Background
The Battery Waste Management Rules, 2022, notified under the Environment (Protection) Act, 1986, came into force on 24 August 2022, replacing the Batteries (Management and Handling) Rules, 2001. The Rules establish an Extended Producer Responsibility (EPR) framework covering portable, automotive, industrial, and electric vehicle batteries throughout their lifecycle. Compliance is administered through the CPCB Battery Waste EPR Portal, enabling registration, return filing, and EPR certificate management. The Battery Waste Management (Amendment) Rules, 2023 strengthened EPR obligations and clarified continuing liabilities, while CPCB’s GST e-invoicing requirement for EPR certificates became effective from 1 July 2026.
Applicability
The Rules apply to Producers, Consumers, Collection Entities, Refurbishers, and Recyclers. Producers must obtain EPR registration, fulfil collection and recycling targets, file returns, comply with labelling and recycled-content requirements, and transact only with registered entities. Consumers must channel waste batteries through authorised collection or recycling systems. Collection entities, refurbishers, and recyclers are required to register with the prescribed authorities, comply with CPCB guidelines, file periodic returns, report on the EPR portal, and deal only with registered entities. Recyclers must also comply with the GST e-invoicing requirements for EPR certificate generation.
Compliance Requirement Under the act in Accordance with the Rules & Regulations:
Every Producer must obtain registration from the Central Pollution Control Board (CPCB) through the online centralised EPR portal in Form 1(A) before commencing operations. ‘Producer’ means an entity that: (i) manufactures and sells batteries, including refurbished batteries and batteries incorporated in equipment, under its own brand; or (ii) sells batteries, including refurbished batteries and batteries incorporated in equipment, under its own brand where such batteries are produced by other manufacturers or suppliers; or (iii) imports batteries as well as equipment containing batteries. Upon registration, the CPCB issues a Certificate of Registration in Form 1(B), which remains valid until it is cancelled or withdrawn.
Every Producer bears Extended Producer Responsibility (EPR) obligations as specified in Schedule II to the Rules, in respect of all batteries introduced in the market and batteries put to self-use. The EPR obligations include meeting collection, recycling, and refurbishment targets for batteries or battery packs made available in the market, including those put to self-use, in the proportions and timelines specified in Schedule II. Every Producer must also file an Annual Return in Form 3 in respect of pre-consumer waste batteries generated in the preceding financial year, in addition to the annual return for batteries collected and recycled or refurbished. The Amendment Rules of 2023 introduced Rule 4(2A), which provides for additional EPR-related obligations for Producers as specified therein.
Every Producer is required to ensure that waste batteries collected by them are sent only for recycling or refurbishing. No waste battery collected by a Producer may be sent for landfilling or incineration. Producers must channel collected waste batteries exclusively to registered recyclers or refurbishers.
Every Producer must promptly inform the Central Pollution Control Board of:
As confirmed and reinforced by the Battery Waste Management (Amendment) Rules, 2023, every Producer must inform the Central Pollution Control Board of any changes to the information contained in the Extended Producer Responsibility Registration. This obligation is continuous and applies whenever any registered particulars are altered, including changes in battery categories, production volumes, brand names, or organisational details.
Where a Producer stops its operations, it is not relieved of its EPR obligations in respect of batteries already made available in the market prior to closure. The Producer must continue to discharge its EPR obligations — including collection, recycling, and refurbishment targets — in respect of all batteries placed in the market up to the date of cessation of operations, in accordance with the provisions of the Rules. This obligation introduced by Rule 4(6A) ensures that market exit does not extinguish pre-existing EPR liabilities.
Every Producer must furnish an annual return in Form 1(C) to the Central Pollution Control Board on or before 30th June of every year, containing information regarding the batteries manufactured, assembled, or imported in the preceding financial year. This return is in addition to the annual EPR return in Form 3 and provides the CPCB with production and import data for computing EPR targets and verifying compliance.
Producers may operate schemes such as deposit refund systems, buy-back programmes, or any other model to develop a separate waste stream for the collection of waste batteries, in order to fulfil their EPR obligations. The establishment of dedicated collection channels ensures that waste batteries are diverted from mixed or domestic waste streams and channelled to registered recyclers or refurbishers.
Every Producer must file annual returns in Form 3 by 30th June of the year following the relevant financial year, covering: (i) the quantity of waste batteries collected and sent for recycling or refurbishment in fulfilment of EPR obligations, with details of registered recyclers from whom EPR certificates have been procured; and (ii) in respect of pre-consumer waste batteries generated in the preceding financial year. The annual return must be filed with the CPCB and the concerned State Pollution Control Board (SPCB).
Every Producer is responsible for ensuring adherence to the prohibitions and labelling requirements prescribed in Schedule I to the Rules. Schedule I specifies restrictions on hazardous substances in batteries and mandates the affixation of labels containing prescribed information — including the crossed-out wheeled bin symbol indicating separate collection — on all batteries placed in the market.
Every Producer must ensure the safe handling of batteries and waste batteries throughout the supply chain such that no damage to human health or the environment occurs. This obligation applies to batteries at all stages — during manufacture, distribution, sale, and end-of-life collection — and requires Producers to implement appropriate handling, storage, and transport protocols.
Every Producer has an obligation to ensure the minimum use of domestically recycled materials in new batteries, in accordance with the targets specified in the table under Rule 4(14). These targets are intended to incentivise the development of a circular economy for battery materials by creating a mandatory demand for secondary raw materials recovered from domestic recycling operations. The applicable percentages and timelines are as set out in Rule 4(14).
No Producer shall deal with any entity — whether engaged in collection, refurbishment, or recycling — that does not hold the registration mandated under the Rules. All upstream and downstream transactions relating to waste battery management must be with duly registered entities. In addition, every Producer must take measures for sustainable production of batteries or battery packs, including in accordance with guidelines issued by the Central Pollution Control Board, covering resource efficiency, reduction of hazardous substances, and environmentally sound design.
Every consumer — being an end-user of batteries — must: (i) discard waste batteries separately from other waste streams, and in particular must not mix waste batteries with mixed waste or domestic waste streams; and (ii) ensure that waste batteries are disposed of in an environmentally friendly manner by handing them over to an entity engaged in the collection, refurbishment, or recycling of waste batteries. Consumers play a critical role in the EPR chain by ensuring that waste batteries are directed to registered entities rather than entering general waste streams, where they can cause significant environmental and health damage.
Every entity involved in the collection, segregation, and treatment of waste batteries must hand over the waste batteries collected by it exclusively to a registered refurbisher or recycler. No collected waste battery may be transferred to any unregistered entity or disposed of through any channel other than registered refurbishment or recycling.
Every entity involved in the collection, segregation, and treatment of waste batteries must: (i) ensure that its facility is established and operated in accordance with the standards or guidelines prescribed by the Central Pollution Control Board; and (ii) carry out all activities — including storage, segregation, and treatment of waste batteries — in accordance with CPCB guidelines. These obligations ensure that collection infrastructure meets minimum environmental and safety standards, preventing secondary pollution during handling of waste batteries.
All refurbishers must obtain a one-time registration with the State Pollution Control Board (SPCB) through the centralised online portal in Form 2(A) before commencing refurbishment activities. ‘Refurbishment’ means the repairing, re-conditioning, or re-purposing of used batteries for a second life. ‘Refurbisher’ means any entity engaged in such refurbishment. Registration is a precondition for generating EPR certificates and for transacting with Producers.
Every registered refurbisher must ensure: (i) all activities are carried out in accordance with guidelines prescribed by the CPCB; (ii) hazardous waste generated from any refurbishment activity is managed in compliance with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016; (iii) other waste generated during handling and refurbishment — including solid waste and plastic waste — is managed as per the Solid Waste Management Rules, 2016 and the Plastic Waste Management Rules, 2016; (iv) refurbishment processes and facilities comply with CPCB standards and guidelines; and (v) where a battery is incorporated in collected equipment, the waste battery is removed from the appliance prior to refurbishment.
Every registered refurbisher must furnish quarterly returns in Form 4 by the end of the month succeeding the end of each quarter. The quarterly return must contain: the quantity of used batteries collected or received from producers and other entities; the quantity refurbished; the quantity of hazardous waste and other waste (including solid waste and plastic waste) generated after refurbishment; and the manner of disposal of such waste in accordance with applicable rules.
On a quarterly basis, every registered refurbisher must make available on the portal developed by the Central Pollution Control Board the total weight of waste batteries processed by it during that quarter. This data is used by the CPCB for the generation of EPR certificates, which are then assigned to the refurbisher for transfer to Producers in discharge of their EPR obligations.
No refurbisher shall deal with any entity — whether for the receipt of waste batteries or for the supply of refurbished batteries — that does not hold registration mandated under the Rules. All transactions by refurbishers relating to waste battery management must be with entities duly registered under the Battery Waste Management Rules, 2022, ensuring the integrity of the EPR chain and preventing the diversion of waste batteries to unregistered or informal operators.
All recyclers must obtain a one-time registration with the State Pollution Control Board (SPCB) through the centralised online portal in Form 2(A) before commencing recycling activities. ‘Recycler’ means an entity engaged in the recycling of waste batteries. Registration is a mandatory precondition for generating EPR certificates and for conducting transactions with Producers under the EPR framework.
Every registered recycler must ensure: (i) all activities are carried out in accordance with guidelines prescribed by the CPCB; (ii) hazardous waste generated from any recycling activity is managed in compliance with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016; (iii) other waste generated during handling and recycling — including solid waste and plastic waste — is managed as per the Solid Waste Management Rules, 2016 and Plastic Waste Management Rules, 2016; (iv) recycling processes and facilities comply with CPCB standards and guidelines; and (v) where a battery is incorporated in collected equipment, the waste battery is removed from the appliance prior to recycling.
Every registered recycler must furnish quarterly returns in Form 4 by the end of the month succeeding the end of each quarter. The quarterly return must contain: the quantity of waste batteries collected or received from producers and other entities; the quantity recycled; compliance with the material-wise recovery percentage targets under Rule 10(4); the quantity of hazardous waste and other waste (including solid waste and plastic waste) generated after recycling; and the manner of disposal of such waste in accordance with applicable rules.
On a quarterly basis, every registered recycler must make available on the portal developed by the Central Pollution Control Board the total weight of waste batteries processed by it during that quarter. This data is used by the CPCB for the generation of EPR certificates, which are then assigned to the recycler for transfer to Producers in discharge of their EPR obligations.
No recycler shall deal with any entity — whether for the receipt of waste batteries or for the supply of recycled materials — that does not hold registration mandated under the Rules. All transactions by recyclers relating to waste battery management must be with entities duly registered under the Battery Waste Management Rules, 2022, ensuring the integrity of the EPR chain and preventing the diversion of waste batteries to unregistered operators.
Every entity involved in the refurbishment or recycling of waste batteries that is registered under the Rules must provide EPR certificates for waste batteries processed. These certificates are category-wise and must include the Goods and Services Tax (GST) data of the issuing entity. The CPCB provides for issuance of such certificates through the online Battery Waste EPR Portal. EPR certificates are issued for the type and quantity of batteries refurbished or recycled and can be transacted between registered entities and Producers for the purpose of meeting EPR obligations. The amount of waste batteries recycled or refurbished by any entity must not exceed the installed capacity of that entity, as certified at the time of registration.
EPR certificates are generated by the CPCB through the Battery Waste EPR Portal on the basis of quantities of waste batteries recycled or refurbished and are assigned to the registered recycler or refurbisher. Registered recyclers or refurbishers may sell the assigned EPR certificates to Producers in exchange for waste batteries or in discharge of the Producer’s EPR obligations. A surplus EPR certificate generated under recycling may be used for recycling obligations; however, a surplus under refurbishing cannot be applied towards recycling targets — the two categories are not interchangeable.
With effect from 1st July 2026, all registered recyclers are mandatorily required to upload GST e-invoices for the sale of recovered key battery metals and metal compounds on the Battery Waste EPR Portal, as a precondition for the successful generation of EPR certificates. EPR certificates generated on the basis of sales invoices other than GST e-invoices shall not be considered valid after 30th June 2026. Recyclers who do not currently have arrangements for GST e-invoicing must obtain GST e-invoicing registration immediately and comply with GST e-invoicing requirements. Any EPR certificates generated on the basis of non-GST e-invoices after the stipulated date shall be treated as false certificates and as non-compliance under the Battery Waste Management Rules, 2022, attracting Environmental Compensation and other consequences under Rule 11(12) and Rule 13(5) of the Rules.
Penalty & Consequences
Environmental Compensation — EC Regime 1: Non-Fulfilment of Metal-wise EPR Targets by Producers
Under EC Regime 1, Environmental Compensation is levied on Producers for non-fulfilment of metal-wise EPR targets specified in Schedule II. EC is calculated separately for two categories of batteries — (a) Lead Acid Batteries, and (b) Lithium-Ion and Other Batteries. For both categories, the EC calculation includes the cost of handling, collection, and transportation, as well as the cost of processing waste batteries. The detailed methodology for EC computation under Regime 1 is provided in Section 5.1 of the CPCB Guidelines for Imposition of Environmental Compensation under Battery Waste Management Rules, 2022.
Environmental Compensation — EC Regime 2: Non-Compliances such as Non-Filing of Returns, Labelling Violations, and Dealing with Unregistered Entities
Under EC Regime 2, Environmental Compensation is levied on any entity (Producer, Refurbisher, Recycler, or Collection/Segregation/Treatment entity) for non-compliances including: non-submission of annual returns (Producers) or quarterly returns (Refurbishers, Recyclers); non-compliance with labelling requirements; dealing with unregistered entities; and failure to upload GST e-invoices for EPR certificate generation. The EC under Regime 2 is calculated on a progressive escalating basis: for the 1st default — ₹20,000 (equivalent to the application fee at the middle slab); for the 2nd default — ₹40,000 (two times the 1st default); for the 3rd default — ₹80,000 (two times the 2nd default). The EC amount in this regime increases by ten percent every year.
Rule 11(12) — Suspension or Cancellation of Registration and Imposition of Environmental Compensation
The Central Pollution Control Board is empowered under Rule 11(12) to suspend or cancel the registration of a Producer, and/or impose Environmental Compensation, in the event of any violation of the Rules by a registered entity. Rule 13(4) additionally empowers the CPCB to levy Environmental Compensation on Producers with respect to non-fulfilment of EPR targets, responsibilities, and obligations set out in Schedule II.
Rule 13(5) — Environmental Compensation on Refurbishers, Recyclers, and Collection Entities by State Pollution Control Boards
Environmental Compensation may be levied by the respective State Pollution Control Board on entities involved in collection, segregation, treatment, refurbishment, or recycling of waste batteries, operating within their jurisdiction, with respect to non-fulfilment of responsibilities and obligations set out under the Rules. For non-fulfilment, such entities are liable under EC Regime 2. The competent authority — the CPCB — may also take further action including increases in EC amounts and cancellation of registration, as deemed necessary.
Section 15 of the Environment (Protection) Act, 1986 — Penalty for Contravention by Individuals
Where any person contravenes or fails to comply with any provision of the Environment (Protection) Act, 1986, or the rules, orders, or directions made thereunder — including the Battery Waste Management Rules, 2022 — for which no specific penalty is separately provided, that person shall be liable to a penalty of not less than ₹10,000 but which may extend to ₹15,00,000 for each such contravention. Where the contravention continues, an additional penalty of ₹10,000 for every day during which such contravention continues shall also be imposed.
Section 15A of the Environment (Protection) Act, 1986 — Penalty for Contravention by Companies
Where any company contravenes any provision of the Environment (Protection) Act, 1986 or the rules made thereunder — including the Battery Waste Management Rules, 2022 — the company shall be liable to a penalty of not less than ₹1,00,000 but which may extend to ₹15,00,000 for each such contravention. Where the company continues such contravention, an additional penalty of ₹1,00,000 for every day during which the contravention continues shall also be imposed.
Consequence — EPR Certificates Based on Non-GST E-Invoices Treated as False Certificates
With effect from 1st July 2026, any EPR certificate generated on the basis of a sales invoice other than a GST e-invoice shall be treated as a false certificate and as non-compliance under the Battery Waste Management Rules, 2022. Such false certificates attract Environmental Compensation under Rule 11(12) and Rule 13(5), as well as escalating consequences including cancellation of registration as determined by the competent authority.
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