Battery EPR certificates: who generates them, and what a collector can't do.

If you put batteries on the Indian market, you carry Extended Producer Responsibility for them (battery EPR) under the Battery Waste Management Rules, 2022, and you meet it with certificates. Who generates those certificates, and who can't, is the most misunderstood part of the rules.

This guide is our reading as a battery collector, with rule numbers so you can check each point against the current text. The rules have been amended several times since 2022. It isn't legal advice.

Who counts as a producer?

Not only a manufacturer. Under Rule 3, a producer is an entity that manufactures and sells batteries under its own brand, sells batteries under its own brand made by others, or imports batteries or equipment containing batteries. An EV maker that imports packs, or sells vehicles with packs inside them, is a producer for those batteries.

What does EPR require?

Rule 4 places Extended Producer Responsibility on the producer for the batteries it introduces to the market. Producers register on the Central Pollution Control Board's portal, file a return each year on the batteries they placed on the market, and must meet collection and recycling or refurbishment targets.

Those targets are set by chemistry as well as by category: the rules make them “specific to the kind of Battery (viz. Lead acid, Li-Ion, Nickel Cadmium, Zinc based Battery, etc.)”. Waste batteries a producer collects “shall be sent for recycling or refurbishing and shall not be sent for landfilling or incineration.”

Certificate prices are bounded too. A 2024 amendment has the Central Pollution Control Board fix the highest and lowest prices for EPR certificates at 100% and 30% of the environmental compensation leviable for non-fulfilment.

Who generates EPR certificates?

Under Rule 10, registered recyclers and refurbishers provide certificates for the waste batteries they process. The Central Pollution Control Board generates the certificates through its centralised portal, based on recycled or refurbished quantities, and assigns them to those recyclers or refurbishers. Producers procure them to meet their targets.

Certificates are category-wise, can only be used within the same battery category, and can be “transacted for meeting Extended Producer Responsibility obligations.” A recycler can't certify more than it can process: “in no case, the amount of Waste Battery recycled or refurbished by the entity shall be more than installed capacity of the entity.”

1. 01

   A registered recycler or refurbisher processes waste batteries

   It is registered with its State Pollution Control Board and files returns on what it receives and processes.

2. 02

   CPCB generates the certificates

   Through its centralised portal, based on recycled or refurbished quantities, and never beyond the entity's installed capacity.

3. 03

   They're assigned to the recycler or refurbisher

   Category-wise, and usable only within the same battery category.

4. 04

   Producers procure them

   And report, in their annual returns, the registered recyclers they procured them from.

Can a collector issue EPR certificates?

No. Certificates relate to batteries recycled or refurbished by registered entities. A collector's duty under Rule 7 is to “hand over Waste Battery to registered refurbisher or recycler”, and to follow the Central Pollution Control Board's standards while doing it.

So treat any offer of certificates straight from collection with caution: it describes something Rule 10 doesn't provide for. What a collector can offer a producer is material moved to registered recyclers, with records good enough to support the recycler's reporting.

Can a producer outsource collection?

Yes, but not the obligation. Rule 4(10) says a producer “may engage itself or authorise any other entity for collection, recycling or refurbishment of Waste Battery. However, the obligations of meeting the Extended Producer Responsibility targets shall remain with the Producer.” Producers may also run schemes such as deposit refund or buy-back to build a collection stream.

In practice, many EV makers run take-back through their dealer and service network: packs come back on replacement, under warranty and at end of life, and a collector picks them up from each site. Our take-back programme for EV makers works that way.

What does a producer report?

Producers file annual returns that include details of the registered recyclers from whom they procured EPR certificates, and must not deal with any entity that doesn't hold the registration the rules require. The Central Pollution Control Board levies environmental compensation on producers that don't meet their EPR targets and obligations.

What should a producer ask a collection partner?

Where does the material go, and are those recyclers registered? Can you show where every pack from our network came from and where it went? Are damaged packs kept out of lots and handled separately? Is every weight recorded individually, with evidence? And do you claim to issue certificates yourselves? The right answer to the last one is no.

To talk about collection across your dealer and service network, contact our team. The wider regime is covered in the rules, explained.