Battery Swapping Policy (2022) – Laying Groundwork for Future Battery Accessibility

The Government of India allowed sales and registration of EVs without batteries in August 2020. The immediate outcome of this announcement is the reduction in upfront costs of an electric two-wheeler (E2W) and electric three-wheeler (E3W) as battery accounts for 30-40 percent of an electric vehicle’s cost. One of the other linked outcomes of this decision is the promotion battery swapping in India. Battery swapping is an alternative which involves exchanging discharged batteries for charged ones and provides user the flexibility to charge them separately. Three key advantages of battery swapping are- it is time- saving, space efficient, and cost-effective at the same time, given that each swappable battery is actively used.

In the same direction, the Government has also introduced a draft battery swapping policy in April 2022 to lay ground principles of operations in this sector. The final policy is expected to be introduced in a few weeks’ time. The Draft policy highlights the following:

General RequirementsFor efficient battery monitoring, data analysis, and safety, batteries are required to be Battery Management System (BMS) enabled, and the manufacturer shall ensure that appropriate BMS is in place to protect the battery from conditions such as thermal runaway.To ensure battery safety and security of assets, swappable batteries will be equipped with advanced features like IoT-based battery monitoring systems, remote monitoring and immobilization capabilities, and other required control features
Battery and Swapping Station Unique Identification Number (UIN)To implement unique traceability across the battery lifecycle, a Unique identification number (UIN) shall be assigned at the manufacturing stage for tracking and monitoring EV batteries. Required technical data of the battery will be mapped by the OEMs with UIN of battery pack at the manufacturing stage. The battery swapping operator must store the usage history and required performance data of battery with UIN during EV application.Similarly, a UIN number will be assigned to each Battery Swapping Station.
Testing & Certification for Battery Swapping ComponentsStandards approved or defined by BIS shall be implemented for the electric vehicle, battery safety requirements, Degrees of Protection of electrical equipment against foreign objects, technical specification of cables and connectors, and traction battery safety requirements. Batteries shall be tested and certified as per AIS 156 (2020) and AIS 038 Rev 2 (2020) standards for safety of traction battery packsFor EVs with swappable battery functionality, vehicle OEMs shall be required to get ARAI approval for their vehicles to accept interoperable swappable batteries.
Battery charging and swapping infrastructureEach battery swapping station (BSS) should serve at least 2 EV OEMs and setup battery swapping stations at locations like retail fuel stations, public parking areas, malls etc.Standards for battery charging station (BCS) and BSS will be developed or approved by BIS/ Ministry of Power (MoP) or other competent authorities.The Electric Vehicle Supply Equipment (EVSE) used at the swapping station must be tested and approved by the National Accreditation Board for Testing and Calibration Laboratories (NABL) or agency appointed by the central nodal agency for battery swapping.
Data SharingInformation to support ease of consumer access and use of battery swapping services, on availability, battery type, compatibility, and performance for batteries at all BSS, must be made openly available in a standard format by battery providers.
Tariff for supply of electricity to Public Battery Charging StationsThe provisions mentioned in Section 7 of the revised consolidated Guidelines and Standards for Charging Infrastructure for Electric Vehicles issued on 14th January 2022 will be applicable to Public and Captive BCSs provided they are energized by exclusive electricity connections (not used for other purposes).The Policy advocates bringing BCSs under existing or future Time-of-Day (ToD) tariff regimes as stipulated by the appropriate Commission so that the swappable batteries can be charged during the off-peak periods when the electricity tariffs are low.
Provision of land at promotional rates for Public Battery Swapping StationsThe provisions mentioned in Section 9 (to provide land parcels on a revenue sharing basis for the purpose of establishing public charging Infrastructure) of the revised consolidated Guidelines and Standards for Charging Infrastructure for Electric Vehicles issued on 14th January 2022 will be applicable to Public BCSs.
Proposal for Applicable rates of Goods and Services TaxThe Policy proposes reducing tax rate differential existing between batteries and EV supply equipment which is 18% and 5% respectively by the Goods and Services Tax (GST) council.
Rollout of battery swapping in PhasesThe target vehicle segments for battery swapping are E2Ws & E3Ws segments which are heavily concentrated in urban areas. The rollout of battery swapping stations (BSS) will therefore be phased in the following manner: Phase 1 (Years 1-2): All metropolitan cities with a population of greater than 4 million (as per census 2011) will be prioritized for development of battery swapping networks under the first phasePhase 2 (Years 2-3): All major cities such as state capitals, UT headquarters, and cities with population greater than 5 lakhs (as per census 2011) will be covered under second phase, given the importance of the 2W and 3W vehicle segments in growing cities  
Nodal agencies for rollout of battery swapping stationsThe Bureau of Energy Efficiency (BEE), the Central Nodal Agency responsible for the rollout of EV public charging infrastructure, will be responsible for the implementation of battery swapping networks across the country. States and union territories (UTs) are responsible for the implementation and governance of the battery swapping ecosystem. Appointed state nodal agencies (SNAs) for EV public charging infrastructure will facilitate the rollout of battery swapping. SNAs will be supported by the following state agencies: Transport department and State transport authorities are responsible for easing registration processes for vehicles sold without batteries or for vehicles with battery swapping functionality Municipal corporations are responsible for planning, zoning permissions, and land allocation for battery swapping stations Energy departments and DISCOMS are responsible for supply of power to battery swapping stations and for any policy support vis-à-vis power connections. State Electricity Regulatory Commissions (SERC) are responsible for concessional power tariffs, open access, and other regulatory incentives or support for battery swapping services  
Registration of vehicles with swappable batteriesAs per the Ministry of Road Transport and Highways (MoRTH) circular RT-11036/72/2017, vehicles without batteries can be registered based on the Type approval certificate issued by an accredited Testing Agency, without the need to specify the make/type or any other details of the battery.
Planning and provision of battery swapping networksBattery charging and swapping stations are required to be in accordance with the requirements specified for public charging infrastructure, in Section 3 of the January 2022 amendment of the revised “Charging infrastructure for electric vehicles – Guidelines and Standards” released by MoP. Any individual or entity is free to set up a battery swapping station at any location, provided that the specified technical, safety and performance standards are adhered to all. BSS should serve at least one vehicle segment (E2W, E3W, LCV, etc.), and each BSS should serve at least two EV OEMs.
Single window portalA single window portal should be setup to facilitate submission of all required documents by battery swapping providers, issue trade licenses for battery swapping business, approve allocation of public land for installation of battery swapping stations, and to grant electricity supply connections for battery charging centres/stations.

Various states have already shown green signal to the Draft Battery Swapping Policy and have started working towards the battery swapping initiative while other states are yet to announce plans for installation of Battery Swapping stations by including the provision in their state EV policies.

Table 1: Efforts by states to promote battery swapping:


Initiatives for Battery swapping


A pilot of 50 battery swapping stations is under process and will be allotted to station operators by the end of 2022. Currently there are 10 battery swapping stations operational in Telangana


100 battery swapping stations will be set up by Delhi Transco Limited (DTL). Currently 234 battery swapping stations are operational in New Delhi


Sun Mobility plans to deploy over 2,000 battery swapping points across 2025 in collaboration with Amazon India

Source: Industry Search, JMK Research

The battery swapping policy intervention in terms of smart BMS, IoT-based monitoring, Unique identification number (UIN), vehicle type-approval with an interoperable swappable battery are all initiatives in the right direction. The policy coupled with Government of India sponsored incentives and strong coordination between multiple players has the potential of helping India achieve its long-term climate goals. Further increased purchase incentives and awareness about the benefits of battery swapping are expected to attract more consumers leading to large scale switch to EVs.