EPR - Battery Waste

The Battery Waste Management Rules, 2022, amended in 2025, mandate EPR obligations for all battery stakeholders, including producers, recyclers, and refurbishers, across portable, automotive, industrial, and EV categories. Registration is required via the CPCB’s centralised EPR portal.

Bulk consumers are not required to register, but must ensure disposal only through registered entities. As of 2026-27, producers must meet 90% material recovery targets to support India’s circular economy goals.

Who Needs EPR Registration?

Producers / Importers: Register via Form 1A with an EPR plan.
Recyclers: Register via Form 2, must demonstrate ≥ 90% recovery.
Refurbishers: Register via Form 3, with testing facilities details.
Collection Points: ULB registration only (Rule 5(4)).

Batteries under 10 grams are exempt from physical labelling if they meet weight thresholds under Legal Metrology rules.

Additional Information

Producers

Form 1A with FY 2023–24 sales and recovery plan
QR/barcode labels with EPR registration number (digital labelling)
Budget plan for awareness and collection activities

Recyclers

Form 2 with facility layout and recovery technology details
Material recovery audit reports showing ≥ 90% efficiency
Financial guarantee under Rule 12

Refurbishers

Form 3 with test report procedures
Annual returns detailing refurbished volumes

All Entities

Geo-tagged facility documentation
Digital manifest (Form 5) for tracking battery movement on the portal
Valid Consent to Operate (if applicable)

Authorisation Process

Eligibility Check

Eligibility Check and stakeholder category assessment

Account Setup

Account Setup on CPCB portal (eprbattery.cpcb.gov.in)

Form Submission

Upload Documents and complete forms 1A/2/3

Compliance Verification

CPCB reviews submissions (usually within 25 days)

Inspection

Field checks for recyclers/refurbishers to validate ≥ 90% recovery

EPR Certificate Trading

Producers may purchase EPR certificates from recyclers to meet obligations

Certificate Issuance

License granted upon satisfactory compliance, valid for 5 years

Additional Information

EPR Certificates issued by CPCB based on verified recycling volume; producers can buy to offset shortfalls.
EPR Certificates are valid for 2 years
Labelling Update: Producers may use digital barcodes/QR codes for packaging or brochures; physical ‘Cd’ or ‘Pb’ marking waived if thresholds are met.
Swappable EV Batteries: New guidelines effective 2025 for battery swap station operations and collection protocols.

How Neeyal EnviroSolutions Assists You

Eligibility Assessment

Identify stakeholder role & compliance path.

Documentation Prep & Portal Filing

Form 1A/2/3, uploads, registration assistance.

Recovery Target Planning

EPR recovery calculations per Schedule II.

Certificate Trading Facilitation

Assist with buying/selling EPR certificates.

Ongoing Reporting Support

Annual/Quarterly Form 3 & 4 returns.

Verification Audit Preparation

Support for CPCB inspection readiness.

Labelling Compliance

QR code integration per the MoEFCC amendment.