A Delhi-based electronics importer recently called us in a panic. His battery shipment — worth nearly ₹38 lakh — was held at the port because customs flagged it for “Missing CPCB EPR Registration”.
He assumed EPR only applied to manufacturers.
But under India’s Battery Waste Management Rules, importers are legally treated as “Producers” — and the compliance starts before the first shipment lands.
This blog is written exactly for importers like him who want a simple, no-confusion guide.
Importing batteries into India today comes with strict compliance expectations. Under the Battery Waste Management Rules (2022 & 2025 amendments), any importer of battery or equipment containing battery must register as a “Producer” on the CPCB Battery EPR Portal.
Why it matters:
Let’s break it down into a practical, action-oriented checklist.
Many businesses get stuck because they start compliance after the first shipment.
Here’s the correct order.
You are a Producer (and must register) if you:
You are not liable for EPR only if:
Most importers fall under “Producer with EPR obligations”.
Documents required for importer EPR registration:
| Document | Notes |
|---|---|
| PAN | Company PAN or proprietor’s PAN |
| GST certificate | Address must match application |
| CIN (if applicable) | For companies |
| IEC (Import Export Code) | Mandatory for importers |
| Authorized signatory ID | Aadhaar or PAN |
| Sales plan / Product list | Type of batteries or battery-powered equipment |
| Brand details | Under which battery will be placed on Indian market |
| Awareness plan (simple PDF) | For annual return section |
| Signature image | For digital signing |
Keep all PDFs under 2MB for smooth upload.
Actions you will complete on the portal:
Once approved, your Form 1(B) Registration Certificate is issued.
Your EPR is calculated based on:
Here is a simplified table:
| Year | Target (Recycling / Material Recovery)* |
|---|---|
| Year 1 | 5% – 20% depending on category |
| Year 2 | 10% – 40% |
| Year 3 | 20% – 70% |
| Year 4 | 30% – 90% |
*Actual targets vary by battery type & chemistry as per CPCB’s Schedule II.
Most importers only track “units” but the EPR portal requires:
This is critical for meeting targets and filing returns.
Every importer must file:
Returns include:
Missed returns = non-compliance + penalty exposure.
| Stage | Action |
|---|---|
| Before Import | Register as Producer on CPCB EPR portal |
| Keep IEC, PAN, GST, CIN ready | |
| Check battery type, chemistry, weight | |
| Know your EPR target for the year | |
| At Import Stage | Ensure brand information matches documents |
| Keep invoices ready for customs queries | |
| Maintain battery composition data | |
| Post-Import | Update sales data regularly |
| Purchase EPR certificates from registered recyclers (if needed) | |
| File annual return by 30 June | |
| Keep records for 5+ years |
| Risk | Impact on Business |
|---|---|
| Shipment holds at port | Delay of weeks → demurrage charges |
| Rejection of import consignment | Forced re-export or destruction |
| Environmental Compensation (EC) | Financial penalty based on non-compliance |
| Registration suspension | No legal right to import battery-based products |
| Loss of tenders / OEM partnerships | Large companies only work with compliant partners |
| Reputational risk | Compliance is now part of supplier onboarding checks |
Battery import compliance isn’t as complicated as it appears — but timing is everything.
If you register early, maintain proper records, and follow a simple checklist, your operations stay smooth and risk-free.
If you delay, even one shipment can trigger unnecessary penalties, delays, or business interruptions.
For Indian importers, EPR is not optional — it’s a core compliance requirement.
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📧 wecare@greenpermits.in
The first step is registering as a Producer on the CPCB Battery EPR Portal. Importers automatically fall under the “Producer” category, so EPR registration is mandatory before importing batteries.
Yes. Importers must obtain EPR Registration and later meet recycling targets by purchasing EPR certificates from CPCB-registered recyclers. Without this, imports can be stopped at customs and penalized.
Importers need: GST certificate, Company PAN, CIN, Authorized person KYC, IEC, and consent/authorization if applicable. All documents must be uploaded in PDF format during registration.
Targets are calculated using past-year sales data, battery chemistry percentage, and CPCB-defined recovery factors. Once you submit your sales/import data, the portal auto-generates your EPR obligation.
CPCB may suspend registration, impose environmental compensation, and block future imports. Repeat violations can lead to cancellation of registration for up to a year.
