Table of Contents

• What Is EPR for Battery Waste?
• Legal Framework: Battery Waste Management Rules, 2022
• Who Must Register for Battery EPR?
• Which Batteries Are Covered?
• EPR Battery Waste 2025 Compliance Checklist
• Step-by-Step EPR Registration Process (CPCB)
• EPR Targets for Battery Producers
• Consequences of Non-Compliance
• EPR Certificates: How They Work
• Frequently Asked Questions
• Conclusion

Introduction

India generates hundreds of thousands of tonnes of battery waste every year — from discarded mobile phone batteries and power banks to industrial lead-acid batteries and EV battery packs. The environmental consequences of improper disposal — heavy metal contamination, soil and water pollution, hazardous chemical exposure — are severe and well-documented.

In response, the Government of India enacted the Battery Waste Management Rules, 2022, making EPR (Extended Producer Responsibility) registration with CPCB (Central Pollution Control Board) mandatory for all battery producers, importers, and sellers operating in India.

If you manufacture, import, or sell any type of battery in India, you are a Producer under these rules — and you must be EPR-registered. This guide gives you a complete 2025 compliance checklist.

What Is EPR for Battery Waste?

Extended Producer Responsibility (EPR) is a policy principle that makes producers financially and operationally responsible for the end-of-life management of their products. For battery waste, this means:

• Producers must collect a mandated percentage of batteries placed on the Indian market
• Collection must be channelled to registered recyclers and refurbishers
• Annual EPR targets (expressed as a percentage of battery weight/units placed on market) must be met
• EPR certificates from recyclers serve as proof of compliance

EPR does not mean you run your own collection network. It means you must demonstrate — through EPR certificates — that batteries equivalent to your mandatory collection target have been collected and processed by a registered recycler.

Legal Framework: Battery Waste Management Rules, 2022

The Battery Waste Management Rules, 2022 were notified by the Ministry of Environment, Forest and Climate Change (MoEFCC) on August 22, 2022. They replaced the earlier Batteries (Management and Handling) Rules, 2001.

Key legal provisions:

• Mandatory EPR registration with CPCB for all producers, importers, and sellers
• Annual EPR targets for collection of spent batteries (percentage increases over time)
• EPR certificate system — recyclers issue certificates for batteries processed, which producers must acquire to demonstrate compliance
• Annual returns filing — all registered entities must file annual compliance reports with CPCB
• Penalties for non-registration and non-compliance

Who Must Register for Battery EPR?

Under the Battery Waste Management Rules, the following entities are defined as Producers and must register:

• Manufacturers of any battery in India (even if sold only domestically)
• Importers of batteries (cells, packs, modules) into India
• Importers of products containing batteries — crucially, this includes companies importing laptops, smartphones, electric vehicles, power tools, UPS systems, and any device with an integrated battery
• Sellers (e-commerce marketplaces or brand owners) if they sell batteries or battery-containing products under their own brand
• Bulk consumers (in some cases) — entities procuring batteries at scale for their own use

Key point for electronics importers: If you import laptops, smartphones, tablets, power banks, or any device with a built-in battery, you are considered a Producer under the Battery Waste Management Rules and must register for EPR.

Which Batteries Are Covered?

The Battery Waste Management Rules cover all battery chemistries and applications:

Battery Type	Examples
Portable batteries	AA, AAA, coin cells, camera batteries
Automotive batteries	Lead-acid starter batteries for vehicles
Industrial batteries	UPS batteries, telecom batteries, solar storage
Electric vehicle batteries	EV traction packs, e-bike batteries
Lithium-ion batteries	Mobile phone, laptop, power bank batteries
Sealed lead-acid batteries	VRLA batteries for inverters, UPS
Nickel-metal hydride batteries	Power tools, hybrid vehicle batteries

EPR Battery Waste 2025 Compliance Checklist

Use this checklist to assess and manage your EPR battery compliance:

Registration

• Identify all battery types placed on the Indian market in the previous financial year
• Calculate total weight (kg) or units of batteries placed on market
• Register on the CPCB EPR portal
• Obtain EPR Producer Registration Number from CPCB
• Tie up with CPCB-registered battery recyclers / refurbishers

Annual Targets

• Calculate your mandatory EPR target for the current financial year (% of weight/units placed on market in previous year)
• Confirm with your recycler partners their EPR certificate issuance process
• Monitor collection progress against targets through the CPCB portal

Documentation

• Maintain records of all batteries imported/manufactured (invoices, import bills)
• Obtain EPR certificates from registered recyclers for batteries collected
• Maintain a battery waste log for the financial year

Annual Returns

• File annual returns on the CPCB EPR portal before the due date
• Report quantities placed on market, quantities collected, and EPR certificates obtained
• Submit details of recycler/refurbisher partnerships

Labelling

• Ensure all batteries and battery-containing products carry the mandatory EPR/take-back symbol
• Include “Do not dispose in landfill” and take-back programme information on packaging

Step-by-Step EPR Registration Process (CPCB)

Step 1: Determine Producer Category

Under the Battery Waste Management Rules, producers are classified by the type of batteries they place on market (portable, automotive, industrial, EV). Your registration and targets differ by category.

Step 2: Gather Company and Product Information

Prepare: company registration details, GST number, IEC code, details of all battery products placed on the Indian market (types, chemistries, annual quantities, and weight in kg).

Step 3: Register on the CPCB EPR Portal

Access the CPCB battery EPR portal. Complete the online registration form, uploading all required documents.

Step 4: CPCB Scrutiny and Registration Approval

CPCB reviews the application. They may raise queries for clarification. Upon approval, a Producer Registration Number is issued.

Step 5: Identify and Tie Up with Registered Recyclers

CPCB maintains a list of registered battery recyclers and refurbishers. Producers must partner with one or more registered recyclers to ensure batteries placed on market are collected and processed at year-end.

Step 6: Annual Returns and EPR Certificate Reconciliation

At the end of each financial year, file annual returns declaring batteries placed on market and EPR certificates obtained from recyclers. The CPCB portal reconciles declared targets against certificates.

EPR Targets for Battery Producers

The Battery Waste Management Rules set progressive annual EPR targets — the percentage of batteries placed on market in the previous year that must be collected in the current year:

Year	Portable Batteries	Automotive Batteries	Industrial Batteries	EV Batteries
2023–24	50%	80%	50%	70%
2024–25	60%	80%	60%	80%
2025–26	70%	80%	70%	90%
2026–27 onwards	80%	90%	80%	90%

Targets are based on weight (kg) or units, depending on battery category. Always verify with the current CPCB notification as targets may be revised.

Consequences of Non-Compliance

CPCB has been actively enforcing battery EPR compliance. Consequences include:

• Cancellation of registration — loss of legal authorization to place batteries on market
• Financial penalties as per the Environment Protection Act
• Environmental Compensation — monetary charges for shortfall in EPR targets
• Customs complications — importers without valid EPR registration may face import clearance issues
• Prohibition orders — CPCB can prohibit a non-compliant entity from placing batteries on market

EPR Certificates: How They Work

EPR certificates are the currency of battery waste compliance in India.

How they work

• A registered recycler or refurbisher collects used batteries
• After processing, the recycler generates EPR certificates through the CPCB portal
• The recycler transfers certificates to the producer who has partnered with them
• The producer submits these certificates as proof of EPR target compliance in annual returns

Certificate value: Each certificate typically represents a specific weight (kg) or quantity of batteries collected and processed. Certificates are non-transferable after assignment.

Frequently Asked Questions

I import smartphones with built-in lithium batteries. Do I need EPR registration?

Yes. If you import any device containing a battery into India for commercial sale, you are a Producer under the Battery Waste Management Rules and must register for EPR. The battery inside the smartphone is subject to EPR obligations.

Can I use the same EPR recycler for multiple battery types?

Yes, if the recycler is registered with CPCB for the relevant battery types. Some recyclers handle multiple chemistries; others specialize. Verify the recycler’s CPCB registration for your specific battery category.

What is the penalty for missing annual EPR targets?

CPCB may impose Environmental Compensation for shortfall in EPR targets. This is typically calculated as a monetary charge per kg or unit shortfall. Repeated non-compliance can lead to registration cancellation.

Is EPR for battery waste the same as EPR for e-waste?

No. Battery waste EPR and E-waste EPR are separate frameworks with separate registrations, portals, targets, and recycler networks. If you import electronics (e-waste category) containing batteries, you may need to register under both EPR frameworks.

Do small importers also need EPR registration?

The Battery Waste Management Rules do not currently provide a blanket exemption for small producers based on turnover or quantity. Any entity placing batteries on the Indian market is required to register. Consult a compliance specialist if your import quantities are very small.

Conclusion

EPR registration for battery waste under India’s Battery Waste Management Rules, 2022 is a mandatory, non-negotiable compliance requirement for all battery producers, importers, and product companies whose products contain batteries. With progressive targets increasing every year and CPCB actively enforcing compliance, the time to register — if you haven’t already — is now.

The practical compliance framework is manageable: register with CPCB, partner with certified recyclers, obtain EPR certificates, and file annual returns. The harder part is staying current as targets increase and reporting requirements evolve.

Need Help With Battery Waste EPR Registration?

PCN Global India Corporation provides complete EPR registration and compliance management for battery waste under India’s Battery Waste Management Rules, including CPCB portal management, recycler partnerships, and returns filing.

We also handle: EPR for E-Waste | EPR for Plastic Waste | EPR for Tyre Waste | BIS CRS for Batteries | WPC ETA | LMPC | DGFT Licensing

Get in touch: Website: https://pcnindiaglobal.com | Email: bdm@pcnindiaglobal.com | Phone: +91 80109 05029