EPR Authorization for Battery Recycling Units: Requirements & Process

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When Rohit Energy Systems Pvt. Ltd., a mid-sized lithium battery recycling company based in Pune, applied for its EPR authorization, the founder expected a quick approval. But a small mistake — uploading non-geo-tagged images — delayed the entire process by two months, affecting supply contracts and EPR certificate sales.

Such delays are more common than most recyclers realize. Whether you are a new entrant in the recycling business or already operating a plant, obtaining proper EPR authorization is not just a regulatory checkbox — it is the legal backbone that allows you to operate, generate EPR credits, and maintain trust with your clients.

Understanding EPR Authorization for Battery Recycling Units

Extended Producer Responsibility (EPR) is a policy mechanism under which manufacturers and importers of batteries are responsible for managing end-of-life waste generated from their products. But this system depends on registered recyclers, who perform the actual recycling and issue verifiable recovery certificates.

Under the Battery Waste Management Rules, 2022 (as amended in 2025), no recycler can operate or issue certificates without registration on the Central Pollution Control Board (CPCB) EPR Portal.

For recyclers, this authorization provides:

  • A formal recognition from CPCB or the State Pollution Control Board (SPCB)
  • Access to the EPR trading and wallet system
  • Permission to issue EPR certificates to producers
  • Legal protection during audits or inspections

This process also helps build transparency — every kilogram of recovered metal is traceable, ensuring a circular and compliant ecosystem for battery waste in India.

Applicability: Who Needs to Register

Every entity involved in dismantling, recovering, or refining materials from waste batteries must apply for authorization. This includes:

  • Lead-acid battery recyclers
  • Lithium-ion battery dismantlers and refiners
  • Nickel-cadmium or zinc-based recyclers
  • Black-mass processors who handle intermediate refining stages

Even if your plant only performs physical separation or smelting, registration under EPR is mandatory. The SPCB uses this information to verify your plant’s technology, installed capacity, and environmental safeguards before approving your license.

Step-by-Step Process for Getting Authorized

Let’s walk through how a recycling unit can successfully obtain EPR authorization and start operating legally in India.

Step 1: Register on the CPCB Portal

Visit the official EPR Battery Portal (www.eprbatterycpcb.in) and select the Recycler Registration option. You’ll create login credentials using your business details and authorized signatory’s contact information.

After OTP verification, your account will be created. This login ID will be used for:

  • Submitting new applications
  • Uploading returns and certificates
  • Communicating with CPCB and SPCB officers

Why this matters: Your login becomes your official compliance identity — losing access or entering incorrect details can lead to submission errors and delays.

Step 2: Collect and Prepare All Required Documents

Before starting the application, ensure you have clear and properly named PDF copies (under 2 MB each) of these documents:

Document Description
GST, PAN, CIN Basic company identity proofs
Valid Consent under Air & Water Acts Proof that your unit is legally allowed to operate
Authorization under Hazardous Waste Rules Required for facilities processing any waste or sludge
DIC Registration For units registered with District Industries Centre
Process Flow Diagram Must show input, output, and intermediate steps of recycling
Geo-tagged Photographs Of plant location, waste storage, machinery, and processing area
Short Video Clip A 360° walkthrough of your facility for CPCB’s verification

Tip: Use clear filenames and check that all documents have the same business name as in GST.

Step 3: Fill the Online Application

The EPR portal divides the form into six key sections:

  1. General Details: Company name, address, and authorized person information
  2. Battery Information: Types and chemistries handled (Lead-acid, Li-ion, etc.)
  3. Documents Upload: Attach all supporting files in PDF format
  4. Geo Images: Upload location photos and select your coordinates on the map
  5. Equipment Details: Add dismantling and refining equipment, along with their daily capacity
  6. Payment of Fees: Final step before submission

The form also asks for details of waste procured and recycled in the last three financial years. Even if your facility is new, you must enter “0” for previous years instead of leaving fields blank.

Step 4: Pay the Applicable Fees

Installed Capacity (Tonnes per Year) Application Fee (₹) Annual Processing Fee (25%)
Less than 1,000 10,000 2,500
1,000 – 5,000 20,000 5,000
Above 5,000 40,000 10,000

Note: The same amount applies during renewal, and payment is made through the portal’s online gateway.

Delays in fee payment can lock your submission temporarily, so ensure timely transactions.

Step 5: Application Review and Site Audit

Once your application is submitted, the concerned SPCB or PCC (Pollution Control Committee) processes it within 15 working days.

If additional information is required, you’ll receive an email or dashboard notification.
In some states, if the board fails to process the application within this period, deemed registration is automatically granted.

Within 30 days of approval, an on-site audit may be conducted to verify machinery, environmental measures, and operational capacity. The audit confirms that your plant actually performs the functions mentioned in your application.

Step 6: Generate EPR Certificates After Approval

After receiving authorization, your recycler account will be activated with an EPR Wallet on the portal.

You can start generating certificates for every tonne of metal recovered and sold to registered producers.
The key metals include:

  • Lead (Pb)
  • Lithium (Li)
  • Nickel (Ni)
  • Cobalt (Co)
  • Manganese (Mn)
  • Aluminium (Al)
  • Copper (Cu)
  • Iron (Fe)

For instance, if your plant recycles 500 kg of lithium-ion batteries and recovers 100 kg of cobalt and 50 kg of nickel, you’ll be able to issue EPR certificates worth that quantity. These certificates can be traded with producers through the CPCB system.

Business relevance: This becomes a direct revenue source for recyclers. The more accurately you record your recovery data, the faster you can generate EPR credits and sell them to producers meeting their compliance targets.

Step 7: Renewal and Periodic Returns

Your authorization remains valid for five years, but quarterly reporting is mandatory.

You must file:

  • Quarterly returns within 30 days of each quarter’s end
  • Annual return by June 30 every year

Returns include data on waste procured, processed, and metals sold. Late submissions attract penalties or suspension.

Before renewal, SPCB officers review your return history, so missing reports can delay the renewal process.

Key Compliance Requirements

Requirement Explanation
Operate only with registered producers and refurbishers Transactions with unregistered entities are invalid and can cause cancellation
Maintain transparent recordkeeping All invoices, lab reports, and metal sale documents should match portal entries
Display authorization details on-site Registration number and validity must be visibly displayed in the plant
Comply with new labeling norms (2025) Barcodes or QR codes with EPR registration numbers must appear on battery or packaging
Cooperate during audits Failure to assist inspection teams can result in suspension or fines

Risks and Penalties

Non-compliance can lead to serious business disruptions:

  • False documentation: Immediate cancellation and fee forfeiture
  • Non-filing of returns: Suspension and environmental compensation charges
  • Unregistered trading: All generated certificates will be deemed invalid
  • Audit refusal or obstruction: Up to one year’s revocation

Real-world case: In 2024, a Delhi-based recycler lost its EPR privileges for submitting duplicate metal sales invoices. The suspension prevented it from issuing new EPR certificates for a full year, severely impacting cash flow.

Why Early and Accurate Registration Matters

Securing EPR authorization early has clear operational and financial benefits:

  • Ensures full legal protection and compliance confidence
  • Enables generation and trading of EPR certificates
  • Builds credibility with producers and government auditors
  • Avoids last-minute renewals or environmental compensation penalties
  • Improves access to financing, as banks prefer registered recyclers

Get Professional Help for Smooth Registration

Green Permits Consulting Private Limited assists recyclers across India in obtaining, renewing, and maintaining EPR authorizations seamlessly. The team ensures document accuracy, portal filing, and audit preparedness from start to finish.

Call +91 78350 06182 | 📧 wecare@greenpermits.in
Book a consultation today to keep your recycling business fully compliant.

 

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FAQs

The concerned SPCB issues it via the CPCB’s centralized EPR Battery Portal.

Five years, subject to quarterly and annual return compliance.

Yes, through the portal’s digital wallet, ensuring transparency and traceability.

Operations are considered non-compliant, and trading access is suspended until renewal.

Yes. A fresh application must be filed reflecting the new capacity and equipment details.