India’s November 10th 2026 export ban on lithium-ion battery black mass aims to retain valuable secondary critical minerals and strengthen domestic recycling.
Black mass contains recoverable lithium, cobalt, nickel and other materials that could supplement India’s primary mineral supplies.
The restriction seeks to address a mismatch in which domestic recyclers have faced feedstock shortages even as locally generated black mass was exported.
Retaining black mass is only the first step. Converting it into battery-grade materials requires investment in advanced processing, refining and purification.
Effective battery collection, traceability and Extended Producer Responsibility (EPR) mechanisms will be essential to ensure a reliable supply of recyclable material.
The commercial viability of recycling will depend on battery chemistry, recovery costs, metal prices and demand for recovered materials.
When an electric vehicle battery reaches the end of its life, the minerals inside it do not necessarily have to leave the economy with it. Lithium, cobalt, nickel and other valuable materials can be recovered and potentially used to manufacture new batteries. But until now, some of the black mass produced from discarded lithium-ion batteries in India has been finding its way to overseas markets, taking with it an opportunity to build domestic mineral recovery capabilities.
The Union government has now moved to address this. On November 10, 2026, it prohibited the export of lithium-ion battery black mass, a move that could help retain an important source of secondary critical minerals within the country. The decision is significant not simply because it restricts the export of waste, but because it raises a larger industrial policy question: can India turn the minerals recovered from discarded batteries into inputs for its own battery manufacturing industry?
The Directorate General of Foreign Trade (DGFT) changed the export policy for the specified category of battery waste and scrap under ITC (HS) code 85491400 from “Free” to “Prohibited”, with immediate effect and until further orders. The provision covers specified unsorted battery waste and scrap that does not contain lead, cadmium or mercury. Transitional arrangements under the Foreign Trade Policy, 2023, will apply. The government’s announcement explicitly identifies lithium-ion battery black mass as the material covered by the notification.
The significance of the decision lies in what black mass represents. Produced by shredding end-of-life lithium-ion batteries and battery manufacturing scrap, it is a powder containing a mixture of recoverable metals, graphite and other residues. Depending on the chemistry of the original battery, it can contain lithium, cobalt, nickel and manganese. It is not, however, a finished material that can be used directly in new cells. It is an intermediate product that must undergo further processing to separate and recover its constituent materials.
For India, this distinction has strategic importance. The country remains substantially dependent on imports for several minerals and processed materials required for lithium-ion battery production. As domestic electric vehicle manufacturing and advanced chemistry cell production expand, access to these materials will increasingly influence the competitiveness and resilience of the manufacturing ecosystem.
Battery recycling offers an additional source of these materials, reducing dependence on newly mined resources or overseas supply chains. In effect, discarded batteries can become an urban mineral resource. The metals recovered from them could supplement supplies of primary minerals and reduce India’s exposure to disruptions in international markets.
The opportunity, however, varies with battery chemistry. Nickel-manganese-cobalt (NMC) batteries contain valuable nickel and cobalt alongside lithium, making their recovery attractive under suitable market and processing conditions. Lithium-iron-phosphate (LFP) batteries have a different material profile: they contain no nickel or cobalt, and are harder to recycle economically because lithium is the principal high-value metal in their cathodes. Consequently, the composition of black mass, the concentration of recoverable materials and the efficiency of the recycling process therefore determine its commercial value. Treating all black mass as an equivalent source of critical minerals would be misleading.
Until now, exporting black mass has meant that the opportunity to recover its constituent minerals could shift to processing facilities outside India. Countries importing the material could extract the metals, refine them and potentially integrate them into their own battery material supply chains. India, meanwhile, risked losing the downstream processing value.
The government has acknowledged this contradiction in its announcement, noting that domestic recycling and refining capacity has expanded but remains underutilised because of inadequate feedstock. It has also pointed to instances in which domestic recyclers have had to import black mass to meet their requirements even as material generated in India was being exported.
The export restriction addresses this mismatch by making domestically generated black mass available to Indian recycling and refining units. It also complements the ₹1,500-crore Incentive Scheme for Critical Mineral Recycling, approved by the Union Cabinet in September 2025 under the National Critical Mineral Mission. The scheme aims to build domestic capacity to separate and produce critical minerals from secondary sources, including battery waste and electronic waste. The Ministry of Mines has set out a six-year implementation period, running from 2025-26 to 2030-31.
This policy direction is consistent with concerns raised by the Centre for Science and Environment (CSE) about India’s battery-recycling framework. In its January 2026 report, “EV Battery Recycling and Extended Producer Responsibility (EPR): Reform the terms of action”, CSE identified black-mass exports as a drain on valuable domestic feedstock and an obstacle to building a circular battery economy. It also highlighted the problem of undervalued EPR certificates, arguing that inadequate financial incentives discourage investment in environmentally sound recycling and high-recovery technologies. CSE’s report called attention to the links between retaining recyclable material, improving the economics of domestic recycling and strengthening regulatory oversight.
The export prohibition addresses an important part of this problem. But keeping black mass within the country will not, by itself, ensure that India captures the full economic value of its minerals. That depend on its ability to process the material further.
Black mass must undergo treatment, typically through hydrometallurgical processes involving chemical leaching, separation and purification, to recover individual metals. Depending on the process and feedstock, this can yield lithium compounds and nickel, cobalt and manganese salts. These products must then be refined to meet the purity and performance specifications required for battery applications. Further processing into precursor and cathode-active materials is necessary before they can enter the cell manufacturing chain.
The distinction between recovering a metal and producing a battery-grade material is critical. Cell manufacturers require consistent chemical composition, controlled impurities and stringent quality specifications. A recycler may achieve high metal recovery rates without producing materials that meet these requirements. Unless domestic processors can bridge this gap, India risks retaining the raw recycling intermediate while continuing to depend on imported refined materials and battery components.
The first constraint is likely to arise much earlier in the recycling chain: the collection of end-of-life batteries. Batteries are dispersed across electric vehicles, portable electronics and industrial applications. Their collection, safe transportation, testing and aggregation require organised systems. Fragmented supply chains and informal handling can result in material losses, safety risks and poor traceability.
The Battery Waste Management Rules, 2022, provide a framework through Extended Producer Responsibility (EPR), placing collection, recycling and refurbishment obligations on battery producers. They also prescribe minimum recovery targets for recyclers. For electric vehicle batteries, the minimum material recovery target reaches 90 per cent from 2026-27 onwards. The rules further require producers to use domestically recycled materials in new batteries from 2027-28, beginning at 5 per cent and rising to 20 per cent by 2030-31. The rules and subsequent amendments provide the regulatory framework for this transition.
These provisions can create demand for recovered materials, but only if compliance translates into actual recovery. EPR certificates must reflect genuine recycling and verifiable recovery, rather than simply the quantities of waste reported as processed. Traceability, from the battery collection through shredding and refining to final material recovery, will therefore be essential.
There is also an economic challenge. Advanced recycling requires investment in safe dismantling, pre-processing, chemical recovery, effluent treatment and quality control. Recovery yields, processing costs, scale and the market prices of recovered metals all influence commercial viability. LFP recycling, in particular, may require stronger producer responsibility mechanisms or other financial support to make recovery economically sustainable.
The export restriction could improve access to feedstock for domestic recyclers, but it does not guarantee sufficient volumes, predictable quality or viable processing margins. Nor does it create assured demand for the recovered materials. Domestic cathode and precursor manufacturing must develop alongside recycling if recovered minerals are to find a reliable market within India.
The next phase of policy action must therefore focus on building an integrated system: collection and aggregation networks, reliable battery chemistry and composition data, standards for black mass and recovered materials, transparent EPR accounting, and commercial arrangements linking recyclers with refiners and cell manufacturers. Customs and environmental authorities will also need to coordinate effectively to ensure that the restriction is applied in accordance with the material’s actual composition and classification.
India’s opportunity extends beyond waste management. A functioning battery recycling industry could build capabilities in secondary mineral recovery, advanced chemical processing and battery materials manufacturing. CSE’s earlier work on battery material security, along with its research into developing batteries suited to Indian operating conditions, also underscore the importance of building domestic technological capabilities across the battery value chain. Its 2023 assessment of EV battery material recycling made the case for treating recycling as part of India’s material security strategy.
The export ban is therefore an important intervention, but its success will not be measured simply by how much black mass stays within India’s borders. It will depend on how much of that material is actually collected, processed and converted into battery-grade inputs.