Understanding EPR Rules for Battery Importers in 2025

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When Rajeev, a small electronics importer from Delhi, received a call from his customs broker saying his shipment was “on hold due to missing EPR details,” he thought it was a minor documentation mismatch. Everything else was in order — IEC, GST, product specs — yet the consignment wouldn’t move.
That moment most importers face eventually: realizing that under India’s Battery Waste Management Rules, importers are treated the same as producers.

If you bring batteries or battery-installed products into the country, the responsibility of end-of-life management sits with you. This guide explains everything an importer needs to know about EPR rules in 2025 — in simple, practical terms.

EPR Rules For Battery Importer

EPR Rules for Battery Importers: What’s New in 2025

The 2025 update strengthened responsibilities for companies placing batteries on the Indian market. Importers now have clearer, stricter obligations around traceability, recycling targets, reporting, and labels.

What changed for importers

Businesses must now ensure:

  • Registration on the battery EPR portal before import
  • Correct categorization of batteries (portable, automotive, industrial, EV)
  • Digital labeling or QR codes displaying EPR details
  • Accurate reporting of imported quantities and weights
  • Meeting annual recycling targets through registered recyclers
  • Filing annual returns by the deadline

Customs authorities have begun enforcing this more aggressively — making EPR a practical requirement, not just a legal one.

Who Qualifies as an Importer Under EPR Rules

You’re considered a “Producer” under the rules if you place batteries or products containing batteries on the Indian market, even if you don’t manufacture them.

EPR obligations apply when you:

  • Import stand-alone batteries
  • Import equipment that contains batteries
  • Import foreign-brand batteries for sale
  • Import batteries for corporate or institutional use
  • Import items with embedded or non-removable batteries

EPR obligations do not apply only when:

  • You supply imported batteries exclusively to another manufacturer
  • And that manufacturer uses them under their own brand
  • And your name or brand doesn’t appear anywhere

If your company name appears in the supply chain, assume you are responsible.

How EPR Targets Are Calculated for Importers

Many importers are unsure how recycling targets are generated. Unlike other compliances, EPR calculations are based on dry-weight of battery material and the metal composition declared in the portal.

What determines your annual target:

  • Battery type
  • Battery chemistry (Li-ion, Lead-acid, Ni-Cd, etc.)
  • Dry weight (in kg) of units imported
  • Target percentage for that financial year
  • Composition percentages of key metals

Targets increase each year, and the portal automatically calculates the exact amount of each metal for which you must buy recycling certificates.

Annual EPR Targets for Importers

Battery Type FY 2025 FY 2026 FY 2027
Lead-Acid 50% 70% 90%
Lithium-Ion 30% 50% 70%
Nickel-Cadmium 40% 60% 80%
Zinc-Based 30% 50% 70%

Meaning:
If your company imports 1,000 kg of lithium-ion batteries in FY 2024–25, your obligation for FY 2025–26 is a minimum of 300 kg of recoverable material.

Compliance Process for Battery Importers

The CPCB portal follows a structured process. Here’s a simplified version tailored for importers.

Step 1: Register on the Battery EPR Portal

Create an account and select “Importer” as the producer type.
Provide company identification details and signatory verification.

Step 2: Declare Battery Details

Enter:

  • Type
  • Chemistry
  • Brand
  • HSN code
  • Whether imported alone or inside equipment

Step 3: Upload Import Data

The portal requires annual import data, with weight in kilograms.
You must also upload invoices regularly.

Step 4: Provide Battery Composition

Importers must declare metal composition for each chemistry.
This is critical because incorrect data can lead to scrutiny or rejection.

Step 5: Review Auto-Generated EPR Targets

The portal computes:

  • Total target weight
  • Targets by metal
  • Annual obligations

Step 6: Meet Targets Using Registered Recyclers

You must purchase recycling certificates equivalent to your annual target.

Step 7: File the Annual Return

This includes:

  • Total quantities imported
  • Target achieved
  • Certificates purchased
  • Awareness measures (if required)

Sample Importer Target Calculation (Lithium-Ion NMC)

Importer Input:

  • Imported weight: 500 kg
  • Battery chemistry: NMC
  • Declared composition: 10% Ni, 8% Mn, 12% Co, 20% Fe, 20% Al

FY 2025 target: 30%

Metal Composition % Total Metal (kg) Target % Target (kg)
Nickel 10% 50 30% 15
Manganese 8% 40 30% 12
Cobalt 12% 60 30% 18
Iron 20% 100 30% 30
Aluminium 20% 100 30% 30

Total certificates required: 105 kg
Importers must procure this quantity from approved recyclers.

Major Compliance Risks for Importers

Importers face unique EPR risks because they rely heavily on overseas suppliers. Small details, such as incorrect battery chemistry or weight mismatches, can lead to regulatory issues.

Key risks:

  • Consignments held due to missing EPR number
  • Penalties for unmet targets
  • Suspension of registration for inaccurate data
  • Delays when model numbers declared don’t match invoices
  • Incorrect metal composition entries causing portal rejections

A real importer scenario

An importer of handheld scanning devices in Bengaluru had a shipment held for nearly a month because the packaging did not display the EPR registration number. Warehousing costs and penalties were significantly higher than the cost of simply staying compliant.

Practical Tips to Stay Compliant in 2025

Here are simple steps importers can follow to maintain clean compliance records.

  • Keep a digital index of all battery models you import
  • Ask overseas suppliers for exact battery weight and compositions
  • Update import data on the portal monthly
  • Buy EPR certificates quarterly to avoid last-minute rush
  • Use only CPCB-registered recyclers
  • Avoid entering unrealistic battery compositions; it triggers scrutiny

This level of discipline ensures customs clearance remains smooth and predictable.

Conclusion

2025 has made battery EPR compliance unavoidable for importers. Whether you import power banks, electronics, appliances, EV components, or industrial devices, your company now plays a role in India’s battery waste ecosystem. Understanding your responsibilities early — and meeting them properly — saves time, reduces risk, and prevents costly shipment delays.

If you’re unsure about battery categories, targets, or certificate requirements, professional guidance can save you from the kind of surprises that hold up imports at ports.

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FAQs

EPR rules require importers to register with CPCB, report annual sales, and meet mandatory recycling/refurbishing targets through certified recyclers.

Yes. Any importer placing batteries or battery-powered equipment in the Indian market must register as a Producer on the CPCB battery EPR portal.

PAN, GST, CIN, IEC, authorized signatory ID, sales data, and relevant compliance documents per CPCB guidelines.

Targets are auto-generated on the portal based on sales history, battery type, and material composition defined under BWM Rules, 2022.

Non-compliance can lead to suspension/cancellation of registration and environmental compensation penalties.