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Battery Waste Management Consulting

Learn about the Battery Waste Management Authorization from State Pollution Board if you are manufacturing, bulk user or recycling the lead-acid batteries.

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Battery Waste Management (BWM) Authorization

Introduction

The Battery Waste Management Registration Process has been taken over by the Central Pollution Control Board (CPCB). The registrations associated with the Battery Waste Management is now called as the Battery EPR certificate, for importers, manufacturers and battery recyclers. 
  • The amount of lead generated from secondary sources is greater than the amount produced from primary sources. According to estimates, the country's lead consumption is about 4.5 lakh tonnes, with only around 1.6 lakh tonnes derived from primary sources. Primary lead production is also decreasing across the world. This means that every year, more lead is produced via the secondary path, which involves hundreds of small-scale recyclers across the country. It is critical to ensure that lead is generated by secondary smelting only in an environmentally sustainable manner, as failure to do so would result in significant environmental and health issues. The Batteries Management and Handling Rules were adopted in 2001 with the primary goal of ensuring the safe disposal of discarded lead-acid batteries with the participation of all stakeholders. To ensure environmentally sound recycling of used batteries, rules have been established to ensure proper monitoring and record keeping on the selling or import of lead-acid batteries, as well as the storage of used batteries for recycling by registered recyclers.
  • Improper lead handling and recycling could endanger workers' health and have a negative effect on the environment. As a result, it is critical to ensure that secondary lead processing takes place in facilities that are registered with the Central or State Pollution Control Boards in an environmentally sustainable manner. It is essential to ensure that all recyclables are directed to approved recycling facilities. It is also necessary to put an end to the widespread practise of smelting used lead-acid batteries in backyards throughout the Country.
  • Manufacturers, importers, reconditioners, and assemblers have responsibilities under the Batteries Rules to ensure that used batteries are collected and routed to Authorized recyclers. Other stakeholders, such as retailers, recyclers, customers, auctioneers, and regulators, including customs authorities, were also assigned responsibilities.

Applicability of Battery Waste Management Rules,2020

Every manufacturer, importer, & recycler involved in the manufacture, processing, sale, purchase, collection, storage, reprocessing, and use of batteries or their components, including their components, consumables, and spare parts that make up the product operational

  • all types of batteries, regardless of form, length, weight, material composition, or use, as specified in Schedule-I;
  • all appliances into which a battery is or may be fixed to operate

These regulations do not apply to Batteries used in:

  • Equipment associated with the defence of vital security interests such as weapons, ammunition, and war material, and designed specifically for military purposes;
  • Equipment designed to be sent into space are exempted from these Regulations (space exploration)
  •  Warning and emergency systems;
  • Emergency lighting; and
  • Medical Equipment

The import and export of battery waste, as well as hazardous waste produced in the establishments of users mentioned in Rule 2(1), are governed by the Hazardous Wastes (Management, Handling, and Transboundary Movement) Rules, 2008.

Benefits of Battery Waste Management EPR Registration

1.  Legal Compliance & Avoid Penalties
Ensures compliance with the Battery Waste Management Rules, 2022, avoiding regulatory actions, penalties, and business interruptions. 

2.  Environmental Responsibility
Enables responsible collection, recycling, and disposal of waste batteries, enhancing sustainability credentials. 

3.  Smooth Business Operations
Mandatory for manufacturers, importers, recyclers, refurbishers, and dealers to operate legally under CPCB/SPCB norms. 

4.  Brand & Market Credibility
Improves trust with customers, OEMs, and buyers by demonstrating adherence to environmental regulations. 

5.  Access to Extended Producer Responsibility (EPR)
Authorization is essential for filing EPR obligations and ensuring transparent tracking of waste battery flow. 
 

How to get Battery Waste Management EPR Registration

Step 1 – Eligibility & Documentation Check
Assessment of applicant category (Manufacturer / Importer / Recycler / Refurbisher / Dealer) and compilation of required documents. 

Step 2 – Online Application on CPCB Portal
Preparation and submission of the BWM Authorization form along with mandatory attachments and declarations. 

Step 3 – Technical Review by CPCB/SPCB
Regulatory authorities verify product details, recycling arrangements, EPR plan, and compliance history. 

Step 4 – Clarifications & Compliance Verification
Responding to queries, submitting additional information, and ensuring adherence to rules and standards. 

Step 5 – Authorization Issuance
Upon approval, CPCB/SPCB grants the Battery Waste Management Authorization valid for the prescribed period. 
 

What are the documents required for BWM EPR Registration

  • CIN of the applicant company 
  • PAN card of the applicant company 
  • GST Certificate 
  • Authorized Signatory KYC  
  • Authorization Letter / Board Resolution 
  • IEC Certificate (Importers) 
  • Battery Details (Type, Model, Capacity) 
  • Product Specifications 
  • Production / Import / Sales Data 
  • Collection & Recycling Plan 
  • Consent to Operate (CTO) 
  • Site Layout / Storage Details 

What you get?

  • Battery EPR Registration with the CPCB

Common Questions

Frequently Asked Questions

  • The Batteries Management and Handling Rules were adopted in 2001 with the primary goal of ensuring the safe disposal of discarded lead-acid/li-ion batteries, with the participation of all stakeholders. To ensure environmentally sound recycling of used batteries, Battery EPR Rules have been established to ensure proper monitoring and to record the manufacturing & import of lead-acid/li-ion batteries, as well as the storage of used batteries for recycling by registered recyclers.
  • Improper lead handling and recycling could endanger workers' health and have a negative effect on the environment. As a result, it is critical to ensure that secondary lead processing takes place in facilities that are registered with the Central or State Pollution Control Boards in an environmentally sustainable manner. It is essential to ensure that all recyclables are directed to approved recycling facilities. It is also necessary to put an end to the widespread practice of smelting used lead-acid/li-ion batteries in backyards throughout the Country.
  • Manufacturers, importers, reconditioners, and assemblers have responsibilities under the Batteries Rules to ensure that used batteries are collected and routed to Authorized recyclers. Other stakeholders, such as retailers, recyclers, customers, auctioneers, and regulators, including customs authorities, were also assigned responsibilities.
     
  • Every manufacturer, producer, collection centre, importer, reconditioner, refurbisher, dismantler, assembler, dealer, recycler, auctioneer, vehicle service centre, consumer, and bulk consumer involved in the manufacture, processing, sale, purchase, collection, storage, reprocessing, and use of batteries or their components, including their components, consumables, and spare parts that make up the product operational
  • All types of batteries, regardless of form, length, weight, material composition, or use, as specified in Schedule-I;
  • All appliances into which a battery is or may be fixed to operate
     
  1. Any entity generating battery waste must obtain permission from the Central Pollution Control Board (CPCB) 
  2. He must submit an online application on the CPCB Battery EPR portal. 
  3. IN case of Battery Manufacturers & Battery recyclers, the CPCB forwards your application to the State Pollution Control Board or the Pollution Control Committee of Union territories. 
  4.  Each entity authorized under these rules must keep a record of the battery waste they handle in Form 6 and prepare and submit an annual return containing the information stated in Form 1 to the Central Pollution Control Board on or before the 30th day of June following the financial year to which the return relates.

The applicant is required to submit an online application on the CPCB-Central Pollution Control Board portal. The Battery EPR Certificate for importers is issued by the CPCB, for battery Manufacturers and battery recyclers, the CPCB forwards the application to the respective State Pollution Control Board for CTO verification and recommendation. The concerned officer may inspect the premises where the battery materials are being used and may issue some clarifications. Once the clarifications issued by the Inspecting Authority are suitably submitted, the Battery waste EPR certificate is issued. 

The Government fee for Battery Waste EPR certificate depends on the Annual Turnover of the applicant's business. For a turnover of up to Rs. 5 crore, the Govt fee is Rs.10,000, for a turnover of up to Rs.50 crore, the Govt fee is Rs.20,000 and above Rs.50 crore, the Govt. fee is Rs.40,000. If an agency is hired for the same, it may charge you an agency fee. 

  • CIN certificate
  • Company Pan Card
  • GST Certificate
  • IEC / SPCB CTO
  • Aadhar Card + Pan Card of authorized person
  • Email ID + Mobile no for CPCB Registration
  • Previous year Balance sheet
  • Battery Type - Brand name - Constituents of battery - Purpose of use
  • Battery import/Manufactured data
  1. Any producer of battery/battery-containing equipment must apply for EPR Authorisation in Form 3 to State Pollution Control Board Pollution Control Committees in the case of selling their product in one state or to the Central Pollution Control Board in the case of selling their product in more than one state within three months of the date of commencement of these rules.
  2. In the case of a pan-India authorization, upon receipt of a complete application in all respects, a committee constituted by Central Pollution Control Board (CPCB) with representatives from State Pollution Control Board (SPCB) or Pollution Control Committees(PCC), after evaluating the State-specific EPR Plan, after such an inquiry as it deems appropriate, and on being satisfied that the producer has detailed out an effective system to manage Extended Producer Responsibility, The EPR-Authorization would be valid for a maximum of five years at first.
  1. ‘Battery’ or ‘’accumulator’’ means any source of electrical energy produced by direct conversion of chemical energy, including disposable primary (Alkaline/Mercury/Silver oxide/Zinc Carbon) batteries, rechargeable secondary (Lead Acid/Lithium Ion/Lithium Metal/Nickel Cadmium) batteries, and any other battery that contains (or may produce) potassium hydroxide at the end of its life.
  2. Extended Producer Responsibility (EPR) refers to any battery manufacturer's responsibility for their products beyond production before environmentally sound end-of-life management; and for the channelization of waste batteries to ensure environmentally sound waste management. Implementing a take-back scheme, setting up recycling centres, or both, and making agreed agreements with registered recyclers either individually or jointly through a Producer Responsibility Organization acknowledged by producer or producers in their Extended Producer Responsibility are examples of Extended Producer Responsibility. - Authorization;
  3. ‘Producer' refers to someone who: i. manufactures and offers to sell batteries and their components, consumables, parts, or spares under their own brand; or ii. manufactures or offers to sell equipment / products that use a battery or batteries as a component under their own brand; or iii. offers to sell assembled battery under their own brand.
  1. Person who is generating battery waste must obtain a Battery EPR Certificate from the Central Pollution Control Board (CPCB) 
  2. Following receipt of a Battery Manufacturer or a Battery Recycler EPR application for Battery EPR, the State Pollution Control Board or the Pollution Control Committee of Union territories can, after making any inquiries it deems necessary and being satisfied that the applicant has appropriate facilities, technical capabilities, and equipment to safely handle battery waste, will issue the Battery EPR Certificate
  3.  Every person authorized under these rules must keep a record of the battery waste they handle in Form 6 and prepare and submit an annual return containing the information stated in Form 1 to the Central Pollution Control Board on or before the 30th day of June following the financial year to which the return relates.

The Government fee for Battery Waste EPR certificate may range from Rs.10,000 up to Rs.40,000 depending on the Annual Turnover of the previous year. If an agency is hired for the same, it may charge you a consulting fee.

1.  Documents required for Producers/Manufacturers of Batteries

  • Certificate of Incorporation / Business Registration
  • PAN Card of Company
  • GST Certificate
  • PAN Card & Aadhaar Card of Authorized Signatory
  • Battery Sale/purchase data of last 2 years
  • Types of Batteries and Battery Chemistry
  • State Pollution Board CTO for Battery Manufacturing

2.  Documents required for Importers / Brand Owners of Batteries

  • Certificate of Incorporation / Business Registration
  • PAN Card of Company
  • GST Certificate
  • PAN card & Aadhaar card of Authorized Signatory
  • Import Export Code (IEC) / SPCB CTO/CFO Consent
  • Details of Batteries or Battery Products Imported / Sold
  • Battery Chemistry Details

3.  Documents for Recyclers / Refurbishers of batteries

  • Certificate of Incorporation / Business Registration
  • PAN Card
  • GST Certificate
  • PAN & Aadhaar of Authorized Signatory
  • SPCB Consent to Operate (CTO)
  • Details of Recycling / Refurbishing Facility
  • Installed Capacity of Plant
  • Process Flow of Recycling

‘Battery’ or ‘’accumulator’’ means any source of electrical energy produced by direct conversion of chemical energy, including disposable primary (Alkaline/Mercury/Silver oxide/Zinc Carbon) batteries, rechargeable secondary (Lead Acid/Lithium Ion/Lithium Metal/Nickel Cadmium) batteries, and any other battery that contains (or may produce) potassium hydroxide at the end of its life.

Extended Producer Responsibility (EPR) refers to the battery manufacturers'/ importers' responsibility for their products beyond production. They are required to dispose off their battery scrap in an environmentally sound manner, implementing a take-back scheme, setting up recycling centres, or both, and making agreements with registered recyclers.

‘Producer' refers to someone who:   

 i. manufactures and offers to sell batteries and their components, consumables, parts, or spares under their own brand;

ii. manufactures or offers to sell equipment/products that use a battery or batteries as a component under their own brand; 

iii. offers to sell assembled batteries under their own brand.

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