Battery waste EPR India: the second registration

A separate instrument, and a separate portal

The Battery Waste Management Rules, 2022 were notified by the Ministry of Environment, Forest and Climate Change as S.O. 3984(E) dated 22 August 2022, published in the Gazette on 24 August 2022, under sections 3, 6, 8 and 25 of the Environment (Protection) Act, 1986, superseding the Batteries (Management and Handling) Rules, 2001. They came into force on publication, more than seven months before the e-waste rules did.

They have been amended five times: S.O. 4669(E) of 25 October 2023, G.S.R. 190(E) of 14 March 2024, S.O. 2374(E) of 20 June 2024, S.O. 5210(E) of 3 December 2024 and S.O. 958(E) of 24 February 2025. CPCB runs them on a different portal, under a different registration, with different forms; an e-waste EPR registration number does not satisfy this.

Does a battery pull you into both regimes

It does, and the mechanism is worth showing, because one instrument genuinely carves something out of the other.

Rule 2 of the E-Waste (Management) Rules, 2022 states that those rules “shall not apply to waste batteries as covered under the Battery Waste Management Rules, 2022”. Meanwhile rule 2 of the battery rules applies them to “all types of batteries regardless of chemistry, shape, volume, weight, material composition and use”, with only two exclusions, military equipment and equipment designed to be sent into space. There is no carve-out for a battery inside an appliance.

The join is rule 9(2)(vi), which requires a recycler to “ensure that the Waste Battery is removed from collected appliance if Battery is incorporated in an equipment”. So a pair of wireless earbuds generates an e-waste obligation on the equipment and a battery obligation on the cell, and the carve-out exists so the same mass is not counted twice. Two registrations, two target calculations, two certificate markets, one product.

One asymmetry matters. The e-waste rules exclude a micro enterprise as defined in the MSMED Act, 2006; these rules do not. A micro enterprise can be outside the e-waste regime and squarely inside this one.

Your battery type, and who is a producer here

The rules recognise four types: portable, automotive, electric vehicle and industrial, the last being the residual category. Portable is a battery “that is sealed, less than five kilograms, not made for industrial purposes, electric vehicle or to be used as an Automotive Battery”. A D2C electronics brand sits in portable, and Schedule II splits it again, giving rechargeable consumer electronics their own target table.

The producer definition in rule 3(1)(u) has three limbs: manufacture and sale of battery including in equipment under its own brand; sale under its own brand of battery including in equipment produced by others; or import of battery as well as equipment containing battery. Compare the e-waste definition, which has four limbs, adds a phrase about dealers, retailers and e-retailers, and separately catches importers of used equipment. This one does its work through the words “including in equipment”, which is how it reaches a brand that has never sold a bare cell.

Registration, returns and the five year clock

You register on the CPCB battery portal in Form 1(A); the certificate issues in Form 1(B), and renewal is filed sixty days before expiry. Under rule 4(7) you file an EPR plan in Form 1(C) by 30 June every year for battery placed on the market in the preceding financial year, with quantity, weight and dry weight of battery materials. The portal records sales in kilograms by battery type and composition, and entries lock after 30 June or once that year’s return is filed, whichever comes first.

Schedule II gives portable batteries in rechargeable consumer electronics their own table, and the reference year is always the fifth preceding financial year:

• 2022-23: minimum 50 per cent of the quantity placed on the market in 2017-18
• 2023-24: minimum 60 per cent of 2018-19
• 2024-25: minimum 70 per cent of 2019-20
• Every year after: minimum 70 per cent, so FY 2026-27 is 70 per cent of 2021-22

The lag is fixed at five years, where e-waste EPR lags by the product’s own average life. On top of collection sits 100 per cent recycling or refurbishment of that year’s collection target. Across a ten year cycle both must reach 100 per cent, with up to 60 per cent of the remainder carried forward. Targets are tracked by kind of battery, so lithium ion counts separately from nickel cadmium.

Recovery percentages, certificates and marking

Rule 10(4) sets minimum recovery as a percentage of total recovered material weight out of the dry weight of the battery: portable 70 per cent in 2024-25, 80 in 2025-26 and 90 from 2026-27 onwards. Electric vehicle batteries follow the same ladder. Automotive and industrial run 55, 60 and 60. Read it carefully: this binds the recycler, not you. Your number is the Schedule II collection target. The percentage feeds rule 10(8), which sizes certificates as actual recovery divided by target recovery, times quantity processed, times a factor that discounts imported waste battery by 20 per cent.

You may buy certificates up to your current liability plus leftover liability plus 10 per cent, where the e-waste rules allow 5 per cent, and may buy surplus certificates from other producers in the same category. G.S.R. 190(E) of 14 March 2024 replaced rule 10(17) to fix the highest and lowest certificate price at 100 and 30 per cent of the environmental compensation, six days after the identical mechanism entered the e-waste rules. That amount is not in these rules but in CPCB guidelines, and we could not verify a published battery rate table, so treat it as unconfirmed. The refund ladder does differ: 75, 60 and 40 per cent here against 85, 60 and 30 under the e-waste rules.

Marking. Schedule I requires labels to BIS standards, printed visibly, legibly and indelibly, plus the crossed out wheeled bin symbol at prescribed sizes, and the chemical symbol Hg, Cd or Pb beneath it at a quarter of its size. S.O. 958(E) of 24 February 2025 added two reliefs: the Cd or Pb symbol is not required where cadmium is at or below 0.002 per cent or lead at or below 0.004 per cent by weight, and a producer may instead print a barcode or QR code carrying its registration number on the battery, the equipment or either one’s packaging, having told CPCB in writing. Note that the 2022 text glosses 0.002 per cent as 2000 ppm, which is wrong by a factor of 100; the 2025 amendment uses 20 ppm. Design to the percentage.