Mapping the Regulatory Landscape of Used Lead-Acid Battery Management in ASEAN

This analysis was researched and written by Anaeli Victorica, a volunteer policy researcher with LABRI.

This blog post was drafted on the basis of broader research that Anaeli conducted for LABRI to examine hazardous waste regulations across the ASEAN region. We conducted this research to inform LABRI’s future decisions about where we might work and to support our work in the Philippines, where we are supporting policymakers to design solutions to address informal ULAB recycling.

Introduction: Why ULAB Policy Matters

Lead-acid batteries power the vast majority of cars, motorcycles, and solar home systems across Southeast Asia. These batteries are highly recyclable, with virtually every component recoverable if handled correctly. However, most countries in the region lack the formal infrastructure to process used lead-acid batteries (ULABs) safely at scale, and the facilities that do exist often operate without appropriate safeguards. As a result, ULAB recycling is a major source of lead exposure in Southeast Asia and globally. More than one million children in the Philippines and over eight million in Indonesia are estimated to have blood lead levels high enough to cause developmental harm, and the regional productivity losses attributable to lead exposure have been estimated to be at least $115 billion annually (Ericson and Brown; Daniels et al.). Improving the overall safety of ULAB handling is a tractable and necessary step to address this problem.

Workable alternatives to unsafe ULAB recycling already exist. Brazil cut informal, unsafe recycling by more than half in five years by pairing a sales tax exemption on ULABs with an Extended Producer Responsibility (EPR) scheme (World Economic Forum). Approaches like this might similarly respond to the challenges facing Southeast Asia which are less a matter of regulatory absence than of economic incentives and infrastructure. Informal collectors in the Philippines, for instance, pay up to 50% more than licensed operators for used batteries, because they absorb none of the costs associated with safe handling. This makes it structurally difficult for formal recyclers to compete for supply against informal recyclers that bear lower compliance costs (Daniels et al.). Since the obstacles are economic and infrastructural rather than regulatory gaps alone, effective interventions depend on first understanding what each country already regulates. This post therefore maps the existing regulations governing the lead-acid battery and ULAB markets across ASEAN, providing a reference point for designing interventions suited to each national context.

Approach

This analysis is intended as a reference point for understanding the current regulatory landscape across the Association of Southeast Asian Nations (ASEAN) member states. ASEAN member states share a regional governance architecture that includes frameworks for hazardous waste cooperation. Moreover, the movement of used batteries across borders means that a weak regulatory link in one country affects the entire regional chain. 

To map the flow of batteries in the ASEAN region, I examined the regulatory frameworks governing used lead-acid battery lifecycle management across each of the eleven ASEAN member states. I then analyzed how each country controls transboundary movements, what environmental standards apply to recycling and storage, and how far each has progressed in adopting circular economy mechanisms such as Extended Producer Responsibility.

The regulatory mapping covers ULAB regulatory frameworks across all ASEAN member states: Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, the Philippines, Singapore, Thailand, Timor-Leste, and Vietnam, organized around three dimensions. The first is transboundary movement controls, including how countries regulate the import and export of ULABs and how they implement their Basel Convention obligations. The second is standards for treatment, storage, and recycling, covering environmental standards for air emissions and wastewater, facility licensing, and handling protocols. The third is circular economy models, focusing on whether countries have established mandatory obligations for the collection and recycling of used lead-acid batteries, including EPR schemes that require manufacturers or importers to manage their products at end of life. 

The analysis that follows is organized in three parts. Key Similarities Across the Region identifies the regulatory patterns that hold across most ASEAN member states, while Major Points of Variation examines where frameworks diverge and why. The Country Comparison Table provides a simplified overview of each country's position across all three dimensions for readers seeking a quick reference.

Key Similarities Across the Region

Despite the wide variation in institutional capacity and economic development, several regulatory patterns hold across the region.

Transboundary controls are the most consistent area of regulation. Nearly all countries have ratified the Basel Convention, the international treaty that governs the transboundary movement of hazardous wastes, and implemented some form of Prior Informed Consent (PIC) procedure, which requires exporting countries to obtain approval from the receiving country before shipping hazardous waste across borders. Most prohibit or heavily restrict ULAB imports (Basel Convention). The pattern is likely explained by the fact that the Basel Convention provides a ready-made framework that countries can transpose into domestic law with relatively little customization. Timor-Leste is the notable exception, as it is not a Basel Convention signatory and relies instead on a bilateral arrangement with Australia for hazardous waste export (Timor-Leste Regulations 2003).

Environmental standards for lead exist in most countries, though they vary considerably in specificity. Countries consistently stipulate permitted maximum levels of lead in air and water, but these vary widely, ranging from 0.5 to 30 mg/Nm³ (milligrams of particulate per normal cubic metre, a standard unit for measuring air emissions at reference temperature and pressure) for air and 0.1 to 0.5 mg/L for wastewater discharge (see the country comparison table for specific legal references). Several countries, particularly those with limited domestic recycling capacity such as Timor-Leste and Brunei, reference international benchmarks from the World Health Organization or the World Bank/International Finance Corporation where national standards for lead emissions have not yet been established, a practice that provides a regulatory floor even in the absence of dedicated legislation.

ULAB management involves multi-agency coordination in every country examined. This usually involves environment ministries that set policy, customs agencies that manage transboundary flows, industry ministries that handle manufacturing and licensing, and health ministries that sometimes oversee occupational exposure limits. This fragmentation creates coordination challenges but also reflects the cross-cutting nature of ULAB recycling markets, and it suggests that effective measures would require inter-ministerial mechanisms rather than action by any single body.

Major Points of Variation

The most significant variation across the region appears in three areas, each of which has implications for policy interventions.

The specificity of ULAB regulations varies significantly. At one end of the spectrum, we have examples like Malaysia and Singapore. Malaysia designates ULABs as "Scheduled Waste 102" with dedicated handling, storage, transport, and treatment rules enforced through an electronic tracking system, while Singapore classifies them as controlled toxic industrial waste under a strict licensing regime that includes GPS-tracked transport and digital manifests for every shipment (Malaysia's Environmental Quality (Scheduled Wastes) Regulations 2005; Singapore's Toxic Industrial Waste Regulations). At the other end, Brunei and Timor-Leste regulate ULABs only under broad hazardous waste or anti-pollution provisions, with no ULAB-specific requirements. Most countries fall somewhere in between, regulating ULABs as a subcategory of general hazardous waste without dedicated battery codes, which means that the distinctive hazards of lead-acid chemistry are not always specifically addressed (Brunei's Environmental Protection and Management Act; Timor-Leste Decree-Law No. 5/2011; Daniell et al.).

EPR adoption is uneven and still emerging. Vietnam stands out as having enacted mandatory EPR for batteries, including lead-acid accumulators, with a compulsory recycling rate of 12% taking effect in January 2024 (Vietnam's Decree No. 05/2025/ND-CP; Giang). Cambodia issued its first mandatory EPR regulation in March 2025, explicitly covering lead-acid batteries (Cambodia's Prakas No. 2196/0325). The Philippines has an EPR Act from 2022, though it currently targets plastic packaging and has not been extended to batteries. LABRI is currently working with government stakeholders in the Philippines to support the development of market-based policies, including an EPR scheme for ULABs. Several countries, including Thailand and Myanmar, have EPR schemes in policy documents or draft legislation but nothing yet in force, while Brunei, Laos, and Timor-Leste appear to have no EPR framework at all for batteries (Tungsuwan et al.).

Country Comparison Table

The table below provides a simplified overview of where each country stands across the three dimensions examined in this analysis.

Country	Transboundary Controls	Recycling/Treatment Standards	EPR Status
Brunei	Basel Convention was implemented via the 2013 Hazardous Waste Order	General pollution control guidelines; no ULAB-specific standards; batteries exported for processing	No mandatory EPR; concept introduced in the Recycle 123 Handbook published by the Department of Environment, Parks and Recreation (DEPR) in 2015.
Cambodia	Import prohibited (2023 Environment and Natural Resources Code); export with Basel PIC	Ambient air and wastewater limits exist; ULAB-specific recycling standards are not currently in place.	Prakas No. 2196/0325 on EPR for E-Waste: March 18, 2025. Cambodia's first mandatory EPR obligation. In the annex/table of covered products, it explicitly includes HS 8507.10 (lead-acid accumulators).
Indonesia	Import of hazardous waste is prohibited under UU 32/2009 Art. 69 with limited recycling exceptions. Export requires Basel Convention Prior Informed Consent.	PP No. 101/2014 classifies used lead-acid batteries (ULABs) as Category 1 hazardous waste under code A102d – Aki/baterai bekas and defines additional Category 2 waste codes (B326-1/2/3) for battery manufacturing residues. No specific ULAB recycling emission standards.	No mandatory EPR for lead-acid batteries; circular economy roadmap does not specifically address ULABs.
Laos	Import of old batteries is banned, reinforced by the Decision on Pollution Control (No. 1687/MONRE, April 7, 2021), where Article 8 explicitly lists “old batteries.”	Laos has established benchmarks for environmental quality that apply to lead-related industrial activities. Effluent lead limit of 0.2 mg/L; no ULAB-specific facility standards.	No EPR framework for batteries.
Malaysia	Import banned; Basel Convention via Customs Order 2013.  Import ban: Malaysia bars the import of hazardous waste, including ULABs (policy since the 1990s, reaffirmed in the Customs (Prohibition of Import) Order). Export: not explicitly banned by law but rarely approved – generally discouraged as local capacity exists.	For a ULAB recycler to operate legally in Malaysia, it must meet rigorous technical standards designed to mitigate the inherent risks of lead smelting and acid neutralization. These standards are primarily contained within the Clean Air Regulations 2014 and the Industrial Effluent Regulations 2009, both of which require the application of Best Available Techniques (BAT). Regulations for Pollution Control in Malaysia. Stack emissions lead limit of 5 mg/m3; effluent 0.1 mg/L (sensitive areas); BAT required	No mandatory EPR for batteries yet. Strong focus on Electric Vehicle (EV) battery EPR: Policy announced to require EV manufacturers to reclaim end-of-life batteries, essentially introducing EPR for EV (mostly Li-ion) batteries
Myanmar	Import/transit banned; export permitted via Basel PIC. Limited environmentally sound management capacity cited as basis for import prohibition. (2025 Environmental Conservation Department directive).	Myanmar currently has no specific ULAB lifecycle regulations. The ULAB landscape in Myanmar is dominated by a market-driven informal sector that thrives on the high scrap value of lead. Effluent lead limit of 0.1 mg/L; no ULAB-specific recycling standards.	EPR status for ULABs: Not mandatory yet (policy intent, not an enacted take-back obligation).The Myanmar National Waste Management Strategy and Master Plan (2018-2030) is the first national initiative aimed at institutionalizing waste management and transitioning toward a resource-efficient society.
Philippines	Bureau of Customs (BOC): In a 2021 memo, it states: “The Philippines does not have a viable commercial source of primary lead to supply its demand. Hence, the export of ULABs is not allowed; they must go to licensed domestic TSD (Treatment, Storage, and Disposal) facilities.”	Only authorized TSD facilities are permitted to process ULABs. Department Administrative Order (DAO) 2013-22. The technical standards for water quality are found in DAO 2016-08, which establishes the Water Quality Guidelines (WQG) and General Effluent Standards (GES). Lead (Pb) effluent standard (DAO 2016-08): Effluent lead 0.02 to 0.2 mg/L by water class; ambient air lead 1.0 ug/NCM annual average	ULABs are not yet subject to the mandatory recovery targets of the EPR Act. LABRI is working in the Philippines to support the extension of EPR to lead-acid batteries.
Singapore	Hazardous Waste (Control of Export, Import, Transit) Act. This act provides the statutory power to fulfill Singapore’s obligations under the Basel Convention. Import restricted to recycling only under Basel permit; export via PIC	ULABs from any source (vehicle workshops, uninterruptible power supply systems, etc.) must be consigned to National Environment Agency-licensed Toxic Industrial Waste Collectors (TIW collectors). Air emissions lead limit of 0.5 mg/Nm3; effluent 0.1 mg/L; occupational blood lead monitoring required.	EPR for portable batteries under the Resource Sustainability Act 2019; automotive ULABs managed under the Toxic Industrial Waste regime. A critical legal nuance in the TIW regulations is the “Consignor’s Responsibility”. In many jurisdictions, the liability for waste shifts once it is handed over to a collector. In Singapore, the generator (the consignor) remains legally responsible for providing accurate information to the collector to enable safe handling. Environmental Protection and Management (Trade Effluent) Regulations.
Thailand	The Customs Department implements Basel Convention rules and import/ export controls. Thailand bans the import of used lead-acid batteries (a national hazardous-waste import prohibition). Exports of ULABs (e.g., for foreign recycling) require Basel permits.	Lead batteries are classified as Hazardous Waste Code 16 06 01. Specific Ministry of Industry notifications target lead-smelting factories (dating from 2001), covering location, safety, emissions, and waste management.Stack lead emissions 24 to 30 mg/m3; effluent 0.2 mg/L; specific siting and safety rules for lead smelters	No mandatory EPR for ULABs is currently in force. Thailand has not enacted EPR legislation for batteries. All relevant EPR frameworks remain in draft form.
Timor-Leste	Not a Basel Convention signatory; bilateral arrangement with Australia for hazardous waste export	Timor-Leste does not currently operate a centralized, government-run collection system for ULABs. The segregation of household hazardous wastes is uncommon, with most materials being treated as general domestic waste. Timor-Leste’s technical standards for lead (Pb) and other hazardous pollutants are often a synthesis of national decree-laws and international guidelines (WHO, World Bank/IFC).	As of 2025, mandatory EPR for lead-acid batteries is not in force.
Vietnam	Import of hazardous waste effectively banned; export via Basel PIC	All hazardous waste generators (incl. ULABs) must register; large generators have to report waste annually. Robust standards: Industrial Emission Standards (QCVN 19:2024/BTNMT) Circular No. 45/2024/TT-BTNMT, effective July 1, 2025, promulgated QCVN 19:2024, which replaces multiple outdated standards from 2009 to 2017.  Facilities already in operation have been granted a transition period until December 31, 2031, to meet these new standards; wastewater lead 0.5 mg/L	Mandatory EPR: Batteries (including automotive LABs). Vietnam’s shift toward a circular economy is operationalized through a mandatory recycling quota system, which is intended to divert the financial burden of waste management from the public sector to the private sector. For lead-acid batteries (LABs), the initial compulsory recycling rate was set at 12% of the total weight put on the market for the first three-year phase.

Looking ahead

This mapping reveals a region in transition. The foundations of ULAB regulation exist across Southeast Asia, as most countries have ratified the Basel Convention, classified lead-acid batteries as hazardous waste, and established at least basic environmental quality standards. Nevertheless, the depth and specificity of these frameworks vary widely, and the distance between a regulation on the books and a change in practice on the ground remains a central challenge of ULAB governance in the region.

Although the diversity of regulatory approaches across ASEAN is a challenge to harmonization, it has also been a source of practical knowledge. Vietnam's early experience with mandatory EPR for batteries, Cambodia's recent inclusion of lead-acid batteries in its e-waste EPR regulation, and Malaysia's robust scheduled waste tracking system all offer concrete, regionally-grounded lessons that neighbors can study and adapt. Vietnam's Resolution No. 247/2025 provides a further example of implementation-focused action: the National Assembly has mandated that all polluting industrial clusters within residential areas be relocated to properly zoned industrial sites by 2030, which could reduce one of the most persistent causes of residential lead exposure (Vietnam's Resolution No. 247/2025).

Limitations and information gaps

Significant data gaps persist, and they constrain the ability to measure progress. Blood-lead level studies are scarce or nonexistent in several countries, ULAB generation estimates vary widely, and recycling rates are difficult to verify, which makes it hard to target interventions effectively or to make the case for investment (Myanmar and Laos, for example, have no national blood lead level surveys; The Lancet Planetary Health's 2021 systematic review lists Myanmar among countries with no available data, and the World Bank identifies lead exposure as a significant but largely ignored risk in Laos). International financing is beginning to address some of these gaps: a USD 37.85 million World Bank pollution and waste management project in Laos running from 2025 to 2031 is expected to strengthen monitoring infrastructure and improve environmental data, even though its primary focus is plastic waste (World Bank). For the findings presented here, these gaps mean that the comparison across countries necessarily reflects the strength of regulatory frameworks on paper rather than verified outcomes on the ground, and that countries with less available documentation may appear less developed in their approach than they are in practice. A more complete picture will depend on the kind of monitoring infrastructure that is only now beginning to receive investment.

As regulatory landscapes evolve rapidly across the region, continued monitoring and comparative research will be essential to support the design of effective, context-appropriate policies that protect public health and the environment. LABRI works with governments to design market-based policies for safer battery recycling. For more information, contact us at contact@labrecyclinginitiative.com.