Policy Paper
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Where Batteries Go to Die
The paper “Where Batteries Go to Die: A qualitative study of policy and governance gaps in Pune” examines the state of battery circularity in India through the lens of portable batteries embedded in consumer electronics, a key source of critical mineral-rich “black mass” for recycling. Within this category, the study focuses on smartphone batteries, given the rapid growth of India’s smartphone user base. The research is situated in Pune, Maharashtra’s second-largest e-waste-generating city, and examines the policy and governance gaps between the Battery Waste Management Rules, 2022 and the E-Waste (Management) Rules, 2022, alongside the possible role of local self-government in building a reverse logistics supply chain. Given the significant presence of the informal sector in this supply chain, which creates persistent data gaps in battery circularity, the study adopts a qualitative approach, drawing on eight semi-structured interviews with policy experts, formal recyclers, public officials, and waste-picker representatives, supplemented by field observations at Pune’s SWaCH V-Collect Centre and a local e-waste recycling facility. Four key findings emerge. First, there is widespread public confusion between e-waste and hazardous battery waste, rooted in regulatory ambiguity. Second, dismantling, the manual, labour-intensive extraction of batteries from devices, is an essential but currently unrecognised and unregulated stage of the recycling value chain. Third, despite their constitutional mandate for solid waste management, Urban and Rural Local Self-Governments have no comparable operational mandate for e-waste and battery collection, leaving the sector reliant on producer-led Extended Producer Responsibility mechanisms alone. Fourth, data privacy concerns, rather than lack of awareness, are a major behavioural barrier to smartphone recycling, as consumers fear irreversible loss of personal data. Based on these findings, the study recommends: integrating the two regulatory frameworks to formally recognise e-waste as a source of end-of-life batteries; formally regulating battery extraction as a distinct, labour-protected activity; mandating local governments to establish permanent e-waste collection infrastructure, potentially in partnership with educational institutions; and introducing mandatory, indigenously developed data-wiping certification to address consumer privacy concerns and reduce device hoarding. Most importantly, the study argues that battery circularity policy in India must shift its underlying orientation from end-of-life waste management toward design-for-reuse and lifecycle optimisation.
Keywords: Portable Batteries, End-of-Life (EOL), Battery Circularity, Recycling, Circular Economy, Smartphones, E-waste, Hazardous Waste, Pune.