Battery Waste EPR in India: Who Is Obligated and What It Takes

Most companies meet battery EPR the same way: a customer's vendor form, a due-diligence questionnaire or an auditor asks for a registration number that nobody in the building has. By then the obligation has usually been running for a year or two. The reason is simple - the rules do not ask whether you make batteries.

What the rules actually cover

You can be a producer without making a battery

Under the rules a producer is a manufacturer, an importer or a brand owner placing batteries on the market. The clause that catches people is the second one. If you import equipment, vehicles or devices with batteries inside them, those batteries were placed on the Indian market by you.

Dealers, refurbishers and recyclers carry their own duties, but they do not absorb the producer's obligation. Buying from an Indian distributor who imported the goods does not transfer it either - what matters is who placed the battery on the market.

The four battery types

What compliance involves in practice

• Register as a producer on the CPCB EPR portal, now reached through a consolidated single sign-on.
• Declare the quantity of batteries placed on the market, by type.
• Meet the collection and recycling obligation, which is computed against what you placed on the market in an earlier reference year and steps up over time under the Schedule.
• Discharge it with EPR certificates obtained from registered recyclers or refurbishers.
• File returns and keep records that reconcile against your import and production data.
• Label in the prescribed manner.

What changed recently

• February 2025. An amendment permitted digital labelling - a barcode or QR code carrying the EPR registration details on the battery, vehicle, packaging or brochure - and relaxed marking requirements for trace cadmium and lead.
• Recovery rates are stepping up. Minimum recovery obligations for EV and portable batteries rise towards ninety per cent by 2026-27, and for automotive and industrial batteries towards sixty per cent over the same horizon.
• Recycled content becomes mandatory. Minimum recycled material in new batteries begins in FY 2027-28 and increases in later years. That is a procurement and design decision rather than a filing one, which is why it needs to enter sourcing plans well before the deadline.
• Certificates now trade on a regulated platform, and portal access has been consolidated - if your last registration predates this, the login path you remember may no longer be the current one.

Where it goes wrong

• Assuming one EPR covers the others. Battery, e-waste and plastic packaging are three obligations. We have written on how e-waste EPR and plastic EPR differ; batteries are a third, separate track.
• Numbers that do not reconcile. Import documentation and portal returns are both discoverable. When they disagree, the return is the one that gets questioned.
• Certificates from the wrong source. A certificate is only useful if the counterparty is registered for that battery type and that period.
• No internal owner. The obligation sits between procurement, logistics and EHS, and in most organisations that means it sits with nobody.

A sensible order to do this in

• Establish whether you place batteries on the market at all - explicitly including batteries inside imported equipment.
• Classify what you place by battery type.
• Quantify the last three years from customs and production records, not from memory.
• Register, or correct a registration that was filed on the wrong basis.
• Build the reconciliation between source records and portal returns once, properly, so every future filing is a repeat rather than a project.
• Contract recyclers for certificates ahead of the deadline. Buying in the last month is how companies end up paying twice.

If you already hold e-waste EPR or plastic packaging registration, the battery track will feel familiar - but it is filed separately, reported separately and audited separately. It also sits alongside, not inside, your hazardous waste authorisation - the two answer different questions.