EPR for Battery Waste Management in India

  • EPR for Battery Waste is a mandatory CPCB compliance for producers, importers, and brand owners in India.
  • Silvereye Certifications (SEYECS) helps businesses obtain EPR authorization and meet recycling targets without regulatory risk.
  • Updated 2025 rules strengthen traceability, reporting, and enforcement under Battery Waste Management Rules.

Introduction

In India, Battery waste is quickly becoming one of the most pressing environmental issues, primarily due to the growing use of electric vehicles, consumer electronics, and energy storage systems. When batteries are not properly disposed of, they release toxic substances that can severely affect the environment and people's health.

In India, Battery waste is quickly becoming one of the most pressing environmental issues, primarily due to the growing use of electric vehicles, consumer electronics, and energy storage systems. When batteries are not properly disposed of, they release toxic substances that can severely affect the environment and people's health.

In order to mitigate this situation, the Government of India has mandated Extended Producer Responsibility (EPR) under the Battery Waste Management Rules as part of the battery waste management process. Manufacturers, importers, and brand owners are legally obliged to ensure the proper collection, recycling, and reporting of battery waste through the CPCB EPR portal under this framework.

Currently, EPR for Battery Waste stands as an enforceable compliance requirement, and timely registration and authorization are necessary actions to prevent fines and be in compliance with the law.

What is EPR For Battery Waste Management?

Extended Producer Responsibility (EPR) for Battery Waste Management is a compulsory compliance framework in India that requires battery manufacturers, importers, and brand owners to take legal responsibility for the collection, recycling, and disposal of battery waste in an environmentally safe manner.

Implementing and enforcing the EPR will trace the whole process of battery recycling, which will be done through a regulated method while at the same time helping to eliminate the environmental and health risks that may arise from improper disposal.

Role of producers in environmentally responsible battery disposal

  • Obtain EPR registration and authorization from the CPCB before placing batteries in the Indian market
  • Ensure collection and recycling of battery waste through authorised recyclers or PROs
  • Meet annual EPR recycling targets as prescribed under the Battery Waste Management Rules
  • Maintain traceability and compliance reporting on the CPCB EPR portal
  • Prevent informal or unsafe recycling practices that pose environmental and health risks

Why do you need EPR For Battery Waste Management?

  • Legal compliance requirement: EPR for Battery Waste is obligatory under the Battery Waste Management Rules for manufacturers, importers, and brand owners placing batteries in the Indian market.
  • Avoid penalties and regulatory action: Not getting EPR registration can result in environmental compensation, halting of operations, or limitations on sales and imports.
  • Environmentally safe disposal: EPR makes it compulsory that the waste from batteries is treated and recycled through the authorized channels, thus lessening the pollution and health risks.
  • Regulatory transparency: Compliance through the CPCB EPR portal provides the possibility of tracing and being ready for audits.
  • Business continuity and credibility: EPR authorization secures the access to the market, brand reputation, and trust with the regulators and customers.

Legal mandate under Battery Waste Management Rules

EPR registration is mandatory. Non-compliance can result in:

  • EPR is compulsory by law: The Battery Waste Management Rules stipulate that EPR is to be applied to all producers who sell batteries or battery-operated products in India.
  • CPCB registration necessary: Companies that produce batteries or battery-operated products have to get EPR registration as well as permission from the Central Pollution Control Board which is a regulatory authority, before starting or continuing their business operations.
  • Responsibility for the entire lifecycle: Legal responsibility is not just limited to sale but also includes collection, recycling and reporting of battery waste.
  • Compliance that can be enforced: Violations of the law can lead to a variety of consequences including the imposition of environmental compensation, fines, and revocation or suspension of registration.

Compliance requirements for manufacturers, importers, and brand owners

If your company places batteries—or battery-powered products—into India, EPR applies, regardless of company size or sales channel.

  • Mandatory EPR registration: Before releasing batteries or battery-powered devices onto the Indian market, get EPR approval from the CPCB.
  • EPR target fulfillment: Achieve the annual collection and recycling targets allocated to you through the use of authorized recyclers.
  • Use of CPCB EPR portal: Keep precise records and file returns needed on the CPCB EPR portal during the time limits set.
  • Authorised recycling only: Make it a policy that battery waste can only be processed by recyclers who have been approved by the CPCB.
  • Ongoing compliance: Continually update your information and be ready for audits, inspections, and the regulatory review process.

Importance of EPR For Battery Waste Compliance

Compliance with Extended Producer Responsibility (EPR) in battery waste management is a must for companies operating in India’s regulated environmental scenario. Battery waste is a mixture of toxic metals and other materials that the environment can even get rid of.

EPR compliance makes certain that the already defined process of collecting, recycling, and disposing of battery waste is adhered to and that it is done in an ecologically and legally approved way.

The main points why EPR compliance is important:

  • Environmentally sound handling and recycling of battery wastes are guaranteed.
  • Compensation for the environment, penalties, and the legal process all suffer.
  • It helps the regulatory system to be open and to be ready for audits through CPCB reporting.
  • It is a way of safeguarding business continuity, brand image, and market access.
  • It is a way of giving a helping hand to sustainable waste management and circular economy goals.

Environmental protection and sustainable waste management

The successful execution of the Extended Producer Responsibility (EPR) scheme in the context of battery waste management is significant not only for environmental protection, but also for the adoption of waste management methods that have less impact on the environment.

The improper disposal of batteries that contain toxins such as lead, cadmium, and lithium can result in the contamination of soil, water, and air.

One of the benefits of EPR is that it mandates the proper management and treatment of battery wastes which decreases the ecological footprint of their discarding.

Battery waste contains hazardous substances that contaminate:

  • Soil
  • Water
  • Air

EPR compliance ensures safe, scientific recycling.

Regulatory accountability and traceability of battery waste

CPCB’s digital EPR system allows real-time tracking of compliance, leaving no room for informal practices.

  • Ensures end-to-end tracking of battery waste through mandatory reporting on the CPCB EPR portal
  • Establishes clear accountability for producers across the entire battery lifecycle, from market placement to recycling
  • Enables regulators to verify recycling targets and compliance data in real time
  • Prevents diversion of battery waste to unauthorised or informal recycling channels
  • Creates a transparent and auditable compliance framework aligned with the Battery Waste Management Rules

Benefits of EPR For Battery Waste

Reduced Environmental and Health Risks

In the case of EPR for Battery Waste Management, the waste comes from batteries and is taken care of through controlled and authorised recycling systems, thus greatly minimizing the chances of harming the environment and risking the health of people.

  • Controlled recycling: Only CPCB-authorised recyclers process battery waste through eco-friendly methods
  • Reduced toxic exposure: The release of hazardous substances like lead, cadmium, and lithium into soil, water, and air is minimised

Improved Corporate Sustainability and Brand Credibility

EPR compliance enhances a manufacturer’s green personality and is a clear indicator of good business practices to the public.

  • ESG alignment: Helps fulfil environmental, social, and governance (ESG) commitments and sustainability reporting
  • Investor and partner trust: Through transparent compliance, it creates trust among investors, regulators and business partners

Alignment with Circular Economy Principles

EPR supports the proper use of resources by replacing battery waste with the recycling ecosystem that has been set up.

  • Resource recovery: Freedom to recover precious materials, thus, cutting down the need for supplying virgin raw materials
  • Long-term cost efficiency: Future compliance and material costs are kept low by systematic recycling and recovery processes

Eligibility for EPR For Battery Waste Management

Entities Covered under EPR Obligations

EPR for Battery Waste Management applies to all entities that place batteries or battery-operated products into the Indian market, regardless of business size or operational model.

  • Battery manufacturers: Entities manufacturing batteries or battery packs in India
  • Importers: Businesses importing batteries or products containing batteries into India
  • Brand owners: Companies selling batteries under their own brand or private label
  • Online sellers: E-commerce platforms and sellers offering batteries or battery-powered products

Applicability Based on Battery Placement in the Indian Market

EPR applicability is determined by market placement, not physical presence. Any entity that introduces batteries into the Indian market—directly or indirectly—is legally required to obtain EPR registration and comply with Battery Waste Management Rules, even if the company has no physical office or manufacturing unit in India.

Who is Required to Obtain EPR Registration for Battery Waste?

EPR Registration for Battery Waste is mandatory for all entities that place batteries or battery-operated products in the Indian market. The requirement applies regardless of company size, sales channel, or country of origin.

Battery Manufacturers and Assemblers

Battery manufacturers and assemblers operating in India are directly responsible for EPR compliance, as domestic production creates immediate legal liability under the Battery Waste Management Rules.

  • Manufacturing or assembling batteries in India triggers mandatory EPR registration
  • Responsibility includes collection, recycling, and compliance reporting

Importers of Batteries and Battery-Operated Equipment

Importers are equally obligated to comply with EPR requirements for battery waste, regardless of the product category.

  • Importing batteries or battery-powered equipment requires prior EPR authorization
  • Customs clearance does not replace EPR registration with the CPCB

Brand Owners and Producers Selling Batteries in India

Brand owners, including private-label sellers, are fully accountable for EPR compliance.

  • Selling batteries under a brand name creates EPR liability
  • Private-label brands remain fully responsible for recycling and regulatory reporting obligations

Types of Battery Covered under EPR

The Battery Waste Management Guidelines designate EPR responsibilities for numerous battery types within the scope of consumer, commercial, and industrial applications.

The different categories are characterized by compliance requirements depending on usage, the amount of batteries, and the risk to the environment.

Portable Batteries

Portable batteries are the most common power sources for both household and personal electronic devices and are thus responsible for huge quantities of post-consumer battery waste.

  • Wherein, they find applications in mobile phones, laptops, tablets, toys, wearables, and other small electronic gadgets
  • Generally, they consist of lithium-ion, nickel-metal hydride, and alkaline batteries
  • The high disposal frequency necessitates controlled collection and recycling through regulation
  • EPR provides the guarantee that these batteries will not go to unsafe waste streams

Automotive Batteries

Automotive batteries are a subject of regulation because they contain hazardous materials and their environmental impact lasts for many years to come.

  • Lead-acid batteries found in conventional vehicles are included
  • Batteries used in hybrid vehicles are also covered
  • Lead and sulfuric acid are among the toxic materials
  • EPR forces the use of licensed facilities for the controlled recycling of such batteries

Industrial Batteries

Batteries for industrial use play a critical role in the supply of power to the infrastructure, hence the demand for compliance is very high.

  • They are used in uninterruptible power supply (UPS) systems, telecommunications towers, data centers, and solar energy installations
  • These batteries are specially designed to handle high-capacity and long-duration use
  • The improper disposal can lead to severe environmental and safety problems
  • The EPR takes care of the whole process of handling, recycling the waste, and recovering the material in a safe manner

Electric Vehicle (EV) Batteries

EV batteries fall under a high-priority category due to their size, chemical composition, and growing market share.

  • Large-capacity lithium-ion battery packs used in electric two-wheelers, cars, and commercial EVs
  • High-value materials such as lithium, cobalt, and nickel
  • Subject to stricter oversight, tracking, and recycling obligations under EPR
  • EPR compliance supports safe recycling and circular use of critical resources

Battery Waste Management Rules, 2022 – Latest Amendments & EPR Compliance Requirements (2025 Update)

The Battery Waste Management Rules, 2022, usher in the legal groundwork for Extended Producer Responsibility (EPR) throughout the country regarding all types of batteries. The former scattered battery disposal rules have been replaced by these regulations, which don’t just stop there, but create a whole new EPR system where all manufacturers are made responsible for the life cycle of batteries—from placing them in the market to disposing of them properly.

By mandating EPR in the 2022 Rules, various aspects like registration, recycling targets, authorized recyclers, reporting mechanisms, and enforcement provisions were specified and placed under the supervision of the Central Pollution Control Board (CPCB).

Key features of the 2022 Rules include:

  • Mandatory EPR for all battery producers including manufacturers, importers, and brand owners
  • Annual recycling targets and compliance reporting
  • Use of authorised recycling channels only
  • Documentation and verification through the CPCB EPR portal

Key Amendments Introduced under Battery Waste Management Amendment Rules, 2025

The Battery Waste Management Amendment Rules, 2025 have brought about a number of significant changes, all aimed at enforcing compliance and ensuring proper traceability inside the EPR framework. Among these are:

  • EPR marking based on mandatory QR/barcode: A QR code or a barcode with the EPR registration number must be produced or affixed to batteries, battery packs, devices with batteries, and their packaging.
  • CPCB disclosures quarterly: Every quarter, producers must disclose their EPR status and recycling performance through the central portal of the CPCB that is open to the public. CPCB unifies this data and makes it accessible to the public, thus providing greater transparency.
  • Low heavy-metal batteries relaxation: Batteries whose heavy metal content is below certain limits (e.g., cadmium and lead below defined ppm limits) are exempted from some marking requirements, therefore the compliance burden for such low-hazard products is made lighter.
  • The changes indicate the regulator’s intent to move towards more accurate data reporting, better tracking, and less informal recycling.

ENFORCEMENT OF EPR MARKING, REPORTING AND COMPLIANCE BY 2025 AMENDMENTS

The amendment of 2025 has fortified the EPR framework in many practical manners:

  • Better traceability: The requirement for QR/barcode makes it possible to check the EPR registration at any place in the supply chain, thus enhancing the accountability.
  • Tighter enforcement mechanisms: The monitoring of compliance, through quarterly disclosures, is a continuous process for CPCB, which means there will be no delay in discovering the gaps.
  • More transparency: The data on compliance made public is a good source of information for all parties involved in the process, that is, regulators, recyclers, and consumers.
  • Reduced informal recycling: By linking EPR authorization, marking, and reporting, the amendments discourage unregulated handling of battery waste and strengthen formal recycling channels.

Together, these updates ensure that EPR for Battery Waste Management is not only more transparent but also more enforceable, supporting environmental protection and regulatory compliance across India’s battery ecosystem.

Importance of EPR Compliance for Battery Waste

EPR compliance for battery waste is essential to ensure that hazardous batteries are collected, recycled, and disposed of through authorised and environmentally safe channels.

It helps businesses meet their legal obligations under the Battery Waste Management Rules while reducing environmental and health risks associated with improper battery disposal.

Key reasons EPR compliance matters:
  • Ensures safe and authorised recycling of battery waste
  • Prevents penalties, environmental compensation, and regulatory action
  • Maintains traceability and transparency through the CPCB EPR portal
  • Supports business continuity and regulatory credibility

EPR Registration Process for Battery Waste

The waste battery management system based on EPR (Extended Producer Responsibility) consists of a strict compliance process prescribed by the Central Pollution Control Board (CPCB).

Manufacturers need to determine their eligibility, provide precise data, and carry out post-approval requirements in order to be considered compliant under the Battery Waste Management Rules.

EPR registration key stages:

  • Eligibility assessment: Determine which battery category is applicable and what EPR obligations for producers are
  • Registration on CPCB portal: Generate an application on the EPR portal of CPCB with the necessary information and submit
  • Submission of documents: Provide copies of documents related to business, product, and compliance
  • Examination and acceptance: The CPCB reviews the submitted application and grants EPR authorization if it has been approved
  • Compliance after registration: Achieve recycling goals, keep track of and submit reports as per the requirements

Documents Required for Battery Waste EPR Registration

To obtain EPR registration for battery waste, producers must submit accurate and complete documentation on the CPCB EPR portal. These documents help regulators verify the business, product details, and recycling arrangements under the Battery Waste Management Rules.

Key documents required include:

  • Business and incorporation documents: PAN, GST registration certificate, and company incorporation details
  • Authorised signatory details: ID proof and authorisation letter
  • Product and battery information: Battery type, chemistry, capacity, and annual quantity placed in the market
  • EPR plan: Details of collection and recycling strategy
  • Agreements with authorised recyclers or PROs: Valid contracts approved by CPCB
  • Import-related documents (if applicable): IEC and import details

Submitting correct documentation is essential to avoid delays or rejection of the EPR application.

EPR Targets & Recycling Obligations

Producers under the Extended Producer Responsibility (EPR) for Battery Waste scheme are compelled to achieve specified collection and recycling targets as a part of their legal compliance.

The targets established under EPR guarantee that the battery waste resulting from the products marketed is properly collected and recycled through licensed channels.

The main points of EPR targets and recycling requirements are:

Producers are obligated to meet recycling targets year-wise depending on the total batteries introduced into the Indian market.

  • Disposal through an authorized channel: Battery waste is to be recycled only through the recyclers approved by CPCB or registered PROs.
  • Recycling credits: The achievement of the targets is validated through the recycling certificates or credits.
  • Regular reporting: The manufacturers are required to file annual and, if necessary, quarterly compliance reports on the CPCB EPR portal.
  • Continuous monitoring: Not achieving targets might result in fines for environmental damage or other measures to correct the situation.

Penalties for Non-Compliance

Should battery waste management producers fail to comply with EPR, they will face severe repercussions both regulatory and monetary.

The staff or the authorities regulating battery waste management will initiate measures against the companies, which do not get EPR registration, do not meet recycling targets, and do not follow the reporting requirements.

Among the penalties, the most significant are mentioned below:

  • Environmental compensation: Financial penalties based on unfulfilled EPR targets or violations of the regulations would be imposed.
  • Suspension or cancellation of the EPR authorization: Loss of approval may hinder the entire business operations.
  • Regulatory actions: The CPBC or SPCBs would issue show-cause notices, conduct audits and initiate enforcement proceedings.
  • Business disruption: The manufacturers, importers, or sellers of batteries and battery-operated products would be under restrictions.

EPR Registration Timeline & Cost for Battery Waste Management

Stage Activity Estimated Timeline Indicative Cost Range (INR)
Stage 1 Eligibility assessment & compliance planning 1–2 working days Included in consultancy
Stage 2 Document preparation & verification 3–5 working days ₹5,000 – ₹15,000
Stage 3 CPCB EPR portal application filing 1–2 working days ₹10,000 – ₹25,000
Stage 4 CPCB review & clarification (if required) 7–15 working days No additional fee
Stage 5 Grant of EPR Authorization 15–30 working days As per CPCB norms
Stage 6 Recycler onboarding & EPR target fulfilment Ongoing Depends on EPR targets

EPR Authorization Validity & Renewal for Battery Waste Management

Aspect Details
Validity of EPR Authorization Valid as long as the producer continues operations and meets annual EPR obligations
Annual Compliance Requirement Mandatory fulfilment of EPR targets and submission of annual returns
Renewal Requirement Renewal not automatic; compliance performance is reviewed annually
When to Apply for Renewal / Update Before the end of the financial year or as prescribed by CPCB
Documents for Renewal Updated EPR returns, recycler certificates, and compliance reports
Consequence of Non-Renewal Suspension of EPR authorization and regulatory action

Why Choose a Professional Consultant for Battery Waste Compliance

The compliance with EPR for battery waste consists of changing regulations, technical documentation, and the continuous control of the CPCB.

A consultant's expertise attracts the firms to meet the requirements very well and stop the compliance risks by being efficient.

Reasons why one should rely on a professional EPR consultant are given below:

  • Authority on regulations: Precise information about the Battery Waste Management Rules already in force and the latest ones added
  • No errors in documentation: Proper filing leads to no delays, no rejections, and no gaps in compliance
  • Quicker grants: The CPCB EPR registration process is expedited in terms of handling
  • Continuous compliance backing: Help with setting and reaching targets, reporting, and renewals
  • Less regulatory risk: The management of compliance in an active manner results in avoiding penalties and not having to stop operations because of business disruption

How We Help with EPR For Battery Waste Compliance

At Silvereye Certifications (SEYECS), we provide end-to-end support to help businesses achieve and maintain compliance with EPR for Battery Waste Management. Our approach is practical, regulation-focused, and aligned with CPCB requirements.

Our EPR compliance support includes:.

We ensure that EPR compliance is handled efficiently, allowing businesses to focus on operations without regulatory risk.

Conclusion

EPR for Battery Waste Management is an indispensable compliance factor for enterprises that are a part of the Indian battery ecosystem. The Battery Waste Management Rules have led to more rigid implementation and the CPCB has been regulating the situation closely, so the companies that have registered for EPR on time and are constantly complying will be the only ones to avoid penalties, safeguard their business activities, and promote eco-friendly waste disposal.

Correct application of EPR will not only give the organizations the regulatory credibility but also the continuity of the business in the long run. Silvereye Certifications (SEYECS) is providing expert guidance to businesses to help them meet EPR requirements in a confident manner and to ensure smooth compliance in a quickly changing regulatory atmosphere.

Frequently Asked Questions (FAQs)

LMPC Certification is issued for manufacturers, importers, packers/re-packers, and varies between state-level and central-level registration depending on the business activity.

Importers must obtain Central LMPC Registration, issued by the Legal Metrology Department, before clearing goods at customs.

Yes. Manufacturers pack goods they produce, while packers/re-packers pack or re-pack goods manufactured by others. Both require separate LMPC certification types.

Yes. State LMPC Registration is valid only in the issuing state. Businesses operating in multiple states must obtain multiple state-wise registrations.

Central LMPC Registration is mainly valid for import activities, but it does not replace state LMPC registration for manufacturing or packing operations

Yes. Online sellers must hold valid LMPC Registration under the applicable category (manufacturer, importer, or packer) to sell pre-packaged goods legally.

Yes. For example, an importer who also re-packs goods in India may need Central LMPC and State LMPC Registration.

LMPC Registration is linked to both the business and the type of packaged commodities, including packaging and labeling details.

Incorrect categorization can lead to application rejection, penalties, seizure of goods, or customs clearance delays.

LMPC certificates are usually valid for 1 to 5 years, depending on the state or central authority, and must be renewed before expiry