EPR for Battery Manufacturers, Importers & Assemblers: Roles & Responsibilities

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Introduction

India’s battery sector is expanding rapidly, especially in electric vehicles, solar storage, and consumer electronics. With this growth comes new environmental responsibility. The Battery Waste Management Rules 2022, amended in 2025, make it mandatory for every business introducing batteries into the market—manufacturers, importers, or assemblers—to comply with Extended Producer Responsibility (EPR).

This article explains what EPR means for your business, how responsibilities differ for each stakeholder, and what steps are required to stay compliant under CPCB’s framework.

Understanding EPR for Batteries in India

Extended Producer Responsibility (EPR) means that the company placing batteries on the market is responsible for managing them after they reach end-of-life. The rule ensures that waste batteries are collected, recycled, or refurbished in an environmentally safe way.

Core requirements:

  • Obtain registration through the CPCB’s central EPR Battery Portal before any sale or import.
  • Ensure that all waste batteries are channelled only through registered recyclers.
  • Meet yearly recycling or refurbishing targets (starting at 30 % in the first year, rising gradually to 70 %).
  • Submit quarterly and annual returns to verify compliance.
  • Maintain EPR certificates equal to the quantity of waste batteries recycled on behalf of your company.

EPR aligns business operations with sustainability and helps prevent uncontrolled dumping or unsafe disposal of used batteries.

Roles and Responsibilities by Category

1. Battery Manufacturers

Who they are:
Companies manufacturing and selling batteries in India under their own brand.

Key responsibilities:

  • Register on the CPCB portal before production or sales begin.
  • Provide detailed information on sales data and battery composition.
  • Meet assigned collection and recycling targets each year.
  • Purchase and maintain valid EPR certificates from registered recyclers.
  • File annual returns by June 30 of the following year.

Business impact:
Lack of registration or incomplete returns can lead to suspension, environmental compensation, and loss of supply contracts. Manufacturers should set up a clear internal compliance calendar for smooth renewal and audit processes.

2. Importers

Who they are:
Businesses importing batteries or battery-operated equipment into India.

Key responsibilities:

  • Obtain producer registration with CPCB before import activity.
  • Upload import and sales details, including HSN codes.
  • Ensure that imported batteries are recycled through authorized Indian recyclers.
  • From July 2025, display a barcode or QR code with the EPR registration number on the battery or its packaging.
  • File quarterly returns reflecting import, sale, and collection data.

Business impact:
Non-compliance can delay customs clearance and result in environmental penalties. Integration of EPR documentation with customs and logistics systems avoids repeated verification delays.

3. Assemblers and OEMs

Who they are:
Companies assembling battery cells or modules into finished battery packs or equipment for sale under their brand.

Key responsibilities:

  • Register as a producer if selling under their own brand name.
  • Maintain records of sourcing, production, and sale for reporting on the portal.
  • Create a take-back mechanism through distributors or service centres.
  • Partner only with registered recyclers to dispose of returned batteries.

Business insight:
Assemblers frequently overlook EPR registration, assuming compliance by component suppliers. However, liability lies with the brand placing the final product on the market.

Registration and Fee Structure

Annual Turnover (₹ Crore) Registration Fee (₹) Validity Renewal Fee
Up to 5 Cr 10,000 5 years Same as registration
5 – 50 Cr 20,000 5 years Same
Above 50 Cr 40,000 5 years Same

Interpretation: EPR registration costs are minimal compared to penalties for non-compliance. Early registration ensures uninterrupted manufacturing and import approvals.

How EPR Certificates Work

Recyclers generate EPR certificates based on the amount of metal recovered from waste batteries—such as lead, lithium, nickel, cobalt, or iron. Producers buy these certificates through the CPCB portal to meet their assigned obligations.

Key Metal Typical Recovery Rate Compliance Credit Example
Lead 60 – 80 % 1 credit = 1 kg lead recycled
Lithium 1 – 5 % Lower yield → higher certificate need
Nickel / Cobalt 10 – 20 % Higher-value metals = valuable credits

Understanding recovery rates helps companies forecast future certificate requirements and manage costs effectively.

Penalties and Compliance Risks

CPCB can suspend or cancel a producer’s registration and impose Environmental Compensation if:

  • Inaccurate or false data is reported.
  • EPR targets remain unmet.
  • Business operations continue without valid registration.

Environmental compensation can include both financial penalties and temporary bans on business activity. Regular internal audits and third-party verification of EPR data can prevent such issues.

The Role of PROs (Producer Responsibility Organisations)

Many companies hire registered Producer Responsibility Organisations (PROs) to handle day-to-day EPR operations.

A PRO typically:

  • Collects waste batteries from dealers, service centres, or consumers.
  • Partners with authorized recyclers to process and recover materials.
  • Maintains the digital paperwork and EPR certificate exchange on the portal.

While outsourcing to a PRO simplifies compliance, the legal responsibility remains with the producer. It is essential to verify the PRO’s registration, recycler network, and audit reports periodically.

Quick Compliance Checklist

Step Action When to Complete
1 Register on the CPCB EPR Battery Portal Before market entry
2 Submit company, product, and sales details At registration
3 Partner with authorized recyclers or a PRO Ongoing
4 Purchase EPR certificates as per targets Quarterly or annually
5 File annual returns and maintain records By June 30 each year

Conclusion

EPR compliance is now central to business continuity in India’s battery industry. Manufacturers, importers, and assemblers who integrate EPR practices early not only avoid penalties but also gain stronger market credibility and smoother regulatory clearances.

By aligning environmental responsibility with operational efficiency, companies can build trust with customers, investors, and regulators—turning compliance into a long-term growth advantage.

📞 Get Expert Help

For guidance on CPCB registration, EPR certificate procurement, or PRO coordination:

📞 +91 78350 06182 | 📧 wecare@greenpermits.in
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FAQs

Yes. If an assembler sells batteries or equipment under its own brand, it is treated as a producer and must obtain EPR registration from CPCB under the Battery Waste Management Rules.

The recycling or collection target starts at 30% of batteries placed on the market in the first year and gradually increases to 70% by the seventh year of operation.

Key documents include GST, PAN, CIN, Import Export Code (for importers), consent under Air and Water Acts, and a manufacturing or import declaration.

Registered recyclers issue EPR certificates based on the weight of recovered metals such as lead, lithium, or cobalt. Producers purchase these certificates through the CPCB portal to meet their annual obligations.

Yes. Producers may engage a registered Producer Responsibility Organisation (PRO) to manage collection, recycling, and reporting, but the legal responsibility remains with the producer.