Batteries are now regulated far more broadly than before. The Battery Waste Management Rules, 2022, notified in August 2022, replaced the old lead-acid battery rules and cover all batteries, whatever their chemistry, size or use: portable batteries in phones and laptops, automotive batteries, industrial batteries and electric vehicle batteries. A producer, which includes a manufacturer, a brand owner and an importer, and also a company that sells equipment containing batteries, must register on the CPCB portal and meet targets for collection and recycling of waste batteries, using EPR certificates from registered recyclers and refurbishers.
The rules also set targets for the recovery of materials in recycling and, from later years, for the use of a minimum share of domestically recycled materials in new batteries. With the growth of electric vehicles and lithium-ion storage, these obligations are becoming significant costs. This page explains who must register, how the obligations work, special issues for EV companies and importers, and how to deal with notices.
हिंदी में सारांश
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Is this your situation?
- You manufacture or assemble batteries or battery packs
- You import lithium-ion cells, packs or devices with batteries
- You make or sell electric two-wheelers, three-wheelers or cars
- You sell inverters, UPS or solar storage systems
- You recycle or refurbish batteries
- You received a CPCB notice on battery EPR
- You are unsure whether batteries inside your products count
Battery EPR at a glance
All batteries covered
Portable, automotive, industrial and EV batteries, of any chemistry.
Who is a producer
Manufacturers, brand owners, importers, and sellers of equipment containing batteries.
Registration
On the CPCB battery EPR portal, before placing batteries on the market.
Collection and recycling targets
Set by battery type and year, met through certificates from registered recyclers and refurbishers.
Domestic recycled content
Minimum use of domestically recycled materials in new batteries, phased in from later years.
Compensation
Environmental compensation for unmet targets and for selling without registration.
Batteries inside products
The rules apply not only to batteries sold on their own but also to batteries placed on the market inside equipment, such as phones, laptops, power banks, toys, tools, inverters, solar storage systems and vehicles. A company selling equipment with batteries may therefore be a battery producer even if it never thinks of itself as one. Where batteries are bought from a domestic battery producer that has already accounted for them, the rules and the portal guidance determine who carries the obligation; the answer depends on how the battery reached the market and how it is reported.
For importers of finished products with batteries, the obligation usually sits with the importer, because the battery enters the Indian market through the import. Check the portal guidance on reporting embedded batteries, so that batteries are neither missed nor counted twice.
Electric vehicles and lithium-ion
EV and energy storage companies face the largest new obligations. EV batteries have long lives, so collection targets are linked to batteries placed on the market years earlier, but the quantities are large and growing. The rules allow refurbishment and second-life use, for example of EV batteries in stationary storage, but these must be handled through registered entities and reported correctly. The phased requirement for domestically recycled content in new batteries means manufacturers will need reliable recycled material supply in coming years.
EV makers should build battery EPR into their supply contracts, warranty and buy-back programmes, and dealer arrangements now, rather than treating it as a later compliance task. Clear records of each battery's chemistry, weight and serial data will make the obligation easier to manage.
How to register and comply
Map battery flows
List batteries sold alone and inside products, by type, chemistry and weight.
Register on the CPCB portal
Submit company details, battery data and the EPR plan, with the fee.
Check the obligation
Confirm the collection and recycling targets for each battery type.
Contract with recyclers and refurbishers
Buy certificates from registered entities after checking registration and capacity.
File returns
Submit returns on the portal by the due dates.
Plan for recycled content
Prepare supply arrangements for the domestic recycled material targets.
Lead-acid batteries
Lead-acid batteries, used in vehicles and inverters, have long had a take-back system through dealers. Under the 2022 rules, these batteries are covered by the same EPR framework, and producers must meet targets through certificates from registered recyclers. Informal recycling of lead-acid batteries, which causes serious lead pollution, has been a target of enforcement by boards and the NGT. Dealers and producers should ensure used batteries go only to registered recyclers, and keep records to show this.
Time and typical cost
Our fees are agreed in writing at the start, stage by stage. They are not linked to the outcome.
| Stage | Usual time | What it involves |
|---|---|---|
| Battery mapping | 1 to 3 weeks | Internal data; our fee |
| Portal registration | Several weeks after a complete application | CPCB fee |
| Certificate purchase | Through the year | Certificate price |
| Returns | As notified | Internal effort; our review |
| Reply to a notice | Within the time stated | Our fee |
Battery types and typical producers
| Battery type | Typical producers |
|---|---|
| Portable | Phone, laptop, power bank, toy and tool brands and importers |
| Automotive | Vehicle makers, battery brands, importers |
| Industrial | Inverter, UPS, solar storage and telecom suppliers |
| Electric vehicle | EV makers, battery pack makers, importers of cells and packs |
Documents usually needed
Company
- Incorporation, GST, PAN, IEC for importers
- Authorised person's details
Batteries
- Battery types, chemistry, weights and quantities
- Sales and import data
- Embedded battery details for equipment
Compliance
- Recycler and refurbisher contracts
- Certificate records and returns
Laws that apply
Registration, targets, certificates, recycled content and compensation.
Changes to targets, reporting and procedure.
The parent law under which the rules are made.
Relevant to storage and transport of waste batteries in some cases.
How we work
We are a litigation and advisory practice led by Advocate BK Singh, with offices in Dwarka (New Delhi) and Vaishali (Ghaziabad). This is what you can expect:
- Battery flows mapped: including embedded batteries.
- EV-specific planning: second life, buy-back and recycled content.
- Recycler due diligence: before you buy certificates.
- Notices answered: with reconciled data.
- Written fee terms: agreed stage by stage, never linked to the outcome.
Mistakes we see with battery EPR
- Forgetting batteries inside products
- Importing cells or packs before registration
- Sending used batteries to informal recyclers
- Ignoring the recycled content targets in supply planning
- Counting the same battery twice across group companies
An electric scooter maker
Here's a made-up example. A Ghaziabad electric scooter company imported lithium-ion cells and assembled packs in-house. It had registered for plastic EPR but not for batteries.
We mapped its imports and sales, registered it as a battery producer, and set up an arrangement with a registered recycler and a refurbisher for second-life use. Its warranty replacement process was revised so that removed packs went only to registered entities.
An inverter brand
Here's a second made-up example. An inverter brand received a notice for not meeting its lead-acid battery target. Its dealers had been selling used batteries to scrap dealers.
We helped the brand set up a dealer take-back system with a registered recycler, bought certificates to cover the shortfall, and replied to the notice with the corrective plan. The board accepted the plan and monitored the next year's compliance.
How the collection target works
Collection targets under the Battery Waste Management Rules are linked to the quantity of batteries the producer placed on the market in earlier years, with the reference period depending on the type of battery and its expected life. Portable batteries, which have short lives, are linked to more recent years; automotive, industrial and EV batteries to longer periods. The targets rise in steps over the years set out in the rules.
In addition, recycling targets require a minimum recovery of materials from waste batteries, and the rules set a phased requirement for the use of domestically recycled materials in new batteries. Producers should not plan only for the current year; the long reference periods mean today's sales create obligations well into the future.
Reporting accuracy and audits
The CPCB relies on data reported by producers and recyclers. Weights matter more than numbers of units, so a producer reporting units without accurate weights, or using wrong battery categories, will have a wrong obligation. Group companies that import and sell batteries through different entities should agree which entity reports which batteries, to avoid double counting or gaps. Recyclers' certificates depend on their own records of batteries received and processed, and the CPCB has power to verify and audit these.
Keeping a clean data trail, from purchase or import records through sales to the certificates bought, is the best defence against a compensation notice. When a notice does come, a reconciliation showing exactly how the reported figures were reached often resolves disputes.
Safety in storage and transport
Waste lithium-ion batteries can catch fire if damaged or stored badly. Producers, dealers and service centres that collect used batteries should store them in safe conditions, with separation from flammable materials and protection against short circuits, and transport them through vehicles and packaging suitable for the risk. Fires at storage sites have led to notices from boards and fire authorities. Building safe handling into the take-back process protects people and property, and avoids an enforcement problem on top of the EPR obligation.
Frequently Asked Questions
Which batteries are covered?
All batteries: portable, automotive, industrial and EV, of any chemistry.
Who is a producer?
Manufacturers, brand owners, importers, and sellers of equipment containing batteries.
Do batteries inside products count?
Yes, batteries placed on the market inside equipment are covered.
Where do I register?
On the CPCB battery EPR portal.
How are targets met?
Through certificates from registered recyclers and refurbishers.
What is the recycled content requirement?
A phased minimum share of domestically recycled materials in new batteries.
Are second-life EV batteries allowed?
Yes, through registered refurbishers and proper reporting.
What about lead-acid batteries?
They are covered, and must go only to registered recyclers.
What if I miss my target?
Environmental compensation is levied, and the obligation continues.
Do importers of devices with batteries have obligations?
Usually yes, as the battery enters the market through the import.
Can dealers sell used batteries to scrap dealers?
No, used batteries should go to registered entities.
Can I challenge a CPCB order on battery EPR?
Yes, through representation and legal proceedings where appropriate.
Battery EPR to Set Up?
Send us your battery data and any notice. We will check your registration and obligations.
This page gives general information about environmental law as it stood when it was last reviewed. It is not legal advice on your case and does not promise any result. Environmental rules, EPR targets, GRAP measures and board procedures change often, so check the current position for your unit or project before acting.
Need help with Battery EPR for Makers, Importers and EV Companies?
Send us the notice, the order or a few photos. We'll tell you where you stand, which authority or NGT bench deals with it and when the next step is due, in plain words.
