Battery EPR Compliance

Batteries EPR Annual Compliances

• To ensure the safe and environment-friendly processing of waste batteries in India, the Ministry of Environment, Forests and Climate Change has issued a notification titled “Battery Waste Management Rules, 2022”.
• The new rules replace the Batteries (Management and Handling) Rules, 2001. The manufacturers, importers & recyclers of lead-acid batteires & Lithium-ion batteries are covered by these rules.
• The regulations apply to all types of batteries, electric vehicle batteries, portable batteries, automotive batteries and industrial batteries. The new rules impose a minimum percentage for the recovery of materials from spent batteries and also require the use of a certain number of recycled materials in the production of new batteries. These battery rules will undoubtedly ensure that the Indian government’s vision of promoting a circular economy is fully realised, with Batteries EPR Compliance mandatory for all stakeholders. 
• The term "Extended Producer Responsibility" (EPR) refers to a battery manufacturer's or a battery importer's responsibility for their products beyond manufacturing until environmentally sound management of their end-of-life products, as well as the channelling of waste batteries to ensure environmentally sound waste management. Implementing a take-back system or establishing collection centers or both and having agreed arrangements with registered recyclers, either individually or collectively 

Key Highlights of The New Battery Waste Management Rules

• Promote Entrepreneurship: The new rules promote the setting up of new industries and entrepreneurs in the domain of recovery, recycling, and refurbishment of waste batteries. 
• Functions of Consumer: To discard the waste battery separately from the waste streams, especially from mixed, domestic waste streams to ensure the waste batteries are disposed of in an environmentally-friendly manner by giving it to an entity engaged in collection or refurbishment. 
• Functions of Producer: They shall have obligations or extended producer responsibility for the battery that they introduce in the market to ensure the attainment of the recycling or refurbishment obligations. The producer will meet the collection and recycling and refurbishment targets as mentioned in schedule II. 
• The person or entity involved in the manufacturing of the battery shall have to register through the online centralized portal as a producer in Form 1(A). The Batteries EPR Compliance of registration shall be issued in form 1(B). 
• The waste batteries collected by the producer will be sent for recycling and shall not be sent for landfilling or incineration. 
• The producer will submit the extended producer responsibility plan in Form 1(C) to the central pollution control board by 30 June every year. 

Minimum use of Recycled Materials out of the Total Dry Weight of a Battery in Percentage

Guidelines Set by the Central Pollution Control Board

Schedule 1

Prohibition and Labeling Requirements

• Prohibition on the metal item in the battery.
• The battery shall not apply to button zinc silver oxide batteries with a mercury content <2% and button.
• Medical equipment 
• A battery that contains up to 0.002% (2000 ppm) of cadmium by weight may only be placed. 
• Zinc-air Battery with a mercury content <2% by weight. 
• A battery that contains up to 0.0005% (5 ppm) of mercury weight may only be placed.
• Portable battery intended for use in.
• Emergency and alarm systems, including emergency lighting. 

Labelling Requirements 

• No person shall place the market on the battery or a button cell containing mercury, cadmium, or lead unless it is marked with the respective chemical symbol- Hg, cd, PB. 
• All requisites labels and symbols shall be printed visibly, legibly, and indelibly. 
• When the size of the battery or battery pack is such that the crossed-cut wheeled bin symbol would be smaller than 0.5cm x 0.5cm, the battery or battery pack needs. 
• The producer shall ensure that all battery packs are appropriately marked with requisite labelling requirements as per the standard prescribed by the Bureau of Indian Standards. 
• No person shall place on the market any battery or battery pack unless it is marked with crossed out wheeled bin symbol as shown in covering at least 3% of the area of the largest side of the battery. 

Schedule II

Targets for extended Producer Responsibility

• Producer shall meet their Extended Producer Responsibility obligation through the extended producer responsibility Registration.
• Recycling waste of batteries means recycling battery materials such as nickel, lead, zinc-based battery, cobalt, etc. 
• If a producer introduces a battery in the market in subsequent hears after the publication of these rules then extended producer targets shall be applicable for different types of batteries, based on the average life of the battery. 

• Helps maintain proper records and submit returns to authorities 
• Improves accountability and traceability

• Establishes structured collection and recycling channels 
• Ensures proper tracking and documentation of battery waste 

• Enhanced Brand Equity: Consumers in 2026 are highly eco-conscious. Publicly demonstrating EPR compliance through QR codes or "Green Certifications" on packaging builds immense brand trust.
• Resource Independence: By building robust domestic recycling loops, companies (and nations) reduce their reliance on volatile global markets for critical minerals.

• Target Calculation: The portal automatically calculates your Recycling Targets based on the weight and type of batteries you sold in previous years (e.g., a percentage of the average life cycle of the battery).
• E-Waste Collection: Producers must ensure that an equivalent amount of waste battery weight is collected. This is usually done through:
• Buy-back schemes or collection centers.

• Collection and channelization: Collect waste batteries through dealers, service centres, buy back or take back schemes, and ensure they move only to authorised recyclers/refurbishers.
• Record keeping and labelling: Maintain records of quantities placed in the market and collected/recycled; comply with QR code/marking and information requirements for traceability.

• Periodic returns: File periodic/annual returns on the CPCB portal within prescribed timelines, declaring quantities placed on the market, collected, recycled, and corresponding EPR certificates used.
• Renewal and updates: Apply for renewal of registration (typically about 60 days before expiry) and update any change in product mix, capacity, or corporate details on the portal.

• Sales invoices / bills
• Battery details

• Battery EPR Annual Compliance submission report