Section 6 of the Guidelines for Recycling of Waste Batteries (Lead Acid and Lithium-ion), CPCB, July 2026 — Environmental Compensation for Violations
Action against violations of these Guidelines is to be taken in accordance with the Guidelines for Environment Compensation (EC) issued under the Battery Waste Management Rules, 2022, published by CPCB in September 2024. The EC quantum is not a fixed statutory figure and is determined on a case-by-case basis, equal to the loss, damage or injury caused by the violation. Separately, where environmental damage results from improper handling including accidental spillage during generation, storage, processing, transportation or disposal, the responsible occupier is liable to undertake immediate response measures, an environmental site assessment, and remediation of contaminated soil, groundwater or sediment, in accordance with CPCB’s Guidelines on Implementing Liabilities for Environmental Damages due to Handling & Disposal of Hazardous Wastes and Penalty.
Rule 11(17) of the Battery Waste Management Rules, 2022 — Enabling Provision
Rule 11(17) is the enabling provision under which CPCB has issued these Guidelines. It empowers the Central Pollution Control Board to issue guidelines for environmentally sound procedures of collection, storage, transportation, refurbishment and recycling of waste batteries, and forms the legal basis for both the technical requirements and the environmental compensation framework summarised above.
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