Battery EPR for importers and producers in India: registration, targets, marking and returns under the 2022 rules

Battery EPR makes the company that puts batteries on the Indian market responsible for collecting and recycling them. The law is the Battery Waste Management Rules, 2022, notified as S.O. 3984(E) dated 22 August 2022. They replaced the Batteries (Management and Handling) Rules, 2001 and came into force on publication^[1].

For an importer, six points cover most of it:

• Importing a gadget with a battery inside makes you a battery producer. The producer definition includes anyone who imports batteries or equipment containing batteries^[2].
• Register before you import. CPCB says importers of batteries and battery-containing equipment must register before importing, and that registrations under the 2001 rules are no longer valid^[7]. CPCB has asked Customs to verify registration certificates at clearance^[8].
• Registration is online in Form 1(A) and, since 2023, stays valid until cancelled or withdrawn^[2].
• You get collection and recycling targets by battery type and chemistry, met by buying EPR certificates from registered recyclers or refurbishers^[1].
• Every battery must be marked with your EPR registration number; the deadline was 31 March 2025^[2]. Since February 2025 a barcode or QR code can carry it^[4].
• Returns are yearly. The annual return for FY 2025-26 is due by 30 November 2026 after an extension^[5].

Battery EPR sits alongside e-waste EPR, not inside it. Waste batteries are excluded from the E-Waste Rules, so the lithium-ion cell in a power bank or pair of earphones is a separate obligation from the device's own e-waste EPR^[9].

2026-27 is the first target year for two- and three-wheeler EV batteries, other portable batteries move to a 60% target, and recyclers' material recovery targets reach their top rate. For consumer-electronics importers, the main news is the extended return deadline: the FY 2025-26 annual return is due by 30 November 2026^[5].

The consumer-electronics target itself does not step up: it has been 70% of the placement five years earlier since 2024-25 and stays there until 2031-32^[10]. What changes is the reference year, so a business that grew fast five years ago faces a bigger target now. On the portal side, CPCB says transfer of EPR certificates has resumed^[11] and all EPR portals are reached through single sign-on at epr.cpcb.gov.in^[11]. See new rules for 2026 for other import rule changes.

A producer is an entity that^[2]:

1. manufactures and sells batteries, including batteries in equipment, under its own brand;
2. sells under its own brand batteries made by other manufacturers or suppliers; or
3. imports batteries, or equipment containing batteries.

The 2023 amendment added those who manufacture or assemble batteries for sale to an unbranded producer^[2].

The rules cover every kind of battery, whatever its chemistry, shape, volume, weight, material or use^[1]. The only exclusions are batteries in equipment for essential security interests or military purposes, and equipment designed to be sent into space^[1]. There is no exclusion for small businesses or small batteries.

When does an importer have EPR obligations?

CPCB's FAQ sets out when an importer carries EPR obligations. It does when it sells under its own brand, supplies others who sell under the importer's brand, supplies bulk consumers directly, or sells under the imported brand name. It does not when its buyers resell under their own brand^[7]. Registration is a separate question: CPCB says importers must register before importing^[7].

Because the definition says so in terms. Rule 3 counts as a producer anyone who imports "equipment containing batteries", not only loose batteries^[2]. On that wording, importing power banks, TWS earphones, phones or laptops makes you a producer^[2].

CPCB's FAQ adds one point that sometimes confuses importers. An equipment maker that uses batteries bought from another registered producer has no EPR obligation for those batteries. That applies to domestic sourcing. It does not help importers of equipment, who are producers in their own right under rule 3(1)(u)(iii)^[7].

It also does not matter that the device is covered by e-waste EPR. Waste batteries are excluded from the E-Waste Rules and governed only by the battery rules^[9]. One imported phone can therefore trigger e-waste EPR for the handset, battery EPR for the cell inside, and plastic EPR for the packaging^[9].

Any product with a battery inside does, because the producer definition covers importers of equipment containing batteries^[2]. The rules apply to every battery type regardless of chemistry, shape or use^[1]. Most consumer gadgets carry sealed batteries under 5 kg, which the rules treat as portable batteries^[1].

The table lists common imports with built-in batteries and the other approvals to check for each. Battery EPR is one line of the compliance list, never the whole of it. Use the approval checker to see the full list for your product.

The rules define four types of battery, and your targets, certificates and EC are all worked out by type^[1]:

• Portable: sealed, under 5 kg, and not an industrial, EV or automotive battery.
• Automotive: used for starter, lighting or ignition.
• Electric vehicle (EV): traction batteries for hybrid or electric road vehicles.
• Industrial: everything else, including energy storage system batteries.

Within each type, targets apply separately to each chemistry, such as lead acid, lithium-ion, nickel-cadmium or zinc-based^[1]. A lithium-ion obligation cannot be met with lead-acid certificates, and certificates can be used only within the same battery category^[1].

Most batteries inside consumer electronics are sealed and weigh well under 5 kg, so they will usually fall in the portable type. Check each model against the definition rather than assuming.

Every producer must get registration from CPCB through the online centralised portal in Form 1(A). The registration certificate is issued in Form 1(B)^[2]. Register before you import^[7].

Our CPCB EPR portal guide shows the screens, and the EPR registration checklist lists what to keep ready.

CPCB's battery producer SOP sets the application fee by annual turnover. The renewal fee equals the registration fee, and fees are paid online, exclusive of transaction charges^[3].

Two notes about the SOP. Its cover is dated February 2022, before the rules were notified, which is probably a typo. It also says registration lasts five years, but the 2023 amendment replaced that with validity until cancellation^[3]. We have not found a later fee schedule, so the slabs below are the latest official figures we hold.

The registration fee can be small next to the cost of EPR certificates.

For the full picture, including certificate purchases and consultant charges, see our EPR registration cost guide and the 2026 compliance fee table.

Since the 2023 amendment, the registration certificate is valid until it is cancelled or withdrawn^[2]. The original 2022 rules gave five years with renewal 60 days before expiry; the amendment replaced this^[2].

CPCB has to decide within two weeks of a complete application, and the registration is deemed granted after that unless refused^[2].

Registrations under the old 2001 rules are no longer valid. If your business registered under those rules, you need a fresh registration under the 2022 rules^[7].

Targets are collection targets plus 100% recycling or refurbishment of what is collected^[1]. Each is a percentage of the quantity you placed on the market in a reference year, and applies separately to each chemistry^[1].

Rechargeable portable batteries in consumer electronics (phones, laptops, earphones, power banks): 50% of the 2017-18 quantity for FY 2022-23, 60% of 2018-19 for 2023-24, and 70% of the year five years earlier from 2024-25 onwards, within a 10-year compliance cycle^[1]. For FY 2026-27 that is 70% of what you placed on the market in 2021-22^[1]. The 2024 amendment changed the carry-forward wording to "up to 60% of the remaining quantity placed in the market during the applicable compliance cycle"^[1].

Other portable batteries: 50% of the 2022-23 quantity in 2025-26, 60% of 2023-24 in 2026-27, and 70% from 2027-28 onwards^[1].

Industrial batteries: 40% in 2022-23, 50% in 2023-24, 60% in 2024-25 and 70% from 2025-26 onwards, measured against a reference year^[1]. We have not cleanly verified the reference years for industrial batteries, so check Schedule II before filing^[1].

EV batteries of three-wheelers (including e-rickshaws, L5, L5-M, L5-N and e-carts): 70% of 2021-22 placement for 2026-27, moving forward one reference year each year, in a seven-year cycle^[2].

We do not hold verified target figures for automotive batteries or for other EV batteries, so they are not listed here.

Our battery EPR targets guide sets out every category's table year by year.

The figures below are invented to show the method; they are not official numbers.

Suppose you import Bluetooth earphones. Each pair contains a small rechargeable lithium-ion cell, which makes you a battery producer^[2]. The cells are portable rechargeable batteries used in consumer electronics, so for 2026-27 your target is 70% of the weight you placed on the market in 2021-22^[1].

If you imported 1,500 kg of these cells (inside earphones) in 2021-22, your 2026-27 collection target is 1,050 kg of lithium-ion portable batteries, and all of it must be recycled or refurbished^[1]. You meet it with lithium-ion portable-battery EPR certificates^[1], and you may buy up to your current-year liability plus leftover liability plus 10%^[1].

If you started importing only in 2023-24, you have no 2021-22 placement for this target. Keep year-by-year records from the first shipment, because each year's imports become a future reference year.

Yes. Producers must use a minimum share of domestically recycled material, as a percentage of the battery's dry weight. The current table, which replaced the 2022 table, is below^[12]. Importers meet it by having recycled material used by others or exported^[12].

A MoEFCC office memorandum of 17 May 2024, published by CPCB on 28 May 2024, clarified that domestically recycled material means any recycled material recovered in India from any waste product (for example lithium, cobalt, aluminium, graphite, paper, plastic or carbon), not only from waste batteries^[13].

Recyclers have their own material recovery targets: for portable and EV batteries 70%, 80% and 90% for 2024-25, 2025-26 and 2026-27 onwards, and for automotive and industrial batteries 55%, 60% and 60%^[1].

Targets are met through EPR certificates generated by registered recyclers or refurbishers^[1]. The main rules:

• Validity. Battery EPR certificates are valid for seven years for meeting producer obligations^[1].
• Purchase cap. You may buy up to your current-year liability, plus leftover earlier liability, plus 10% of the current-year liability^[1].
• Same category only. Certificates are usable only within the same battery category^[1].
• No certificates from imported waste. Since 2023, no certificate may be generated for recycling or refurbishing waste batteries imported under the Hazardous Waste Rules^[2].
• Price band. Under rule 10(17) as substituted in 2024, CPCB fixes the highest and lowest certificate prices at 100% and 30% of the environmental compensation for not meeting EPR, and portal trades must fall within that band^[14].

Producers are also responsible for pre-consumer waste batteries from manufacturing, assembly or import, which they report in Form 3^[2].

CPCB's Guidelines for Environmental Compensation under the battery rules are dated August 2024. They received MoEFCC concurrence on 9 September 2024 and were notified by CPCB notice on 10 September 2024^[6]. Unlike the e-waste guidelines, their approval date is stated in the official record.

Lead-acid batteries: EC is Rs 18 per kg of lead, built from handling, collection and transport at Rs 3,000 per tonne plus processing at Rs 15,000 per tonne. Lead EPR credits therefore trade between Rs 5.4 and Rs 18 per kg^[6].

Lithium-ion and other batteries: EC is set per kg of recovered metal, with the 30-100% credit band shown below^[6]. EC for cadmium and zinc is to be kept the same as for lithium^[6].

EPR registration number. The 2023 amendment requires producers to mark all batteries and battery packs with their EPR registration number on or before 31 March 2025 (Schedule I, paragraph 2(ia))^[2]. That deadline has passed, so batteries you place on the market now must carry it, or use one of the options below.

Imported equipment. A MoEFCC office memorandum of 17 May 2024 clarified that for imported batteries, marking the EPR registration number on the equipment containing the battery, or on the equipment's packaging, satisfies clause (ia)^[13]. For a power bank or phone, that means the number can go on the device or its box rather than on the cell.

Barcode or QR option (S.O. 958(E)). The 2025 amendment, S.O. 958(E) of 24 February 2025, lets producers meet the requirement, after informing CPCB, by printing a barcode or QR code that carries the EPR registration number. It can go on the battery, the equipment, the battery or equipment packaging, or bulk packaging. Producers can also print the number in the product information brochure^[4]. Packaging covered by rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2011 is exempt from clause (ia)^[4]. CPCB publishes, and updates every quarter, a list of producers that have chosen this option^[4].

Crossed-out wheeled bin. Every battery or battery pack must carry the crossed-out wheeled bin symbol. It must cover at least 3% of the largest side (1.5% for cylindrical cells), up to 5 cm x 5 cm. If that would make it smaller than 0.5 cm x 0.5 cm, a symbol of at least 1 cm x 1 cm goes on the packaging instead^[1]. Labels must be visible, legible and indelible^[1].

Heavy metals. Batteries containing mercury, cadmium or lead must be marked "Hg", "Cd" or "Pb" beneath the bin symbol, covering at least a quarter of its size. Since 2025 "Cd" or "Pb" is not needed where cadmium is no more than 0.002% (20 ppm) or lead no more than 0.004% (40 ppm) by weight^[4].

Content limits. Portable batteries may contain no more than 0.002% (20 ppm) cadmium by weight, and batteries with up to 0.0005% (5 ppm) mercury could be placed on the market only until 2025^[2].

Battery producers file two yearly forms.

Form 1(C). By 30 June each year, you file the quantity and weight of batteries you manufactured, assembled or imported in the previous financial year (rule 4(7) as amended in 2023)^[2].

Form 3 annual return. By 30 June of the next financial year, you file an annual return with CPCB and the State Pollution Control Board on waste batteries collected and recycled or refurbished. It includes details of the recyclers whose certificates you bought^[1]. Pre-consumer waste batteries are reported here too^[2].

Extensions. Rule 14(6), inserted in 2023, lets the Central Government relax return deadlines by order by up to nine months^[2]. Deadlines have been extended for each of the last three years:

See our EPR annual returns guide for the filing steps, and diary the dates in the compliance calendar.

EC for missing targets. Shortfalls draw environmental compensation at the rates in CPCB's EC guidelines, such as Rs 2,400 per kg of lithium^[6] or Rs 18 per kg of lead^[6]. If you make up the shortfall within three years, EC is refunded at 75% within one year, 60% within two years and 40% within three years; after three years it is forfeited^[1].

EC for other violations. For non-compliance other than an EPR shortfall, such as not filing annual returns, not following labelling rules or dealing with unregistered entities, EC is Rs 20,000 for a first default, Rs 40,000 for a second and Rs 80,000 for a third, rising 10% every year^[6].

Late payment. Late payment of EC carries interest of 12% a year if paid within one month of the due date, and 24% a year if paid within one to three months. After three months the unit can be closed, trade documents seized and action taken under section 15(1) of the Environment (Protection) Act^[6].

The battery rules have been amended several times. The table lists the changes we hold verified facts for. A further amendment, S.O. 5210(E) dated 3 December 2024, is listed in the 2025 amendment's note, but we have not retrieved its content^[4].

CPCB runs a helpline and daily video-conference sessions, and many consultants handle the filing for a fee. Start with CPCB's own channels; they are free.

• CPCB. The battery portal helpline is 011-43102350 and [email protected], 9:30 am to 6 pm on weekdays^[11]. CPCB also holds video-conference sessions from 4 pm to 5 pm, Monday to Saturday, on registration and certificate issues^[11].
• Consultants. One consultant advertises battery EPR registration for importers from Rs 9,999 plus the government fee, as reported on its website^[17]. Compare offers in our EPR consultants guide, and see how a producer responsibility organisation differs from a consultant.
• Small importers. Our guide to EPR for small importers and the guides for Amazon sellers and Flipkart sellers cover the marketplace angle. If you buy from China, read importing power banks from China.
• Costs. The compliance cost estimator adds battery EPR to BIS and WPC costs.
• A second opinion. Ask for a free compliance check.

A first-time importer of power banks. You are a battery producer because you import equipment containing batteries^[2]. Register in Form 1(A) before the first shipment^[2][7], pay the turnover-based fee^[3], and put your EPR number, or a barcode or QR code carrying it, on the device or its packaging^[13][4]. Schedule I of the e-waste rules does not name power banks, so ask CPCB about e-waste coverage separately^[9].

A marketplace seller importing several gadget lines. Every line with a battery inside adds to your battery obligation, worked out by type and chemistry^[1]. File Form 1(C) by 30 June with last year's imports^[2]. Keep the weights by chemistry, because each year's imports become a future reference year for targets.

A foreign brand selling through an Indian importer. CPCB's FAQ puts EPR obligations on the importer when it sells under the imported brand name^[7]. Agree who registers, who marks the EPR number and who files Form 3 before goods ship.