What the Battery Waste Management Rules mean for producers, recyclers and collectors.

India's Battery Waste Management Rules, 2022 were notified by the Ministry of Environment, Forest and Climate Change as S.O. 3984(E), in supersession of the Batteries (Management and Handling) Rules, 2001. They set up an Extended Producer Responsibility (EPR) regime for batteries, and they define a role for every entity in the chain, from the company that puts a battery on the market to the recycler that recovers its materials.

The rules have been amended several times since: in October 2023, March 2024, June 2024, December 2024 and February 2025. This guide follows the rules as notified, notes the 2025 changes where relevant, and gives rule numbers so you can check each point against the current text. It's our reading as a battery collector, not legal advice.

Who do the rules apply to?

Rule 2 is broad. The rules apply to “Producer, dealer, consumer, entities involved in collection, segregation, transportation, re-furbishment and recycling of Waste Battery”, and to “all types of batteries regardless of chemistry, shape, volume, weight, material composition and use.” Lead-acid and lithium are covered alike. The only exclusions are batteries in equipment for essential security interests, such as military equipment, and equipment designed to be sent into space.

What are the four battery categories?

Rule 3 defines four categories, and obligations differ between them. A portable battery is one that is “sealed, less than five kilograms, not made for industrial purposes, electric vehicle or to be used as an Automotive Battery.” An automotive battery is one “used only for automotive starter, lighting or ignition power.”

An electric vehicle battery is “any Battery specifically designed to provide traction to hybrid and electric vehicles for road transport.” An industrial battery is one “designed for industrial uses”, excluding the other three, and can include sealed and unsealed batteries and energy storage system batteries.

Used, end-of-life and waste batteries: what's the difference?

The rules distinguish a used battery, one that has “residual life and suitable for refurbishment”, from an end-of-life battery, which has “completed its intended use and is not meant for refurbishment.” Refurbishment means “repairing, re-conditioning, re-purposing of used Battery for its second life.”

Waste battery is the wide term. It includes used and end-of-life batteries and their components, off-spec batteries from before they reach a consumer, batteries past their date for appropriate use, and any battery “discarded by the user.” Almost everything a collector handles is a waste battery under this definition.

Who counts as a producer?

A producer is 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. Brand owners and importers carry the same EPR obligations as manufacturers, including for refurbished batteries sold under their own brand.

What must producers do under EPR?

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 (Form 1(A)); under Rule 11 that registration is valid for five years. They file an EPR plan (Form 1(C)) by 30 June each year, and must meet the collection and recycling or refurbishment targets set out in the rules' second schedule.

Waste batteries a producer collects “shall be sent for recycling or refurbishing and shall not be sent for landfilling or incineration.” To build a separate collection stream, producers “may operate schemes such as deposit refund system or buy back or any other model.”

Producers can use others to do the work. 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.” Outsourcing the collection doesn't outsource the responsibility.

Producers also file annual returns (Form 3) by 30 June of the following financial year, including details of the registered recyclers from whom they procured EPR certificates; follow the labelling and prohibition requirements in Schedule I; and “shall not deal with any other entity not having registration mandated under these rules.” Since February 2025, producers may meet a labelling requirement by printing a barcode or QR code carrying their EPR registration number on the battery, the equipment or the packaging.

How do battery EPR certificates work?

This is the part most often misunderstood. Under Rule 10, registered refurbishers and recyclers provide certificates for the waste batteries they process. The certificates are category-wise, include the entity's GST data, 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.”

The Central Pollution Control Board generates EPR certificates through its centralised portal, based on recycled or refurbished quantities, and assigns them to the recyclers or refurbishers. Producers procure them from registered recyclers to meet their targets.

What that means in practice: a collector doesn't issue EPR certificates. Anyone offering a producer certificates straight from collection is describing something Rule 10 doesn't provide for. A collector's value to a producer is getting material to registered recyclers with records that support the recycler's reporting.

What do recyclers and refurbishers have to do?

Rules 8 and 9 require refurbishers and recyclers to register with their State Pollution Control Board through the online portal (Form 2(A), with registration issued in Form 2(B)). They must follow CPCB guidelines, manage hazardous waste under the Hazardous and Other Wastes Rules, 2016, and file quarterly returns (Form 4) on the waste batteries they receive and process.

Recyclers are also held to minimum material-recovery targets, measured as a percentage of the battery's dry weight. Under Rule 12, the State Pollution Control Board verifies compliance through inspection and periodic audit.

What do the rules ask of battery collectors?

Rule 7 covers “entities involved in collection, segregation and treatment.” It is short and absolute: they must “hand over Waste Battery to registered refurbisher or recycler”, and must make sure their facilities and activities follow the standards and guidelines of the Central Pollution Control Board.

The rules also point waste batteries towards collectors. Under Rule 5, a consumer should give a waste battery “to an entity engaged in collection or refurbishment or recycling”, and keep batteries out of mixed and domestic waste.

For a collector, the practical rule is simple: material moves to registered recyclers and nowhere else, and every handover is documented well enough to stand up when it's checked. That's how we operate: see How it works.

What is environmental compensation?

Rule 13 sets out environmental compensation, levied on the polluter-pays principle. It covers carrying out activities without the registration the rules require, providing false information or concealing material facts, submitting forged or manipulated documents, and, by name, “entities engaged in collection, segregation, and treatment” not following sound handling of waste batteries.

The Central Pollution Control Board levies environmental compensation on producers that don't meet their EPR targets, responsibilities and obligations. Violations can also be dealt with under section 15 of the Environment (Protection) Act, 1986.

Where does the system live?

Rule 14 required the Central Pollution Control Board to set up a centralised online portal for registration and returns by producers, recyclers and refurbishers. The portal is meant to reflect the material balance of waste batteries against producers' EPR obligations, and acts as the single repository for orders and guidelines under the rules.

If you're tracing a battery from the street to that portal, the hard part is the first mile. We cover it in The collection gap and A battery changes hands.