Get EPR Battery Waste Certificate Now | 2025 Updated Guide

EPR Battery Waste Overview in 2025

The global transition toward cleaner energy and the proliferation of electronic devices have made batteries an essential part of our daily lives. Whether in electric vehicles (EVs), mobile phones, laptops, solar energy systems, or industrial machinery, the use of batteries has grown exponentially in India. However, with this surge comes the environmental challenge of managing spent or waste batteries.

In response, India has implemented the Battery Waste Management Rules, 2022, under the umbrella of Extended Producer Responsibility (EPR). These rules place the responsibility of post-consumer battery management on producers, including manufacturers, importers, assemblers, and brand owners. The primary aim is to ensure that batteries are collected, recycled, or refurbished in an environmentally sound manner.

For businesses engaged in the import and export of battery-operated products, understanding and adhering to EPR Battery Waste compliance is critical. This article provides an in-depth, comprehensive guide to EPR for battery waste in India, its implications, compliance framework, challenges, and how a professional compliance services company can help.

What is EPR and Why it Matters

Extended Producer Responsibility (EPR) is a policy mechanism that holds producers accountable for the lifecycle of their products, particularly at the post-consumer stage. It ensures that companies which introduce batteries into the market are also responsible for their collection, recycling, and disposal. The rationale behind EPR Battery Waste lies in shifting the burden of waste management from government entities to private producers, thereby promoting a circular economy.

India’s adoption of EPR Battery Waste is aligned with its broader environmental goals, including commitments under the Paris Agreement and the Sustainable Development Goals (SDGs). By enforcing EPR, India aims to reduce hazardous waste, prevent environmental pollution, and recover valuable resources from used batteries.

Overview of the Battery Waste Management Rules, 2022

The Battery Waste Management Rules, 2022 were issued by the Ministry of Environment, Forest and Climate Change and replaced the earlier 2001 regulations. The updated framework includes:

• Applicability to All Battery Types: The rules cover portable, automotive, industrial, and EV batteries.
• Online Portal for EPR Battery Waste Registration: Producers must register through the CPCB portal.
• Quantitative Collection Targets: Producers are assigned specific percentage targets for collection and recycling of used batteries based on their market introductions.
• Recycled Content Mandate: New batteries must include a minimum proportion of recycled materials.
• Prohibition of Informal Sector Involvement: Only CPCB-authorised recyclers and refurbishers can participate in the processing of battery waste.
• Legal Penalties and Environmental Compensation: Non-compliance may lead to fines and public disclosure.

Who Needs to Comply?

EPR Battery Waste compliance applies to a wide range of stakeholders. Understanding your role under the rules is essential:

Producers:

This includes manufacturers, assemblers, importers, and brand owners placing batteries or battery-containing products in the Indian market. They must register with the CPCB, declare battery quantities, and meet collection and recycling targets.

Recyclers:

Recyclers must obtain authorisation from SPCBs/CPCB and follow environmentally sound recycling practices. They must issue recycling certificates that producers can submit as proof of compliance.

Refurbishers:

Entities that extend the life of used batteries through refurbishment must also register and follow operational protocols defined by the CPCB.

Consumers and Bulk Consumers:

Entities that use large volumes of batteries must ensure proper disposal through collection points and avoid mixing battery waste with general solid waste.

Retailers and Dealers:

These are the customer-facing intermediaries who must facilitate take-back mechanisms and educate consumers on responsible battery disposal.

Key Obligations for Producers & Importers

1. EPR Battery Waste Registration on CPCB Portal

All producers, including importers, must register with the Central Pollution Control Board (CPCB) via the Battery Waste Management EPR Portal. Without registration, sale or import is illegal.

2. EPR Battery Waste Target Fulfillment

Importers are assigned collection and recycling/refurbishing targets based on the quantity and type of batteries placed on the market.

3. Authorized Recyclers and Collection Mechanism

Producers must ensure that collected batteries are processed only through authorized recyclers and refurbishers.

4. Annual Reporting

Detailed reports need to be filed yearly to demonstrate compliance with collection and recycling targets.

5. Use of Recycled Materials

New batteries must contain a minimum percentage of recycled materials recovered from waste batteries.

Types of Batteries Under EPR

1. Portable Batteries:

Typically used in handheld devices such as remote controls, cameras, and mobile phones. These are often the most widely disposed of and represent a challenge due to their small size and mixed chemical compositions.

2. Automotive Batteries:

Used in conventional fuel vehicles, primarily lead-acid batteries. These batteries are bulky and contain highly toxic lead, necessitating proper collection and recycling.

3. Industrial Batteries:

Large capacity batteries used in backup systems, energy storage, and solar grids. These are often reusable and need specialised recycling.

4. Electric Vehicle (EV) Batteries:

Comprising lithium-ion chemistry, these batteries are complex and expensive. Their EPR Battery Waste management requires dedicated logistics and safety protocols.

Detailed EPR Battery Waste Compliance Process

Step 1: Registration with CPCB

Before placing batteries in the market, producers must register on the CPCB portal, providing PAN, GST, IEC, authorised signatories, and category details of batteries.

Step 2: Declaration and EPR Battery Waste Plan

Producers must declare the total quantity (by weight) of batteries introduced in the market each year. Based on these quantities, CPCB calculates the target collection obligation for the current and following years.

Step 3: Establishing Collection Mechanisms

To fulfill EPR Battery Waste obligations, producers must:

• Set up drop-off points, take-back schemes, or collection centers
• Collaborate with authorised recyclers or refurbishers
• Offer incentives for returns (especially for portable batteries)

Step 4: Recycling and Refurbishment

Collected batteries must be sent to certified entities. Recyclers/refurbishers issue digital certificates confirming the quantity and type of waste processed, which producers upload on the portal.

Step 5: Annual Returns and Verification

At the end of every compliance year, producers must file an annual report that includes:

• Total batteries placed on the market
• Collection and recycling quantities
• Certificates from recyclers
• Progress toward meeting recycled content mandates

EPR Battery Waste Collection and Recycling Targets

The government has notified progressive collection targets for producers. These targets are based on the number of years since the battery was placed on the market:

The obligation includes recycled content benchmarks — for example, by Year 5, a lithium-ion battery must include at least 25% of lithium sourced from recycled materials.

Labeling, Marking, and Consumer Education

Under the rules, every battery and battery product must be labeled with:

• Recycling symbol
• Registration ID of the producer
• Chemistry of the battery (Li-ion, Lead-acid, etc.)
• Instructions for proper disposal

Additionally, producers are required to run awareness programs to educate users about hazards of improper disposal and the benefits of recycling.

Penalties and Enforcement

Non-compliance attracts environmental compensation, calculated per kg of shortfall in meeting targets. For instance:

• ₹100 per kg for failure to collect lithium-ion waste
• ₹50 per kg for failure to meet lead-acid recycling targets

CPCB may also suspend the registration of habitual violators and publish their names on public portals. Legal action can be initiated under the Environment (Protection) Act, 1986.

Import-Export Considerations

For Importers:

• Batteries imported as standalone units or within equipment (e.g., phones, laptops) must be reported under EPR Battery Waste.
• Importers must align HS Codes with battery categories and declare quantities correctly.
• Imports are disallowed without CPCB registration.

For Exporters:

• While EPR Battery Waste may not directly apply, exporters must prove that battery waste will be managed in the receiving country according to environmental standards.

Trade Documentation:

• Companies should align declarations on DGFT and Customs portals to avoid compliance mismatches. Integration with Importer of Record (IOR) documentation is also critical.

Common Challenges and Solutions

Challenge 1: Tracking Embedded Batteries

Many products (toys, electronics) contain non-removable batteries. Identifying, quantifying, and accounting for these embedded units is complex.

Solution: Use product design databases and supplier declarations to estimate battery volumes accurately.

Challenge 2: Infrastructure Deficiency

Tier 2 and Tier 3 cities lack authorised recyclers, limiting collection.

Solution: Partner with national logistics providers to set up temporary collection points.

Challenge 3: Data Integrity in Reporting

Matching sales, collection, and recycling certificates is often error-prone.

Solution: Use compliance management platforms with real-time dashboards and automated matching tools.

Our Role as a Compliance Partner

As a leading import-export and compliance services company, at JPARKS we offer comprehensive assistance:

• Registration Services: CPCB portal setup and documentation support
• Target Tracking: Real-time monitoring of obligations vs. fulfilment
• Recycler and Refurbisher Network: Pan-India reach
• Return Logistics Setup: Reverse logistics planning, consumer interface
• Audit Readiness: Documentation, mock audits, and CPCB coordination
• Integrated EPR Management: Bundled services for battery, plastic, and e-waste compliance

Future Outlook

India’s EPR rules are evolving. Future changes may include:

• A unified credit trading platform for surplus recyclers
• QR code-based product traceability
• Mandatory third-party audits
• Eco-design guidelines for battery producers

Global harmonisation with the EU’s Battery Regulation and the U.S. EPA’s framework is expected. Companies investing in EPR now will be best positioned to lead in a resource-scarce, compliance-intensive world.

Conclusion | EPR Battery Waste 2025

EPR for battery waste is no longer a choice — it’s a legal mandate and a business imperative. Importers, manufacturers, and brand owners must embrace compliance not only to avoid penalties but to contribute to a greener, more sustainable economy. With strategic planning and the right compliance partner, navigating EPR Battery Waste can become a streamlined and value-generating process.

FAQs

1. How should importers report battery types when importing products with multiple embedded battery chemistries (e.g., lithium-ion and nickel-metal hydride)?

Importers must separately declare each battery chemistry and category (e.g., portable, industrial) in their EPR filing. The CPCB portal allows multiple entries per product batch. Documentation should be supported by OEM datasheets and customs classification records to avoid misreporting.

2. Are refurbished or re-exported batteries counted under a producer’s EPR Battery Waste liability?

No, batteries re-exported within India’s customs territory are not counted toward domestic EPR obligations. However, producers must maintain documentary evidence (e.g., shipping bills, export invoices) to prove re-export. For refurbished units sold in India, EPR continues to apply unless explicitly exempted.

3. Can digital compliance platforms be used to automatically match recycling certificates with collection targets on the CPCB portal?

Yes, but only with authorised recycler integration. Some CPCB-authorised recyclers provide API-based digital compliance tracking, allowing producers to match real-time recycling progress with their obligations. Manual validation is still required before uploading final returns.

4. What are the EPR Battery Waste responsibilities for producers using third-party marketplaces like Amazon or Flipkart?

Even if a producer sells via online platforms, the legal liability for EPR Battery Waste lies with the brand owner or importer who places the product on the Indian market—not the marketplace. However, marketplaces may ask sellers for EPR registration proof as part of their due diligence.

5. How are batteries used in solar energy storage systems classified under EPR?

These are classified as industrial batteries under the Battery Waste Management Rules. EPR Battery Waste obligations include separate collection, bulk transportation, and recycling via specialised recyclers. Producers must provide collection options for remote and off-grid locations where solar batteries are typically deployed.

6. Are companies liable for EPR Battery Waste if they import battery-containing products only for captive (in-house) use?

Yes. Even captive or in-house use by a business qualifies as ‘placing on the market’ under EPR Battery Waste rules. These entities must register and fulfill collection/recycling obligations unless they prove complete internal lifecycle control and disposal via authorised recyclers.

7. How should a company handle EPR reporting when battery imports occur under different business entities (e.g., parent company and subsidiaries)?

Each legal entity with a unique IEC/GST must register separately on the CPCB EPR portal. Aggregated reporting is not permitted unless formally merged under law. Coordination across group companies is essential to avoid duplicate or missing entries.

8. What compliance strategy should be followed for low-lifecycle or single-use batteries (e.g., button cells in hearing aids)?

Producers must still fulfill collection obligations, even for low-volume, single-use batteries. Strategies include:

• Collaborating with retailers or hospitals for drop-off points
  
• Public awareness campaigns to encourage return
  
• Outsourcing recovery logistics to a compliance service provider or recycler network
  

9. How does CPCB verify that collected batteries were actually recycled and not stockpiled or landfilled?

CPCB requires digitally signed recycling certificates from authorised recyclers/refurbishers. These certificates are verified against the recycler’s processing capacity and quarterly return filings. Random inspections and waste traceability audits may be conducted to prevent fraudulent reporting.

10. Can a producer offset EPR targets in one battery category (e.g., lead-acid) using surplus collection from another category (e.g., lithium-ion)?

No. Offsetting across battery categories is not allowed. EPR obligations must be met independently for each battery type and chemistry as declared during registration. Surplus in one category cannot compensate for a shortfall in another.