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EPR Registration for Battery Waste Management

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Introduction

The Battery Waste Management Rules, 2022 (effective from August 22, 2022) replaced the earlier Battery (Management and Handling) Rules, 2001. These rules ensure that used batteries are collected, recycled, or refurbished in an environmentally responsible manner instead of being dumped in landfills or incinerated.

The regulations apply to all types of batteries – industrial, automotive, portable, and electric vehicle (EV) batteries.

Under the rules, producers and importers must:

  • Collect and recycle used batteries,
  • Use recovered materials in new battery production,
  • Register with CPCB through the centralized online portal.

Obtaining an EPR Certificate for Battery Waste Management is mandatory for all battery producers, importers, assemblers, and recyclers.

Liability Under BWM Rules 2022

According to Rule 4(4), the regulations apply to:

  • Producers (manufacturers of batteries)
  • Importers
  • Assemblers & Reconditioners
  • Dealers
  • Recyclers
  • Consumers & Bulk Consumers

👉 Producers must register on Form 1(A) via the CPCB online portal.
👉 These laws cover all battery types, irrespective of chemistry, size, or shape.
👉 Exemptions: Batteries used in defence, ammunition, war materials, and space equipment.

Documents Required for EPR Registration (Battery Waste)
  • GST Certificate (signed & stamped)
  • PAN & Aadhaar of Authorized Person
  • Company PAN, CIN, TIN
  • Consent to Operate (CTO) under Air/Water & Hazardous Waste Rules (if applicable)
  • DIC (District Industries Centre) Registration Certificate
  • Import Export Code (IEC) – for importers
  • GSTR-9 / Previous Year Balance Sheet
  • Authorized Email ID & Mobile Number
  • Company Website Address
Duties of Stakeholders

Duties of Producers / Importers / Assemblers / Reconditioners

  • Collect used batteries in proportion to new batteries sold.
  • Maintain records of new & recycled batteries.
  • Submit Form-I returns every six months (June 30 & Dec 31).
  • Establish collection centres individually or jointly.
  • Use only CPCB-licensed recyclers.
  • Partner with dealers for safe transportation.
  • Ensure batteries carry the global recycling symbol.
  • Promote consumer awareness about:
    • Hazards of lead,
    • Returning used batteries to dealers or collection centres.
    • Report non-compliance of dealers to CPCB/State Board.

Duties of Recyclers

  • Register with CPCB using Form VI.
  • Follow all conditions of registration.
  • Submit annual returns to the State Board.
  • Maintain accessible recycling records.
  • Label reprocessed lead as “Recycled”.
  • Raise public awareness about safe disposal of used batteries.
Collection Targets (Schedule – Rule 4(i) & 7(i))

Collection Targets (Schedule – Rule 4(i) & 7(i))

S.No. Year Number of Used Batteries to be Collected Back
1 During the first year of implementation of rules 50% of new batteries sold
2 During the second year of implementation of rules 75% of new batteries sold
3 After the second year of implementation of the rules 90% of new batteries sold
Renewal of EPR Authorization
  • Renewal must be applied using Form 5 at least 6 months before expiry.
  • CPCB or authorized bodies will review compliance before renewal.
  • Registrations may be cancelled if fraudulent documents are found.
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