Import Compliance - Lithium Ion Battery

• Batteries are classified in two categories, Primary & Secondary

• Primary Batteries are all non-rechargeable batteries in the form of AAA /

AA / Coin cells etc. with import volume of $ 95 Million per annum

• Secondary Batteries are all rechargeable batteries like Lithium Ion, Lead
Acid, Nickle Cadmium batteries etc. with imports of $ 3.725 Billion per
annum as per DGFT data.

• Import Data for Secondary Battery is as below (Major HSN is 85076000)

• More than 50% imports are done by top 10 importers majorly into business
of automotives and power storage systems.

• 95% imports are done from China followed by South Korea, Vietnam and
Japan
 Import Compliance - Lithium Ion Battery

License (Periodic) Requirements for Lithium-Ion Battery Imports

1. Pollution NOC (CTE/CTO) from State pollution Control Board (Pre-condition

& takes 2-3 months)
2. Extended producer’s responsibility (EPR) registration from CPCB & MoEFCC
(Pre-condition & takes 1-2 months)
3. BIS certification for quality of goods. (At the time of Customs clearance. Not
required if supplier is BIS certified)

Process of EPR registration

• EPR registration is required for hazardous waste (battery) | Plastic packaging

waste | E waste (Electrical & electronics) | rubber Tyers |Used / waste Oil
• Documents required for the licenses are,
o Company documents like IEC | GST | PAN | CIN
o Type of battery to be imported with composition of the battery (%age
of Lithium, Nickle, Copper etc.)
o Warehouse to keep such goods (batteries) with adequate and
appropriate storage
o Submission of requisite fee as notified

Annual Compliance for EPR registration (Recycling Targets)

• The new rules as per EPR demands that the producers of the battery make
provisions for the collection, disposal, and recycling of the battery.
• This rule also entitles the producer to delegate its responsibility to a third
party with respect to the collection and disposal of waste.
• Collection/Recycling targets assigned by the CPCB can be completed through
such third party collectors / recyclers
o Annual return to be filed by 30th June (sales to be reported)
o The composition of batteries should be considered while importing
o Cost (per Kg as mentioned below) for purchase of recycling targets has
to be taken into consideration while importing batteries.
o Example : - If we import 50 MT of battery with 10% lithium
composition and 50% is our recycling target then our additional cost
shall be (50 MT X 50% X 10% X cost per MT for recycling credits) = (50
X 50% X 10% X 19 lakhs) = 47.50 lakhs. Cost for other metal in
proportion to their composition shall be additional.
o Cost per KG – ₹ 1906 for Li | ₹ 310 for Ni | ₹ 207 for Cu | ₹ 104 for Al
etc.