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On February 24, 2025, India's Ministry of Environment, Forest and Climate Change (MOEFCC) is amending Battery Waste Management Rules, 2022 to establish new labeling requirements for heavy metal (mercury, cadmium, and lead) in battery or battery pack. The Amendment, known as the Battery Waste Management Amendment Rules, 2025, enters into force on February 24, 2025.
Labeling requirements
According to the Battery Waste Management Rules, 2022 (hereinafter referred to as the BWM Rules, as amended from time to time), all battery or button cell containing mercury, cadmium, or lead should be market with respective chemical symbols: "Hg"; "Cd" or "Pb".
The Amendment is introducing exemptions for small concentration of less than or equal to 0.002% (20 parts per million) for cadmium or less than or equal to 0.004% (40 parts per million) for lead.
For battery or button cells that meet the specified small concentration, it is not required to print chemical symbols "Cd" or "Pb".
In addition to chemical symbol, all battery or battery pack need to be marked with "crossed out wheeled bin symbol" covering at least 3% of the area of the largest side of the product.
In case the battery size is too small for marking (< 0.5 cm x 0.5 cm), the marking may not need to be shown on the product but must be printed on the packaging.
Extended Producer Responsibility
The BWM Rules has introduced the Extended Producer Responsibility for battery, under which producers bear the responsibility of recycling or refurbishing for batteries that they introduce in the market. (Read more)
In addition to registering on the portal, fulfilling the collection, recycling and refurbishment targets as set out in the BWM Rules, producer also need to ensure all battery or battery pack produced are appropriately marked with EPR registration number by March 31, 2025.
The Amendment has went on to specify the marking methods, which include:
Printing a barcode or QR code containing EPR registration number on the battery, or the equipment containing battery, or the packaging of the battery or the equipment containing the battery;
Printing the EPR registration number on the product information brochure.
Prohibition
Currently, India has implemented prohibitions on the presence of heavy metal in the battery through BWM Rules. The limit values for mercury and cadmium are as follows:
Battery that contains up to 0.0005% (5 ppm) of mercury by weight may only be placed till 2025;
Portable battery that contains more than 0.002% (20 ppm) of cadmium by weight cannot be placed on the market;
The prohibitions on mercury shall not apply to button zinc silver oxide battery with a mercury content < 2% and button zinc air battery with a mercury content < 2% by weight. The prohibitions on cadmium shall not apply to a portable battery used for emergency and alarm systems and medical equipment.
