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MCBI Publishes a Draft Battery EPR Law for Mongolia

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Mongolia Circular Battery Initiative | Policy | September 2026

The Mongolia Circular Battery Initiative (MCBI) has published a proposed Draft Law on Batteries and Waste Batteries, setting out an Extended Producer Responsibility (EPR) framework for Mongolia. The document is openly available on Zenodo: doi.org/10.5281/zenodo.22930741.

Why now. Mongolia’s 2017 Law on Waste has no battery-specific producer responsibility. In May 2026, a parliamentary working group reviewing the Law on Waste called for full implementation of EPR. Meanwhile, lead-acid batteries remain the main waste stream today, and electric vehicle battery waste is expected to grow sharply after 2033.

What the draft proposes. The draft contains 25 articles in seven chapters:

  • Registration of all battery producers and importers
  • Producer responsibility organisations (PROs) to organise collection nationwide
  • Eco-modulated fees that reward recycled content and easy removal
  • A deposit-refund scheme for lead-acid batteries
  • State-of-health diagnostics before EV batteries are recycled
  • A national battery registry linked to customs data
  • Phased implementation, with full EV battery coverage from 2030

The framework follows the structure of EU Regulation 2023/1542, simplified and phased for Mongolian conditions. The targets in the annex are preliminary and need validation through cost and impact assessment.

Next steps. MCBI welcomes feedback from government, industry, civil society and researchers. The draft is a policy proposal by a non-governmental initiative, not an official government draft. It is published under CC BY 4.0 and may be freely used and adapted with attribution.

Contact: mcbis.org

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