Battery EPR compliance in India: obligations, targets, and filing

If you manufacture, import, or sell batteries under your own brand in India, you are a producer under the Battery Waste Management Rules 2022 and must register with the CPCB. Your collection target is a percentage of what you placed on the market in an earlier financial year — not this year — and your annual return is due 30 June.

Who has a battery EPR obligation?

The rules define one role that matters: producer. There is no separate definition of "importer" or "brand owner" — those words do not appear in the operative English text. If you import batteries, you are a producer.

Rule 3(1)(u), as substituted by S.O. 4669(E) of 25 October 2023, covers an entity that engages in:

• manufacture and sale of batteries, including in equipment, under its own brand;
• sale under its own brand of batteries produced by other manufacturers;
• import of batteries, or of equipment containing batteries;
• manufacture or assembly of batteries for sale to a brand-owning producer, without its own brand name.

The fourth limb was added in 2023. If you assemble battery packs for someone else's brand, you were arguably outside the rules before that amendment and you are inside them now.

Batteries are covered whether sold loose or inside equipment. A "portable battery" is defined as sealed, under 5 kg, and not industrial, automotive, or for an electric vehicle.

What do you register, and how long does it take?

Registration is on the CPCB's centralised portal at eprbattery.cpcb.gov.in. You apply in Form 1(A); CPCB issues the certificate in Form 1(B).

Rule 11(3) requires registration within two weeks of a completed application, and the 2023 amendment added deemed approval: if CPCB has not refused you within those two weeks, registration is deemed done.

One widely repeated detail is out of date. The original rules gave registration a five-year validity with renewal 60 days before expiry. S.O. 4669(E) replaced that: registration is now valid until cancelled or withdrawn by CPCB, and the renewal sub-rule was omitted. If a consultant is quoting a five-year renewal cycle for battery registration, they are working from the superseded text.

How is the target actually calculated?

This is where most liability estimates go wrong.

Targets are set by battery type — portable, automotive, industrial, and electric vehicle — not by chemistry. Chemistry enters only as an allocation instruction: Schedule II requires the target to be "specific to the kind of Battery (viz. Lead acid, Li-Ion, Nickel Cadmium, Zinc based Battery, etc.) within each type".

More importantly, the percentage applies to a lagged base year. A 70% target on portable batteries means 70% of the quantity you placed on the market in the fifth preceding financial year — not 70% of what you sold this year. For automotive, industrial, and EV batteries the base is the third preceding year.

If your volumes have grown, this works in your favour. If they have shrunk, you owe against a bigger past year. Either way, an estimate built on current-year volume is measuring the wrong thing.

What are the collection targets?

From Schedule II. Each target carries a further obligation to recycle or refurbish 100% of the quantity actually collected.

Portable rechargeable targets phased in at 50% for 2022-23 and 60% for 2023-24 before reaching 70%. Automotive ran 30%, 50%, 70% across 2022-23 to 2024-25.

Shortfalls are not simply lost. G.S.R. 190(E) of 14 March 2024 rewrote the carry-forward: up to 60% of the remaining quantity placed on the market during the applicable compliance cycle may be carried forward. This replaced the earlier wording, which was based on average annual quantity and gave automotive only 20%.

A separate obligation is often mistaken for the EPR target: Rule 4(14) sets minimum domestically-recycled content. For automotive and industrial batteries that is 35% from 2024-25, rising to 40% from 2026-27. For portable and EV it starts at 5% in 2027-28 and reaches 20% by 2030-31.

How do EPR certificates work?

You do not buy certificates from a recycler's own stock. CPCB generates them through the portal, based on quantities a registered recycler or refurbisher has actually processed, and assigns them to that recycler — who may then sell them to you.

Terms that decide whether a certificate is any use to you:

• Validity: seven years from generation (Rule 10(14)).
• Category-locked. Surplus in one category is only usable for the same category, and a refurbishing surplus cannot be applied to a recycling obligation (Rule 10(9)).
• Single-use. Once used against an obligation, a certificate cannot be exchanged again (Rule 10(12)(ii)).
• Purchase capped at current-year liability, plus leftover prior liability, plus 10% of current-year liability (Rule 10(11)).
• Imported waste is discounted. The generating formula applies a factor of 0.8 to waste batteries sourced through imports, against 1.0 for domestically generated waste (Rule 10(8)).

Price is not open-ended: G.S.R. 190(E) confines the exchange price to a band between 30% and 100% of the environmental compensation that would otherwise be leviable.

The practical exposure is that a certificate is only as good as the registration behind it. Certificates are assigned to registered recyclers through the portal; if that registration lapses or is revoked, what you hold may not do the job you bought it for.

What are the filing deadlines?

There is no half-yearly return for battery producers. If you have seen an October date attached to battery EPR, it is not from these rules — the quarterly cycle in the table above belongs to recyclers, not producers.

What does non-compliance cost?

The rules themselves set no rate. Rule 13 delegates it, and the figures live in a separate CPCB document: Guidelines for imposition of Environment compensation (EC) under Battery Waste Management Rules, 2022, notice dated 10 September 2024, with MoEF&CC concurrence dated 9 September 2024.

Lead-acid, as of that notice: ₹3,000 per tonne handling, collection and transport, plus ₹15,000 per tonne processing — ₹18,000 per tonne, or ₹18 per kg of lead.

Lithium-ion and other chemistries are assessed per kg of recovered metal, so a per-tonne figure does not apply: lithium ₹2,400/kg, cobalt, nickel and manganese ₹555/kg, copper ₹270/kg, aluminium and iron ₹120/kg.

For non-target defaults — a missed return, a labelling failure, dealing with an unregistered entity — the guidelines set ₹20,000 for a first default, ₹40,000 for a second and ₹80,000 for a third, increasing 10% each year.

Two things that catch people out. Paying environmental compensation does not discharge the obligation (Rule 13(6)) — the shortfall still carries forward for three years. And the money is partly recoverable if you fix the shortfall: 75% returned within one year, 60% within two, 40% within three, nothing after that.

Do you also have an e-waste obligation?

Many producers do. A battery inside equipment is covered here; the equipment itself may be covered by the E-Waste (Management) Rules 2022, which are a separate registration, a separate target basis, and a separate return. See the e-waste EPR guide.

Sources

Primary sources only. Rates and targets are as of the dates shown; the rules have been amended five times since 2022.

• Battery Waste Management Rules, 2022 — S.O. 3984(E), 22 August 2022 (CPCB)
• Battery Waste Management (Amendment) Rules, 2023 — S.O. 4669(E), 25 October 2023 (CPCB)
• Battery Waste Management (Amendment) Rules, 2024 — G.S.R. 190(E), 14 March 2024 (CPCB)
• Battery Waste Management (Amendment) Rules, 2025 — S.O. 958(E), 24 February 2025 (CPCB)
• Guidelines for imposition of Environment compensation under BWMR 2022 — CPCB notice, 10 September 2024
• CPCB battery EPR portal