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Extended Producer Responsibility Registration For Battery Waste Management 

Home / CPCB certification / Extended Producer Responsibility Registration For Battery Waste Management 
Battery Waste Management
Table of Contents
  • Battery Waste Management facilitates proper collection, recycling, and disposal processes for spent batteries.
  • Ensures following India’s Battery Waste Management Rules sanctioned in 2022.
  • EPR Registration mandates the responsibility of producers for the disposal of their batteries at end-of-life.
  • CBCP Guidelines provide a structured framework for collection, recycling, and reporting.

Introduction

Diligence Certification BIS consultancy in India (CPCB)

Battery waste management A Pune-based, mid-sized electronics corporation received notification in 2024 from the government regarding what it perceived as a possible violation of its battery disposal responsibilities. The firm sold over 50,000 lithium-ion batteries a year and had not registered at any time under EPC (Extended Producer Responsibility) in accordance with CBCP (Cell Battery Collection Pathways). The penalties, fines, and operational delays were fully avoidable if they had adopted appropriate Battery Waste Management protocols.

India generates over 50,000 tons of battery waste annually, yet formal recycling channels cover less than 30% of the total. With growing EV adoption and electronics consumption, EPR registration is no longer optional. It is mandatory for responsible producers.


Understanding Battery Waste

Battery waste management entails a collection, recycling, and disposal process for used batteries. The purpose of battery waste management is to minimize risk to the environment and to meet any legal and/or regulatory obligations regarding battery disposal. It is important to properly manage batteries; if not, (very) dangerous levels of contamination can occur to soil, groundwater and excessive dangers that contain heavy metals. 

Why Battery Waste is Important?

  • Environmental Protection:- Lead-acid and lithium-ion batteries contain harmful substances. Proper disposal can help prevent contamination of the soil and heavy metals in waterways.
  • Policy/EPR:- The Central Pollution Control Board (CPCB) has a policy in place to have producers comply with Extended Producer Responsibility (EPR).
  • Brand Credibility:- Companies that dispose batteries sustainably establish brand credibility with stakeholders.

What is Battery Waste Management?

Battery Waste Compliance

Battery waste management refers to the safe disposal of used batteries or decommissioned batteries, in a way that lowers the impacts on human health and the environment, which is known as battery waste management (and all materials in batteries can be thought of as waste). Used batteries have toxic components in them, like lead, cadmium, lithium and mercury, which can damage human health, damage wildlife, and contaminate soil and water if batteries are not disposed of in proper manner.


What is  EPR Registration?

Extended Producer Responsibility (EPR) Registration is the official authorization from the Central Pollution Control Board (CPCB) that allows producers, importers, and brand owners to legally sell the product in India and take accountability for managing the waste generated via the product.


Why EPR For Battery Waste?

Used batteries can contain harmful chemicals which are potentially harmful to the environment (for example lead, cadmium and mercury) if not disposed of properly. Many national governments including India have established compliance certification in respect of the disposal of batteries in its Battery Waste Management Rules to address these concerns about proper disposal of batteries.

For companies, compliance certification means:

  • Legal compliance national waste management regulations.
  • Minimized risk of penalties or bans on products. 
  • Enhanced reputation as an environmentally friendly company.
  • Progress toward circular economy and sustainability objectives

Who Needs EPR Registration For  Battery Waste ?

Under the Battery Waste Management Rules, 2022 in India, EPR Registration is mandatory for all entities involved in the production, import, or branding of batteries. In particular, the following stakeholders must acquire EPR registration:

  • Battery Producers/Manufacturers: – Companies that manufacture batteries domestically to sell on the Indian market.
  • Battery Importers: – Organizations that import batteries into India, to sell, distribute, or use batteries in India.
  • Brand Owners: – Company / individual that has marketed batteries under their brand name, even if the manufacturer is not the owner.

Benefits of ERP Registration for  Battery Waste

The registration for Extended Producer Responsibility (EPR) for battery waste management has so many benefits for companies and their environmental stewardship. Some key benefits are: 

  • Ensures environmental protection by preventing both soil and water contamination from hazardous waste from batteries.
  • Ensures compliance with Battery Waste Management Rules 2022.
  • Encourages sustainability, while building corporate social responsibility (CSR).
  • Provides an avenue for a circular economy by recycling / recovery of material.
  • Increases brand reputation and consumer confidence being a sustainability friendly company.
  • Encourages efficient waste management with authorized recyclers and PROs.

ERP Registration Process for  Battery Waste

  • Eligibility Requirements:- Required for battery producers, importers, and brand owners.
  • Documentation Requirements:- Company information (PAN, GST, incorporation certificate), product information, and a battery waste management plan.
  • Application Process:- Apply for registration using the CPCB EPR portal.
  • Application Steps:- Upload Documents; CPCB verifies, reviews, and approves applications.
  • Reporting and Compliance:- Will create annual collection and processing targets and reporting timelines (monthly, quarterly, semi annually, annually, etc.).
  • Engagement:- Will engage certified recyclers or Producer Responsibility Organization (PRO).
  • Renew:- Will have to be renewed periodically for completion.

Documents Required for EPR Registration for Battery Waste

Company Details:

  • Certificate of Incorporation / Business Registration
  • PAN Card of the company
  • GST Registration Certificate

Product Details:

  • Types of batteries manufactured, imported, or sold
  • Quantity of batteries placed in the market

Waste Management Plan:

  • Strategy for collecting, recycling, and sustainably disposing of used batteries 

Authorization & Compliance Documentation (if needed): 

  • Any existing approval or license for battery recycling or waste management 

Other Supporting Documents:

  • Any agreement(s) with Producer Responsibility Organizations (PROs) or battery recyclers 
  • If a renewal for EPR is submitted, any annual targets or compliance reports 

Key Provisions Of Battery Waste Management 2022

The principle of extended producer responsibility (EPR) is simply the understanding that a manufacturer, importer, or brand owner of batteries will collect, sort, and responsibly manage the waste stream of batteries at end-of-life ensuring sustainability is achieved.

  • Mandatory registration:- it is required that manufacturers, importers, and brands of batteries register with the Central Pollution Control Board (CPCB). 
  • Collection and recycling targets:- each manufacturer, importer, or brand of battery is required to meet an annual collection and recycling target proportionate to their market share.
  • Authorized recyclers/Priority Recycle Organization (PRO’s):- All producers, importers and brands must use either a registered recycler or registered PRO.
  • Safe Disposal Practices:- All battery waste must be treated and recycled/disposed of in an environmentally sound way and no battery should be able to pollute the environment at the time of disposal.
  • Compliance and Reporting:- All producers, importers and brand owners must submit documentation to demonstrate compliance periodically and renew their EPR authorization. 
  • Consumer Awareness:- Encouraging consumer awareness regarding environmental suitability of battery disposal and recycling.

Fee for Battery EPR Registration

The cost for registering under ERP for battery waste management set by the government can change depending on how much waste you produce 

The fees shall be paid online through the payment gateway integrated in the portal.
Fees for renewal of registration shall be the same as the Registration fee.
Application Fees is exclusive of any transaction charges.

Validity of EPR Registration for Battery Waste

  • Duration:- 5 years from the date of grant.
  • Issuance:- The Central Pollution Control Board (CPCB) grants a certificate of registration in the form of Form 1(B), upon successful registration

Renewal of EPR Registration for Battery Waste

  • Application Schedule:- The producers must submit a renewal application at least 60 days before the expiry of the registration. 
  • Renewal Form:- The renewal application must be submitted in Form 1(A).
  • Processing Time:- CPCB will endeavor to process the renewal and grant the application within 15 working days, given all necessary documents are complete and submitted.

Cancellation of EPR Registration Guidelines

Authority CPCB can cancel or suspend EPR registration for non-compliance.

  • Grounds for Cancellation:
    • Failure to meet collection or recycling targets
    • Improper handling or disposal of battery waste
    • Non-submission of required documents or reports
    • Non-payment of registration or renewal fees
  • Consequences:
    • Suspension of registration and halt on battery sales
    • Financial penalties or environmental compensation
    • Possible legal action for serious violations
  • Procedure:
    • Issuance of notice by CPCB
    • Opportunity for the entity to respond or rectify issues
    • Final decision based on compliance and response

Why Choose Diligence Certification?

  • Credibility and Trust – Certification gives your clients, partners and regulatory stakeholders, clear evidence of competence.
  • Global Recognition – Global recognition and respect across a number of sectors and industries.
  • Assured Compliance – It provides evidence of compliance with relevant legal and good practice requirements as well as international standards.
  • Competitive Advantage – It differentiates you against competitors and gives you credibility and brand.
  • Risk Management – It assists in the detection, prevention, or management of operational or compliance risks.
  • Efficiency and Continuous Improvement – It helps in efficiencies through process improvements to reduce errors and costs.
  • Customer Confidence – It is evidence of quality, safety and ethical behaviour.
  • Sustainable growth – It lays the foundation for lasting success through well-structured and disciplined practices of business.

Conclusion

ERP Registration ForBattery waste management, ERP registration and EPR compliance under the CBCP (Canadian Battery Recycling Program), is necessary in meeting compliance obligations and contributing to environmental sustainability. Organizations that carry out systematic collection, recycle with recyclers authorized by CPCB, and develop proper documentation could avoid expensive fines and even potentially build their brand. By transforming battery disposal into an obligation from a more strategic approach than a compliance task, organizations can accelerate a more sustainable approach to a greener India while leveraging their operating efficiency.

Frequently Asked Questions

What is EPR?

Producers/importers are responsible for collection, recycling, and safe disposal of battery waste.

Who needs EPR registration?

Battery manufacturers, importers, brand owners, and sellers of battery-containing products.

Why is it mandatory?

To facilitate required disposal and recycling and reduce environmental pollution.

How to register?

Apply online through the CPCB portal with company and product details.

Documents required:

PAN, GST, product info, sales volume, and waste management plan.

Compliance obligations:

Collect and channelize waste to authorized recyclers.
Submit annual EPR reports.
Display EPR registration number on products.

Authorized recyclers:

Battery waste must be sent only to CPCB-approved recyclers.

Penalties for non-compliance:

Heavy fines, legal action, and possible business restrictions.

Renewal of registration:

EPR registration is valid for a specified period; renewal required before expiry.

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Experienced BIS Consultant specializing in helping businesses navigate India’s regulatory compliance and certification process. With expertise in BIS standards and product certifications, he guides manufacturers, importers, and exporters in achieving hassle-free approvals while ensuring quality and compliance.

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Rajat Rawat

Experienced BIS Consultant specializing in helping businesses navigate India’s regulatory compliance and certification process. With expertise in BIS standards and product certifications, he guides manufacturers, importers, and exporters in achieving hassle-free approvals while ensuring quality and compliance.

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