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# Battery Waste EPR Compliance in India

Battery Waste Management Rules 2022 impose collection and recycling targets on everyone who places batteries or battery-containing products on the Indian market. The targets are chemistry-specific, rise steeply each year, and penalties for shortfall are financial. Companies selling Li-ion products must start building recycler relationships early — registered recycling capacity is still growing.

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At a glance

Battery chemistries covered

4

Registration steps

6

FAQ items

3

## Battery chemistry targets

### Lead-Acid Batteries

**Collection:** 90% by weight from FY 2024-25

**Recycling:** 90% of collected weight recycled

High-value lead recovery drives strong existing collection. Producers benefit from existing informal sector recycling networks but must formalize through registered recyclers.

### Lithium-Ion Batteries

**Collection:** 70% by weight from FY 2024-25 (rising to 90%+)

**Recycling:** 70% of collected weight by FY 2024-25

Li-ion recycling infrastructure in India is developing. Producers with large EV and consumer electronics battery portfolios face the most complex compliance.

### Nickel-Cadmium (NiCd) Batteries

**Collection:** 90% by weight

**Recycling:** 90% of collected weight

NiCd phasing out globally but still in some industrial and emergency equipment. Cadmium content makes disposal obligations particularly strict.

### Other Battery Chemistries

**Collection:** As specified in Schedule II of Battery Waste Rules 2022

**Recycling:** Per schedule targets

Alkaline, NiMH, primary lithium, and other chemistries each have schedule-specific targets. Verify your chemistry in Schedule II.

## Registration and compliance process

01

### Determine your EPR producer category

Under Battery Waste Management Rules 2022, producers include manufacturers, importers, and brand owners of batteries and products containing batteries. Identify whether you are primarily a battery manufacturer, a product manufacturer with embedded batteries, or a battery importer.

02

### Register on CPCB EPR portal for battery waste

Register on the CPCB EPR portal. Select the battery waste category. Provide battery chemistry types, quantity data for base year calculations, and company details.

03

### Empanel registered battery recyclers

CPCB maintains a list of registered battery recyclers for each chemistry type. Empanel and contract with registered recyclers who can issue recycling certificates. For Li-ion, the registered recycler network is growing — confirm recycler availability for your battery type in your supply regions.

04

### Obtain EPR authorization for battery waste

CPCB issues the battery waste EPR authorization after reviewing the application and recycler empanelment. Targets are specified in the authorization certificate.

05

### Operate collection and recycling channels

Set up collection mechanisms: collection points at retail locations, take-back schemes, bulk consumer agreements (for industrial batteries), or use CPCB-registered PRO (Producer Responsibility Organization) services.

06

### File quarterly and annual returns

File quarterly reports on collection quantities and annual returns with full recycling evidence. The annual return must show actual collection vs target and recycling certificates from registered recyclers.

## Frequently asked questions

### Does my product with an embedded battery need separate Battery Waste EPR authorization?

Yes. Products containing batteries — smartphones, laptops, cordless power tools, IoT devices, EVs — are subject to battery EPR obligations. As the manufacturer or importer placing the product on the Indian market, you must register for both E-Waste EPR (for the product itself) and Battery Waste EPR (for the embedded battery). Both obligations apply simultaneously for products with batteries.

### What is a Producer Responsibility Organization (PRO) and can I use one?

A PRO is a specialized entity that helps producers fulfill their EPR obligations by managing collection logistics, contracts with recyclers, and documentation. Using a CPCB-registered PRO does not transfer the legal EPR obligation — you remain responsible for fulfillment — but it simplifies the operational aspects. PROs are especially useful for foreign companies or smaller producers who lack the scale to build their own collection networks in India.

### How are battery EPR targets calculated for a company importing products with batteries?

EPR targets are calculated based on the quantity (by weight) of batteries placed on the Indian market in prior financial years. For embedded battery products, the battery weight must be declared separately. Target percentages increase year-on-year per Schedule II of Battery Waste Management Rules 2022. Companies new to India begin accumulating target obligations from year one of sales — even if targets are calculated on prior-year quantities.

**Disclaimer:** Battery EPR targets are set under Battery Waste Management Rules 2022. Targets and obligations are subject to annual CPCB updates. Always verify current targets on the CPCB EPR portal.

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