Registrations, permits and insurance
Start with the basics. Confirm that the recycler holds current registrations and permits for the activities and quantities involved, such as registration on India's CPCB portal or the relevant environmental permits in other jurisdictions. Check that the permitted capacity matches the volumes they claim to process.
Insurance is equally important. Ask for evidence of cover for fire, environmental damage, product liability and transport, and check the limits against the value and risk of the material you will send. Gaps here can leave you exposed if something goes wrong.
- 1. Which registrations and permits do you hold, and for what capacity?
- 2. When were they last renewed or inspected?
- 3. What insurance cover do you hold, and at what limits?
- 4. Have you had any enforcement actions in the past five years?
- 5. Which certifications, such as ISO 14001, ISO 45001 or R2v3, do you hold?
Operations and safety
Visit the site. Look at how batteries are received, stored and quarantined, whether storage matches the recycler's own limits, and how damaged units are handled. Ask about fire detection and suppression, emergency plans and incident history.
Review training records and procedures for high-voltage work, dangerous goods handling and emergency response. A recycler that can show clear procedures and trained staff is more likely to handle your batteries safely.
- 6. How are incoming batteries inspected and recorded?
- 7. Where and how are damaged units quarantined?
- 8. What fire detection and suppression is installed?
- 9. What incidents have occurred and what changed afterwards?
- 10. How are staff trained for high-voltage and dangerous goods work?
Mass balance and recovery
Ask to see the mass balance: how much material entered the site, how much left as products, residues and waste, and how much is in stock. The figures should reconcile. Recovery rates should be stated per metal against contained metal in the input, not as a single aggregate figure.
Check how your specific consignments are tracked. Serial-level or lot-level records linking your material to the certificates you receive give you confidence that the paperwork reflects reality.
- 11. Can you show a site mass balance for the last year?
- 12. What recovery rates do you achieve for each metal?
- 13. How are our consignments tracked through the process?
- 14. How are certificates linked to physical material?
- 15. What happens to residues and non-recoverable waste?
Downstream vendors and data
Many recyclers send intermediate products, such as black mass, to other companies for refining. Ask for a list of downstream vendors, their locations and their permits, and whether the recycler audits them. Material leaving the country may be subject to transboundary shipment rules.
Finally, review data handling. Batteries may carry vehicle and user data in their management systems, and certificates contain commercial information. Ask how data is protected and how long records are retained.
- 16. Who are your downstream vendors, and where are they?
- 17. How do you audit downstream vendors?
- 18. Do any shipments cross borders, and under which permits?
- 19. How do you handle data stored in battery management systems?
- 20. How long do you retain records, and can we access them?
Field note