Battery EPR targets by battery type: the year-by-year schedule, compliance cycles, certificates and shortfall costs

Battery EPR targets are collection targets. Each year you must collect a percentage, by weight, of the batteries you placed on the market in a named earlier year, and 100% of what you collect must be recycled or refurbished^[1]. You meet them by buying EPR certificates from registered recyclers or refurbishers.

Three features make battery targets different from e-waste:

• By type and chemistry. Targets apply separately to each chemistry (lead acid, Li-ion, Ni-Cd, zinc-based) within each battery type: portable, automotive, industrial and EV^[3]. The four types are defined in the rules^[3].
• Compliance cycles. On top of the yearly target, by the end of each cycle (ten years for portable, seven for automotive, industrial and two- and three-wheeler EV, fourteen for four-wheeler EV) you must have collected and recycled 100% of what you placed during that cycle^[1].
• Importers of equipment count. Importing equipment with a battery inside (phones, power banks, earphones, laptops) makes you a battery producer^[2].

Registration and who must register are covered on EPR battery.

The battery type decides which row of the schedule applies. The rules define four types: portable (sealed, under 5 kg, not industrial, EV or automotive), automotive (starting, lighting or ignition), EV (traction for hybrid or electric road vehicles) and industrial (everything else, including energy storage batteries)^[3]. Here is how common imports usually fall. Confirm against the definitions for your exact product.

Most electronics importers meet the battery rules through the cells inside their products, not through loose batteries. The table maps common imports to the battery type in the rules^[3] and notes the separate e-waste obligation, because waste batteries are carved out of the e-waste rules^[6].

Importers of batteries and of equipment containing batteries are producers and must register with CPCB before importing^[8]. CPCB's FAQ says an importer has EPR obligations when it sells under its own brand, supplies others who sell under its brand, supplies bulk consumers directly, or sells under the imported brand name; it does not have them when buyers resell under their own brand^[8]. Customs has been asked to check CPCB registration on battery consignments^[9], so register before the first shipment even if your first target is small.

Your own batteries count too. Since 2023 producers are responsible for pre-consumer waste batteries and have EPR for batteries put to self-use^[2].

Register on CPCB's battery portal first: importers of batteries and battery-containing equipment must register before importing^[8], and Customs has been asked to check the CPCB certificate at clearance^[9]. The application is Form 1(A) on the centralised portal, and the certificate in Form 1(B) is now valid until cancelled^[2]. The portal is the 'EPR Portal for Battery Waste Management' at eprbattery.cpcb.gov.in^[10]; our CPCB EPR portal guide walks through it.

These are the Schedule II targets as amended. Each cell shows the collection target and the reference year of placement it is measured against.

• Rechargeable portable batteries in consumer electronics:^[1][3]
• Other portable batteries:^[1][3]
• Automotive (starting, lighting, ignition) batteries:^[1]
• Industrial batteries, including energy storage:^[1][3]
• EV two-wheeler batteries:^[1]
• EV three-wheeler batteries (e-rickshaws, L5, L5-M, L5-N, e-carts), as replaced in 2023:^[2]
• EV four-wheeler batteries start in 2029-30 at 70% of 2021-22 placement, in fourteen-year cycles; the 2023 amendment changed one 80% year to 70%^[1].

The reference-year gap reflects how long each battery type lasts. A phone battery sold in 2021-22 is expected back around 2026-27; an industrial battery three years after sale.

CPCB shows the target on the portal from the data you file. Each year you report what you imported in the previous year in Form 1(C) by 30 June^[2]. New producers get targets based on the average battery life shown in the tables^[1], so check the target CPCB generates rather than assuming zero because you did not sell in the reference year.

Illustrative figures only.

Facts assumed. An importer of power banks has sold since 2020. Li-ion cells inside its power banks placed on the market in 2021-22 weighed 4,000 kg.

Type. Power banks contain sealed batteries under 5 kg used in consumer electronics, so they are portable batteries^[3], rechargeable, consumer electronics.

2026-27 target. 70% of 2021-22 placement: 0.70 x 4,000 kg = 2,800 kg collection, all of it to be recycled or refurbished^[1].

Certificates. The importer must buy Li-ion portable-battery certificates for 2,800 kg; certificates from another battery category do not count, and purchases are capped at current liability plus leftovers plus 10%^[3].

Cycle check. Its first ten-year cycle runs 2022-23 to 2031-32; by 2031-32 it must have collected all batteries placed during the cycle, carrying forward at most 60% of any remainder^[12].

The battery obligation is separate from the power bank's e-waste obligation^[6].

Illustrative figures only, and our arithmetic.

Facts assumed. An importer sells UPS systems with sealed lead-acid batteries. Batteries placed on the market in 2023-24 weighed 20,000 kg.

Type. Energy storage batteries are industrial batteries under the rules^[3], so the industrial row applies.

2026-27 target. 70% of 2023-24 placement^[1]: 0.70 x 20,000 kg = 14,000 kg to collect, all of it recycled.

Certificate budget. Lead certificates trade between Rs 5.4 and Rs 18 per kg of lead^[13]. Treating the whole 14,000 kg as lead (a simplification; certificates are counted by lead recovered), the certificate bill would fall between Rs 75,600 and Rs 2,52,000.

If it buys only 10,000 kg. The 4,000 kg shortfall at the lead EC of Rs 18 per kg is Rs 72,000 of environmental compensation^[13]. Pay late and interest runs at 12% a year in the first month and 24% within three months^[13]. If it then buys the missing certificates within a year, 75% of the EC (Rs 54,000) comes back; within two years 60%; within three 40%^[3].

Lesson. At the ceiling price, buying certificates costs the same per kg as paying EC, but EC does not cancel the obligation and is only partly refunded. Buying on time is always cheaper.

You still get a target. Schedule II says a new producer's targets apply by average battery life as shown in the tables^[1], and CPCB computes the target from what you file. Each year you report the previous year's imports in Form 1(C) by 30 June^[2].

Practical steps for a first-year importer:

1. Register before the first bill of entry^[8].
2. Record battery weight per model from the supplier's datasheet, not the gross product weight. Weigh a sample if the datasheet is silent.
3. Keep batteries for self-use and pre-consumer waste (damaged stock, rejects) in the records, because both count^[2].
4. File Form 1(C) and check the target the portal shows. If it looks wrong, raise it with CPCB before the annual return.

Small importers worried about cost can read EPR for small importers; the EPR registration checklist lists the documents.

CPCB's battery EC guidelines received MoEFCC concurrence on 9 September 2024 and were notified the next day^[13]. Because Li-ion EC is per kg of recovered metal, the money value of a kg of collection target depends on the metal content of the batteries recycled, which is why prices vary.

Yes. Labelling breaches are a separate violation from missed targets and carry their own EC^[13]. The key marks are:

• EPR registration number on all batteries and packs from 31 March 2025^[2]. For imported batteries inside equipment, putting it on the equipment or its packaging is enough^[14], and since February 2025 a QR code or barcode carrying the number is allowed after informing CPCB^[15].
• Crossed-out wheeled bin of at least 3% of the largest side (1.5% for cylindrical cells), up to 5 cm x 5 cm^[3].
• Hg, Cd or Pb under the bin symbol where those metals exceed the thresholds^[15].

Run your artwork through the label checker and the product label checklist.

Yes, from 2027-28. Batteries must contain a minimum share of domestically recycled material by dry weight: portable and EV batteries 5% in 2027-28 rising to 20% from 2030-31; automotive and industrial batteries 35% in 2027-28 rising to 40% from 2029-30^[16]. MoEFCC has clarified that this can be any domestically recycled material, not only material from waste batteries^[14].

Recyclers also have recovery targets: for portable and EV batteries 70%, 80% and 90% of dry weight for 2024-25, 2025-26 and 2026-27 onwards^[3].

• EC per shortfall. Calculated using CPCB's EC rates above^[13].
• Refund if you catch up. If the shortfall is met within three years, EC is refunded at 75% within one year, 60% within two and 40% within three; after that it is forfeited^[3].
• Late payment. Interest of 12% a year within one month and 24% within one to three months; after three months the unit can be closed and trade documents seized^[13].
• Other violations. Missing returns or labelling breaches attract Rs 20,000, Rs 40,000 and Rs 80,000 for first, second and third defaults^[13].

Annual returns in Form 3 are normally due on 30 June^[3]; for FY 2025-26 the deadline was extended to 30 November 2026^[5]. See EPR annual returns.

Put these into your compliance calendar. The government can relax return deadlines by up to nine months by order^[2], and has done so every year so far.

1. Reporting gross product weight. Targets run on battery weight per type and chemistry^[3]. Reporting the whole power bank's weight inflates your target; reporting nothing for built-in cells understates it.
2. Buying the wrong certificates. Certificates only work within the same battery category, and purchases are capped at liability plus leftovers plus 10%^[3]. A Li-ion portable target cannot be met with lead-acid credits.
3. Assuming the brand owner abroad is responsible. In India, the importer is the producer^[2], unless your buyers resell under their own brand^[8]. Put the split in writing with distributors.
4. Thinking a PRO takes the liability. You may authorise another entity to collect or recycle, but the obligation stays with you^[19]. Check what any EPR consultant or producer responsibility organisation actually files in your name.
5. Ignoring the cycle-end rule. The yearly target is not the whole story: by the end of the cycle, 100% of placement must have been collected, with at most 60% of any remainder carried forward^[12].

The full chain is listed in the 2025 notification^[20].

• 2026-27 is the first year for EV batteries. Two-wheeler targets start at 70% of 2022-23 placement^[1] and three-wheeler targets at 70% of 2021-22^[2].
• Other portable batteries step up from 50% in 2025-26 to 60% in 2026-27^[1].
• Return deadline moved again, to 30 November 2026 for FY 2025-26^[5].
• Heavy-metal marking relaxed in 2025 where cadmium or lead is below the thresholds^[15], and the QR option for EPR numbers arrived in February 2025^[15].

For how battery targets compare with the device-level obligation, see e-waste targets; for packaging, plastic targets. To price all three for one product, use the compliance cost estimator, see EPR registration costs, or ask us for a free compliance check.