Bangladesh MoEF promulgates Order on battery recycling

The Ministry of Environment, Forest and Climate Change (MoEF) of Bangladesh promulgated an Order (S.R.O No. 45-Act/2021) on battery recycling under the Bangladesh Environment Conservation Act, 1995, on February 25, 2021. This Order will come into effect upon its promulgation (Envix has reviewed this Order and the superordinate law, the Bangladesh Environment Conservation Act, 1995, but has not been able to find a clear definition of a battery).

The main provisions of this Order are as follows.

• • Individuals or companies dismantling and incinerating batteries for recycling shall obtain Environmental Clearance Certificate from the Department of Environment (DoE) prior to the event.
  • Companies engaged in dismantling and incinerating of batteries for recycling shall ensure that workers use protective equipment.
  • Companies involved in the manufacture and recycling of lead-acid batteries shall appoint dealers and agents to collect used batteries.
  • Companies shall obtain a Non-objection Certificate (NOC) from the DoE to obtain a license to import lead-acid batteries, and the importer shall sign a contract with a battery recycling company.
  • The body of lead-acid batteries shall be marked with the country code, company code, serial number of the battery, and warning statement about lead.
  • Battery recycling facilities that have received Environmental Clearance Certificate shall report the amount of lead recycled to the DoE on a semi-annual basis.
  • Battery manufacturers shall only purchase lead that has been recycled by facilities that have obtained Environmental Clearance Certificate.
  • Disposing of used batteries in an unapproved manner shall be prohibited.
  • To protect the environment, all retailers, dealers, or distributors shall collect used batteries instead of every new battery sold and transport them to a recycling facility within three months. This information shall be recorded as an electronic data and submitted to the DoE.

According to a local media report dated March 5, 2021, there are more than 1000 companies engaged in battery recycling in Bangladesh, but most of these companies are recycling batteries in an unapproved manner and only five companies are officially approved to engage in recycling.

This Order can be downloaded from the following URL (in Bengali).
https://doe.portal.gov.bd/sites/default/files/files/doe.portal.gov.bd/page/5a9d6a31_d858_4001_b844_817a27d079f5/2021-03-11-13-01-38e62a2a902a7530bc9ceb795fd153ed.pdf

EnviX Comment

Envix has reviewed this Order and the superordinate law, the Bangladesh Environment Conservation Act, 1995, but has not been able to find a clear definition of a battery. The term “lead-acid battery” is used in some of the provisions, and we can assume that this Order focuses on lead-acid batteries, but since the Order does not allow a definitive determination, this is noted as a comment from EnviX.