EV Battery Swapping Policy Draft 2022 Released- Highlights

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https://e-vehicleinfo.com/ev-battery-swapping-policy-draft-2022-released/During Budget 2022-2023, the Indian government announced plans to introduce a Battery Swapping Policy and interoperability standards, with the intent of building and improving the efficiency of the battery swapping ecosystem, thereby driving EV adoption.

This Policy is targeted at supporting the adoption of battery-swapping primarily for battery swapping systems destined to be used for light electric power train vehicles (LEV) of category L, and E-Rickshaw/E Cart. However, this does not preclude the Government from extending its coverage to other EV segments in the future.

This Policy will be valid from the date of its public notification till 31st March 2025 and will be reviewed and extended thereafter, as may be decided by the Ministry of Power.


Battery swapping is an alternative that involves exchanging discharged batteries for charged ones and provides flexibility to charge them separately. This de-links charging and battery usage and keeps the vehicle in operational mode with negligible downtime.

Battery swapping is generally used for smaller vehicles such as 2Ws and 3Ws with smaller batteries that are easier to swap, compared to 4 wheelers and e-buses, although solutions are emerging for the latter segments as well. Battery swapping offers three key advantages relative to charging: it is time, space, and cost-efficient, provided each swappable battery is actively used.

With existing technologies for e-2Ws and e-3Ws, regular charging takes at least 3 to 4 hours, adding to inconvenience and creating range anxiety. The resulting vehicle downtime is particularly significant for freight and shared mobility vehicles. Whereas, battery swapping is done in minutes, as the batteries are pre-charged in swapping stations.

  • Charging stations require more space since vehicles need to be parked next to the chargers during the charging process. Battery swapping stations can stack multiple batteries on top of each other, and require limited parking, which would address space constraints in urban areas.
  • While battery swapping involves a greater number of batteries than conventional batteries, each swappable battery can be smaller in capacity (kWh), since range anxiety is a smaller concern.

Battery swapping falls under the broader umbrella of Battery as a Service (BaaS) business models which involve users purchasing an EV without the battery, which significantly lowers upfront costs, and paying a regular subscription fee (daily, weekly, monthly, etc.) to service providers for battery services throughout the vehicle lifetime. BaaS is applicable for both fixed and removable batteries and is the channel to implement swapping solutions.

Battery swapping is still nascent in India but gaining ground, especially for commercial and fleet operations. There are currently a limited number of battery swapping service providers that have been engaging with original equipment manufacturers (OEMs), individual/commercial users, and other relevant stakeholders, to develop ecosystems of swapping services with compatible components (batteries, vehicles, chargers, etc.) within each ecosystem.

The definitions here shall be considered only in the context of this Policy

  • Battery as a Service (BaaS) decouples the EV and its battery by enabling the use of the battery as a service, without ownership of the battery. BaaS can be applicable for fixed and swappable batteries.
  • Battery-swapping shall mean a method to cater to the charging requirements of battery-powered EVs that entail replacing discharged batteries or partially charged batteries of EVs with charged batteries which can be conveniently carried out manually and/or with mechanical intervention.
  • A battery swapping ecosystem shall mean a compatible set of battery swapping components, viz. EVs, swappable batteries, and charging facilities that satisfy the technical and operational requirements
    stipulated in Section 5 of this Policy.
  • A fixed battery shall mean a battery that remains associated with a particular EV as long as it is used for mobility purposes.
  • A swappable battery shall mean an ACC battery used in a battery-powered EV that can be conveniently detached and interchanged with another battery and subsequently, electrically recharged outside the EV to replace a discharged battery of a battery-powered EV.
  • Battery Charging Station (BCS) shall mean a station where the discharged or partially discharged electric batteries for EVs are electrically recharged. In case the swappable batteries are electrically recharged at a facility not set up for battery charging, like a Kirana store, commercial or private property, or any other such place, the host facility will not be regarded as a BCS.
  • Battery Swapping Station (BSS) shall mean a station where an EV can get its discharged battery or partially charged battery replaced by a charged battery.
  • A BCS and a BSS can be co-located or integrated at the same site or located separately at different locations.
  • Public BSS shall mean a BSS where any EV, privately or commercially owned, can get its discharged or partially charged battery replaced by a charged swappable battery.
  • Public BCS shall mean a BCS where only the swappable batteries that are dispensed at one or more Public BSS(s) are electrically recharged.
  • Captive BSS shall mean a BSS exclusively for the EVs owned or under the control of the owner of the BSS and is not accessible to other EVs with swappable and compatible batteries.
  • Captive BCS shall mean a BCS exclusively for the swappable batteries of the EVs owned or under the control of the owner of the BCS and is not made available for charging other swappable and compatible batteries.

Battery Provider refers to any entity which owns EV batteries and provides them based on BaaS models to electric vehicle owners.

General Requirements

The Policy will only support batteries using “Advanced Chemistry Cells” (ACC), with performance that is equivalent to or superior to EV batteries supported under the FAME-II scheme. Additional specifications or standards for batteries eligible under this Policy shall be applied from time to time, based on relevant policies and schemes in practice.

  • Battery providers must demonstrate end-to-end compatibility between batteries and other components of the swapping ecosystem, all of which must be certified under appropriate processes defined or referred to under Section 5.2. of this Policy.
  • For efficient battery monitoring, data analysis, and safety, batteries covered under this policy are required to be BMS-enabled. 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 &immobilization capabilities, and other required control features.
  • Additional standards and specifications for batteries regarding battery pack dimensions, charging connectors, etc. will be notified over time with adequate notice, and consultation with, the industry stakeholders, to support a phased transition to interoperability between ecosystems.

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. Various tracking and tracking solutions are used in different industry sectors, and an appropriate system may be applied for EV batteries that are tamper-proof and allow centralized monitoring. The standard or generic methodology and the detailed definition of the UIN system for EVbatteries will be developed by the relevant authorities.
  • Required technical data of the battery will be mapped by the OEMs with Uthe IN of the 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, and data must be maintained to facilitate the traceability of EV batteries during the entire lifecycle.
  • Similarly, a UIN number will be assigned to each Battery Swapping Station

Testing & Certification for Battery Swapping Components

Standards approved or defined by BIS shall be implemented for the electric vehicle, battery safety requirements, Degrees of Protection (IP-code) 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 the safety of traction battery packs, as well as additional tests that may be prescribed for swappable batteries which are subject to multiple coupling/ decoupling processes at the connectors.
  • To ensure a high level of protection at the electrical interface, a robust/rigorous testing protocolshall be adopted to avoid any dielectric breakdown, arc phenomenon, or any unwanted temperature rise at the electrical interface. BMS of the battery must be self-certified and open for testing to check its combability with various systems, and capability to meet safetyrequirements.
  • Compatible electric vehicles shall be tested as per relevant regulatory standards. For EVs with swappable battery functionality, vehicle OEMs shall be required to get ARAI approval for theirvehicles to accept interoperable swappable batteries.

Battery charging and swapping infrastructure

To ensure safe and cost-effective infrastructure for charging and swapping of EV batteries, standards for 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 andapproved by the National Accreditation Board for Testing and Calibration Laboratories (NABL) or agencyappointed by the central nodal agency for battery swapping.

For safety during the operation of the charging infrastructure, the operator must follow the guidelines andprotocols of DISCOMS/CEA (Central Electricity Authority).

Battery Swapping Business Model

It is noted that there are different business models under the umbrella of BaaS which are currently being employed by Battery Providers. The models mainly differ in the extent to which different roles in the battery swapping ecosystem are integrated or kept separate.

On one end, Battery Providers work with battery OEMs to develop smart, swappable batteries, provide them to the end user, and also operatecharging facilities or BCS/BSS. Each of these roles can also be separated, whereby the batteries manufactured by an OEM are purchased by a Battery Provider, which then partners with relevant entities(such as retail/Kirana stores) that deliver customer-facing facilities such as BCSs/BSSs.

As battery swapping is still nascent in India, it is recognized that further business models will emerge asthe market matures. The Policy is therefore business model agnostic and seeks to even the playing field for different models.

Hence this Policy recommends the following measures to support the development of such business models:

  • Encourage collaboration among stakeholders to form battery swapping ecosystems that are sustainable, scalable, and leverage the strengths of each party.
  • The Battery Provider is expected to play a key role in managing these partnerships to ensure key requirements related to safety, and performance is met. The Battery Provider would also be thepotential point of contact representing the ecosystem for any coordination with externalstakeholders including EV users, and government agencies.
  • Provide flexibility to end-users (personal and business) to have different arrangements with battery Providers with the option of switching operators in the future. For added flexibility, thisPolicy does not prevent Battery Providers from allowing EV users to detach swappable batteriesfrom EVs to charge elsewhere (at home for instance), with appropriate measures to ensure safety and performance.
  • Support enabling technologies, which promote standardization, interoperability, safety, and improve communication among stakeholders (including EV users where applicable). This wouldinclude providing access to real-time data on battery statistics like charge levels and range,discovery of nearest swapping stations as well as seamless options to book and pay for the services through multiple modes.

With the strengthening of the ecosystem supported by the de-risking measures, it is also expected that other third-party entities will identify new market opportunities in offering value-added services such as insurance, financing etc.

These entities are expected to partner with battery providers, OEMs, and end customers to provide product warranty, minimal maintenance costs assured buyback policy as well as affordable financing options. This would assure EV users that subscribe to BaaS models leading to largescale adoption.

Central and state nodal agencies will be appointed to facilitate coordination among stakeholders,grievance redressal, dispute resolutions, and to ensure compliance with the policy, regulations,standards, and guidelines.


To support the adoption of BaaS models and EVs with swappable batteries, this Policy seeks to level the playing field across business models involving the sale of EVs with fixed or swappable batteries.

It is proposed that demand-side incentives offered under existing or new schemes for EV purchase can be made available to EVs with swappable batteries eligible under this policy. The size of the incentivecould be determined based on the kWh rating of the battery and compatible EV.

An appropriate multipliermay be applied to the subsidy allocated to Battery Providers to account for the float battery requirements for battery swapping stations in different battery swapping ecosystems. It is also proposed that a seamless mechanism for the disbursement of subsidies shall be worked out by the concerned ministryor department.

To formalize and operationalize the possible subsidy scheme, an appropriate ongoing scheme may be revised, or a new scheme may be launched. The scheme may detail the procedures for application toavail the subsidy and subsequent disbursement, including the following:

  • Battery Providers shall receive the subsidy, provided the battery swapping ecosystem that theyrepresent satisfies the technical and operational requirements under Section 5 of this Policy.
  • The scheme will clarify the modality of the subsidies in a way that balances benefits to recipients with ease of implementation. Subsidies may be linked to the UIN of EVs and batteries to ensure that there is no double-dipping.
  • The scheme may specify a minimum contract duration for the contracts to be signed between the EV users and Battery Providers (or relevant ecosystem entity) to ensure that BatteryProviders continue to provide battery swapping services after qualifying for any subsidies.
  • The scheme may also set eligibility criteria based on performance for EVs and swappablebatteries (aligned with requirements under FAME II) to ensure only high-quality EVs andswappable batteries get the incentives.


To address the concerns related to battery life and resale value, BIS or other relevant organizations shall develop regulations for the minimum battery performance and durability requirements.

For safety, reusability, and sustainability of the business models in the second-life application of the used batteries, BIS shall develop standards for the re-use and re-purposing of the End-of-First-Life batteries from EV applications.

To promote the re-use of swap batteries after their End-of-Life (EOL) in automotive/EV applications, energy operators or battery swapping operators will be encouraged to develop a ‘power bank’ using EOLswap batteries to store and use renewable energy for EV charging or other applications.

To ensure proper EOL recycling of EV batteries, a definition of battery ownership and liability shall be developed by BIS or MOEFC. Improper disposal of EV batteries in landfills or scrap will not be allowed. Battery Management Rules shall be released separately to cover the end-of-life handling of the batteries in detail and fix the Extended Producer Responsibility (EPR). Details of tracking of collection and reprocessing of used EV batteries are already available in Draft Battery Waste Management Rules(2020).


The rollout of battery swapping networks will require state and local government coordination and support. States and/or local authorities should ensure that battery swapping is offered a level playing field with plug-in charging for public (and captive) BCS and BSS, as required.

Rollout of battery swapping

The target vehicle segments for battery swapping are e-2Ws and e-3Ws, which are heavily concentrated in urban areas. The rollout of battery swapping stations will therefore be phased in the following manner:

  • Phase 1 (Years 1-2): All metropolitan cities with a population greater than 4 million (as per census 2011) will be prioritized for the development of battery swapping networks under the firstphase
  • Phase 2 (Years 2-3): All major cities such as state capitals, UT headquarters, and cities with populations greater than 5 lakhs (as per Census 2011) will be covered under the second phase,given the importance of the 2W and 3W vehicle segments in growing cities.

Any central and state government agencies involved in implementation of battery swapping networks may consider this prioritization when providing additional policy support and/or subsidy allocations forbattery swapping networks.

Planning and provision of battery swapping networks

Battery charging and swapping stations are required to be by 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.
  • Certified battery agnostic swapping stations must be used for setting up swapping services and may accommodate one or more types of certified battery packs.
  • All BSS should serve at least one vehicle segment (e-2W, e-3W, LCV, etc.), and each BSS should serve at least two EV OEMs.
  • The location of BCS and BSS should be planned for optimum accessibility and utilization, provided that the planning is in line with all defined standards of safety and security.

Find here the complete pdf- link 

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