Critical mineral security requires both supply-side capacity and feedstock assurance. Examine India's recent policy measures on battery recycling in this light.

Lithium, cobalt, nickel and manganese are used in EV batteries, energy storage and electronics. India imports much of what it needs [1]. Securing these minerals takes two things together: plants that can extract them and a steady supply of waste for those plants (feedstock). India's recent battery-recycling measures now use both levers, but they do not yet move at the same pace.

Building supply-side capacity

• Incentive Scheme for Critical Mineral Recycling (₹1,500 crore, Sept 2025), under the National Critical Mineral Mission (NCMM): a 20% subsidy on plant and machinery, plus a running-cost subsidy linked to extra sales [2].
• Targets: about 270 kt of yearly recycling capacity, about 40 kt of critical minerals and nearly 70,000 jobs by FY 2030-31 [2].
• Pushes value addition: it pays only for actual mineral extraction, not for units that only shred batteries into black mass. One-third of the money is kept for small and new recyclers [2].

Assuring feedstock

• Battery Waste Management Rules, 2022: Extended Producer Responsibility (EPR) sets collection and recycling targets for producers. Recyclers must register with State Pollution Control Boards [3].
• DGFT Notification No. 49/2026-27: exports of Li-ion Battery Black Mass moved from "Free" to "Prohibited" under tariff line ITC(HS) 85491400 [1].
• Why: domestic plants were running below capacity for lack of feedstock. Black mass was being exported while some recyclers had to import material [1].
• Effect: the subsidy builds capacity and the ban keeps the raw material in India. This is trade policy used as industrial policy (Aatmanirbhar Bharat).

Gaps

• Timing mismatch: the ban starts immediately, but new capacity comes only by 2031. PIB itself said India's black mass processing capacity was limited [4]. Black mass could pile up or sell at very low prices meanwhile.
• Small scale: subsidy caps of ₹50 crore per large firm and ₹25 crore per small firm slow the building of large refineries [2].
• Collection risk: shredders lose both the export market and the subsidy. If prices fall, more spent batteries may go to informal dismantlers.
• No review date: the ban lasts "until further orders" [1]. That makes it open-ended and could invite WTO scrutiny of export restrictions.

Way forward

• Publish capacity added each year and review the ban against it. Move to "Restricted" (export by licence) for surplus amounts if capacity falls short.
• Strict CPCB/SPCB checks on the plants handling this hazardous material.

Together, the subsidy and the export ban form the core of a domestic urban-mining system. If India adds capacity on time and keeps collection and processing environmentally safe, the policy can deliver both mineral security and SDG 12 (responsible consumption and production).