When EcoVolt Industries Pvt. Ltd., a mid-sized battery importer from Gurugram, applied for EPR registration under the Central Pollution Control Board (CPCB), they assumed the process would be a simple formality. Two weeks later, they received a rejection notice citing mismatched GST and CIN details. The small oversight delayed their import license renewal by over a month — costing lost orders and credibility.
Stories like EcoVolt’s are becoming increasingly common. With the rapid evolution of Battery Waste Management Rules, 2022 and the 2025 amendments, even experienced compliance teams are tripping over documentation errors, label updates, and return-filing missteps.
Let’s look closely at the most frequent mistakes businesses make in Battery EPR compliance — and how to stay miles ahead of them.
Extended Producer Responsibility (EPR) places the responsibility of managing waste batteries squarely on producers, importers, and manufacturers. If you introduce batteries — or products containing them — into the Indian market, you must:
Non-compliance can trigger penalties, environmental compensation charges, and suspension of registration.
One of the simplest but costliest reasons for rejection is inconsistent business details. CPCB’s automated checks instantly flag any discrepancy between your GST, CIN, and PAN data.
A 10-minute internal document audit before submission can save weeks of resubmission time.
CPCB classifies producers into 17 distinct types — from battery manufacturers and importers to refurbishers and sellers. Selecting the wrong one can cause unnecessary confusion during verification.
A business that imports batteries under its own brand selects “Manufacturer,” or a company selling imported equipment with built-in batteries chooses “Dealer.” In both cases, CPCB returns the file for correction.
Having the correct category ensures you receive the right EPR target calculations and renewal conditions later.
EPR targets are generated automatically based on your historical sales data. Wrong numbers or missing years can drastically change your recycling obligations.
Example:
If you sold 1,000 kg of Lithium-ion batteries in FY 2020-21, and the target year is FY 2024-25, your EPR recycling obligation will roughly equal half of that weight.
A missing or inflated figure here can alter your targets and trigger audits later.
The Battery Waste Management (Amendment) Rules, 2025 introduced digital labeling requirements that many producers still overlook.
Every battery or its packaging must display either a barcode or QR code containing the EPR registration number. This rule applies to:
This minor design change now prevents customs holds and compliance penalties.
Many companies complete registration but forget that compliance continues every quarter.
Returns are the backbone of your credibility on the CPCB portal; missing one can stall renewal.
CPCB registration remains valid for five years, but renewal doesn’t happen automatically.
A company that submits its renewal late risks having to start the registration process again from scratch — including fresh fees.
Recycling partnerships can only be recognized if the recycler is registered on the official CPCB portal.
If you buy EPR certificates from an unregistered recycler, they are invalid for target fulfillment. During CPCB verification, your compliance percentage will show as zero even if you paid for those certificates.
Working only with authorized recyclers ensures your certificates count toward your official EPR targets.
EPR non-compliance carries real financial risk. Under CPCB’s Environmental Compensation (EC) Guidelines, violators can face:
Beyond financial penalties, repeated non-compliance can harm import clearances and supply contracts with government or OEM clients.
A Delhi-based EV battery supplier postponed updating its labels to include QR codes, assuming the rule would take effect “next year.” When its first post-amendment shipment arrived at Mumbai Port, Customs flagged it for missing EPR details. The goods sat in storage for six weeks, leading to ₹27 lakh in demurrage charges and a lost partnership with an automobile manufacturer.
The takeaway: regulatory delays cost far more than proactive compliance.
Battery EPR is no longer optional paperwork — it’s a core part of sustainable operations in India. Whether you’re a start-up importer or an established manufacturer, aligning your documentation, labeling, and reporting systems today protects you from delays, penalties, and market interruptions tomorrow.
Timely registration, accurate returns, and verified recycler tie-ups are the simplest way to stay ahead of regulation — and competition.
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Every manufacturer, importer, or assembler introducing batteries or battery-powered equipment into the Indian market must register with CPCB.
Five years from the approval date, subject to timely renewals and returns.
CPCB can impose Environmental Compensation and suspend your registration until the deficit is corrected.
Yes. CPCB’s portal allows profile amendments through an OTP-verified request process; the updated profile is approved by the divisional head before activation.
