EPR Registration for Battery Importers: Complete 2025

  • Home
  • EPR
  • EPR Registration for Battery Importers: Complete 2025

Every month, Indian businesses importing batteries—whether small traders, laptop distributors, EV parts importers, or UPS manufacturers—run into the same challenge: shipments get stuck at customs because they don’t have an EPR Registration Number. Some importers discover this too late, after demurrage charges build up or their supply chain slows down.

If you import batteries or equipment that contains batteries, this guide is crafted specifically for you. It explains the 2025 rules in simple language, walks through registration, obligations, and risks, and gives practical importer-focused examples.

Let’s start with the foundation.

EPR Battery

EPR Registration for Battery Importers

Battery importers are legally treated as Producers under the Battery Waste Management Rules, 2022. It doesn’t matter if the battery carries a foreign brand, comes pre-installed in a device, or is part of a component you import—if it enters India because of your business, you must register.

What this means in practical terms:

  • You cannot import or sell batteries in India without CPCB approval.
  • You must take responsibility for waste battery collection and recycling.
  • You must work only with registered recyclers and refurbishers.
  • You must meet annual EPR obligations and file annual returns.

When importers are exempt:

Only in a rare case:
If an Indian manufacturer imports the battery under their brand, then they are the Producer—not you.
For 95% of importers, EPR registration is mandatory.

Why older registrations are no longer valid:

Registrations under older battery rules (before 2022) no longer apply. Every importer needs a fresh registration under the 2022 Rules.

Steps to Apply on the CPCB Battery EPR Portal

This walkthrough simplifies the official SOP into a clear, importer-friendly flow.

Step 1 — Create Your CPCB Portal Account

Visit the battery EPR portal and choose “Importer” while signing up. You’ll verify your mobile and email via OTP.

Details required during sign-up:

  • GST details
  • PAN
  • Business address
  • Authorized person’s KYC (PAN + Aadhaar)
  • Company name exactly as per GST certificate

Once verified, your account becomes active.

Step 2 — Begin Form 1(A)

After logging in, you will start Form 1(A), which captures basic company information, battery categories, and brand details.

You’ll fill:

  • Company profile
  • Authorized person details
  • Type of batteries you import
  • Whether these are sold under your brand or a foreign brand

Even if you import under the foreign brand’s name, you must still register—they do not carry EPR responsibility inside India.

Step 3 — Add Battery Sales/Import Data

This section is critical because your EPR targets depend on this data.

You must report:

  • Financial year
  • Battery type
  • Weight (kg) of batteries imported and sold
  • Applicable HSN codes

For importers, “sales” means:

  • Quantity imported
  • Quantity sold or distributed in India

This data should match your invoices and import documents.

Step 4 — Declare Battery Composition

The portal requires you to enter the approximate percentage of metals inside each battery type—especially lithium-ion, which has multiple metals.

This helps CPCB calculate:

  • Material-wise EPR targets
  • Required recycling volumes

Example:
A lithium-ion battery might contain nickel, cobalt, lithium, manganese, aluminium, copper, and iron in different percentages.

Step 5 — Upload Documents

You’ll upload all mandatory documents in PDF format:

Required Document Notes
GST Certificate Must match registered address
PAN (company/authorized person) Mandatory
IEC Compulsory for importers
CIN (if applicable) Pvt Ltd / LLP
Sales data sheet Required for EPR target calculation
Battery composition details Metal % declaration
Air/Water Consent Only if you have a manufacturing/storage unit

Step 6 — Pay the Application Fee

The portal calculates fees based on your company’s turnover slab. Payment occurs online using the integrated gateway.

Step 7 — Application Review

CPCB generally processes registrations within 15 working days, provided your documents are accurate and aligned.

If approved, you receive:

  • Form 1(B) EPR Registration Certificate
  • Your unique EPR Registration Number (valid for 5 years)

You can then officially import batteries/enclosed battery products into India.

What EPR Obligations Apply to Battery Importers?

Once registered, you are responsible for ensuring that the batteries you sell in India are collected, recycled, or refurbished at the end of their life.

Your responsibilities include:

  • Buying EPR Recycling Certificates from registered recyclers
  • Meeting annual EPR targets
  • Submitting valid invoices for battery recycling
  • Filing annual returns by June 30
  • Ensuring the batteries have required markings, QR codes, and compliance labels

How EPR Targets Are Calculated

CPCB automatically calculates targets based on:

  • Battery category (portable, automotive, industrial, EV)
  • Battery chemistry
  • Weight of batteries you place on the market
  • Composition of metals

For lithium-ion batteries, the target is split across:

  • Lithium
  • Nickel
  • Cobalt
  • Manganese
  • Aluminium
  • Iron
  • Copper

For lead-acid batteries, targets focus primarily on lead recovery.

Compliance Requirements Importers Must Follow in 2025

Recent updates in 2025 made compliance stricter and more traceable. Here are the key points simplified:

1. QR Code or Barcode Requirement

You must print a machine-readable code containing your EPR Registration Number on:

  • The battery
  • The battery pack
  • Equipment containing the battery
  • Battery packaging
  • Even outer cartons used in bulk transportation

This ensures each battery is traceable back to your company.

2. Relaxation for Very Low Cadmium or Lead

If the battery contains extremely low levels of:

  • Cadmium
  • Lead

Some chemical hazard markings may not be required.
This does not affect your obligation to print the EPR Registration Number.

3. Work Only with Registered Recyclers

To meet your EPR targets, you must buy recycling certificates from recyclers registered on the same CPCB portal.

Compliance Timelines for Battery Importers

Compliance Requirement Deadline
Obtain CPCB Registration Before importing
Enter sales/import data Ongoing
Buy EPR Certificates Annual or quarterly
File Annual Return By June 30 each year
Print QR/EPR Code Mandatory from 2025 onwards

What Happens If You Don’t Comply?

Many importers underestimate the consequences. Here’s what actually happens:

1. Customs Holds Your Shipment

This is the most common real-world impact. If the importer cannot produce a valid EPR Registration Number, customs can hold or delay clearance.

2. Environmental Compensation (EC)

CPCB can levy EC for:

  • Failing to register
  • Failing to meet EPR targets
  • Providing incorrect data
  • Not filing annual returns
  • Working with unregistered recyclers

3. Registration Suspension

If CPCB finds misinformation, they can:

  • Suspend your registration
  • Bar you from re-applying for a period
  • Issue warning letters or initiate legal action

4. Business Disruption

Some distributors refuse to deal with non-compliant importers because they don’t want EC risk passed downstream.

Practical Importer Scenarios

Scenario 1 — Battery Inside a Device

A Gurgaon laptop distributor imported devices with Li-ion batteries and assumed EPR does not apply since batteries were “inside electronics.”
They learned the hard way—CPCB clarified that the importer of the device remains the Producer.

Scenario 2 — EV Battery Packs Without Branding

A Chennai parts importer sourced generic EV battery packs. The foreign manufacturer had no Indian presence.
Result: They were the Producer and had to declare their own brand name during CPCB registration.

Scenario 3 — Import for Company Use Only

A retail chain imported thousands of inverters for their stores’ backup power.
Even though these were not sold commercially, they still counted as a Producer and needed registration.

Document Checklist for Importers

Mandatory Documents

Document Required Notes
GST Yes Must match portal entry
PAN Yes For company/authorized person
IEC Yes Mandatory for importing
CIN If applicable Pvt Ltd/LLP
Sales/Import Data Yes Must match invoices
Battery Composition Yes Needed for EPR calculation
Consent Certificates Only if applicable Not needed for traders

Battery Type vs EPR Certificate Requirements

Battery Type Metals Involved Target Basis
Lead Acid Lead (Pb) Lead recovery
Lithium-Ion Li, Ni, Mn, Co, Al, Fe, Cu Chemistry-wise targets
NiCd Nickel, Cadmium Metal-wise recovery
Zinc-based Zn, Mn, Fe Category-wise targets

Annual Returns Filing

Filing your annual return is straightforward if you keep sales records updated.

You must:

  1. Select the relevant financial year
  2. Verify obligations auto-filled by CPCB
  3. Upload awareness documents (mandatory annually)
  4. Attach recycling certificates purchased from recyclers
  5. Submit before June 30

Missing this deadline may result in penalties.

Conclusion

If you import batteries or equipment containing batteries, the Battery Waste Management Rules, 2022—and the 2025 amendments—place clear responsibilities on your business. EPR is no longer a background compliance formality; it has become an operational requirement affecting logistics, customs clearance, documentation, and long-term business relationships.

Being proactive with registration, maintaining sales data, and ensuring recycling obligations are fulfilled helps you avoid delays, penalties, and business disruptions.

If you need support navigating the registration process or understanding EPR obligations clearly, expert help can save weeks of time and prevent costly mistakes.

📞 Contact Green Permits

📞 +91 78350 06182
📧 wecare@greenpermits.in

Book a Consultation with Green Permits

 

Book a Technical Call with Expert

FAQs

Because importers are treated as “Producers” under BWM Rules 2022. Without EPR registration, you cannot legally import or sell batteries in India.

You’ll need GST, PAN, CIN, IEC, sales data, battery composition details, and an authorized person’s KYC — all uploaded on the CPCB portal.

On average, CPCB processes applications within 15 working days, provided all documents are correct and complete.

CPCB can impose Environmental Compensation, suspend registration, or revoke your license to import.

Yes — most businesses prefer consultants because the portal is complex, and even a small mistake can delay or reject approval.