Five amendments since 2022: what changed in India's battery waste rules.

The Battery Waste Management Rules, 2022 were notified by the Ministry of Environment, Forest and Climate Change in August 2022. Since then the ministry has amended them five times. Most of the change sits in one notification, of October 2023; the four after it are narrower: a price band for certificates, a revised recycled-content timeline, a new penalty provision and labelling options.

This piece takes them in order, quotes the Gazette text, and gives each notification number so you can check every point. For the rules as a whole, start with the rules, explained. It's our reading as a battery collector, not legal advice.

October 2023: who carries the obligation, and for how long

S.O. 4669(E) widened the rules at the start. “Battery” now means a “new or refurbished cell or Battery”, so refurbished packs sit inside the regime by definition. The producer definition gained a fourth limb for contract assemblers: “manufacture or assembling of Battery or refurbished Battery including in equipment for sale to the Producer … without its own brand name.”

The obligation itself grew. Producers now carry Extended Producer Responsibility “for the Battery that they introduce in the market and the Battery which they put to self-use”, and a new duty covers pre-consumer waste batteries generated during manufacture, assembly or import. If a producer stops operating, it must still discharge its obligation for batteries already on the market.

Registration became open-ended. As notified, a producer's registration was valid for five years and then renewed. After the amendment, the certificate of registration in Form 1(B) is “valid until it is cancelled or withdrawn”, and an application is deemed approved two weeks after filing if CPCB hasn't refused it. The annual EPR plan in Form 1(C) became a return: a statement, by 30 June each year, of the batteries manufactured, assembled or imported in the previous financial year.

October 2023: how EPR certificates are generated

The rules as notified generated certificates from a formula: a recycler's actual recovery against a table of recovery targets, multiplied by the quantity processed, with a 20% discount for imported waste. The amendment omitted that table (rule 10(4) and (5)) and replaced the formula. Certificates are now generated “based on the weight of waste Battery processed or refurbished … and weight of Battery material produced as per guidelines of the Central Pollution Control Board.”

Imported waste no longer earns anything: “No Extended Producer Responsibility certificate shall be generated for the recycling or refurbishment of waste Battery imported” under the hazardous waste rules. And a certificate stays in its lane: one issued in a category “can only be used for off-setting, carry forward and sale for the same category of Battery.” The amendment also allowed accredited trading platforms for certificates, and fixed a drafting slip so that the recycler rule now reads: “Recycler shall not deal with any other entity not having registration mandated under these rules.”

For a producer, the effect is that certificates follow domestic material actually processed, category by category. For a collector, it means the material it delivers is what a recycler's certificates rest on, which is why the records travelling with it matter. We explain that side in Battery EPR certificates.

October 2023: targets for three-wheeler EV batteries

The amendment replaced the target table for e-rickshaw batteries with one for “three wheelers, including E-rickshaw, categories L5, L5-M, L5-N, E-cart”. As notified, the first compliance year was 2024-25. Under the new table it is 2026-27, and each year's collection target looks five years back rather than three: a minimum of 70% of the batteries placed on the market in 2021-22, then 2022-23, and so on.

The two-wheeler table wasn't changed, and its first year is also 2026-27. So from 2026-27, producers of both two- and three-wheeler EV batteries carry collection targets at the same time. Four-wheeler EV batteries begin in 2029-30, at a minimum of 70% of the quantity placed on the market in 2021-22.

March 2024: a price band for certificates

The October 2023 amendment had CPCB fix the highest and lowest certificate prices “every six month or as required.” G.S.R. 190(E) replaced that with a fixed rule: the highest and lowest prices “shall be equal to 100% and 30%, respectively of the Environmental Compensation leviable on the obligated entities for non-fulfilment”. A new sub-rule requires every exchange between registered entities through the portal to sit inside that band.

The same notification rewrote carry-forward in every target table, EV tables included: “up to 60% of the remaining quantity of battery placed in the market during the applicable compliance cycle may be carried forward to the next compliance cycle.” For automotive batteries that raised the limit from 20% to 60%. And CPCB, rather than the implementation committee, now prepares the guidelines for imposing environmental compensation on producers, recyclers and refurbishers.

June 2024: recycled content, later for lead-acid categories

Rule 4(14) requires producers to use a minimum share of domestically recycled material in new batteries. S.O. 2374(E) replaced the table. For automotive and industrial batteries, mostly lead-acid, the schedule moved back three years: 35% from 2027-28, where the original table began at 35% in 2024-25.

The EV row didn't move. Electric vehicle batteries must contain a minimum of 5% recycled material in 2027-28, rising by five points a year. That is the demand side of everything a collector does: recycled lithium, nickel and cobalt have to come from packs someone first collects.

December 2024: from offence to penalty

The Jan Vishwas Act of 2023 amended the Environment (Protection) Act, 1986 to decriminalise offences under it. S.O. 5210(E) brought the battery rules into line. It deleted the old provision that violations “may also be dealt with” under section 15 of that Act, and replaced the rule on non-fulfilment with one sentence that reaches everyone in the chain.

That includes collectors. Rule 13 already named “entities engaged in collection, segregation, and treatment” among those liable to environmental compensation; the penalty provision now applies to “any person” who fails to comply.

February 2025: what goes on the label

The October 2023 amendment required producers to mark every battery or battery pack with their EPR registration number by 31 March 2025. S.O. 958(E) made that easier to meet. A producer may instead print a barcode or QR code carrying the number on the battery, the equipment containing it, either one's packaging, or bulk packaging not for retail sale, after informing CPCB in writing; CPCB publishes a list of those producers every quarter.

It also set thresholds for the chemical symbols: “Cd” and “Pb” markings aren't needed where cadmium is at or below 0.002% (20 parts per million) or lead at or below 0.004% (40 parts per million) by weight. And packaging covered by rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2011 is exempt from the registration-number marking.

What it means for each part of the chain

Producers and importers carry most of the change: open-ended registration, a yearly return, EPR on self-use and pre-consumer waste, a fixed certificate price band, new labelling options, and two- and three-wheeler EV targets that both begin in 2026-27.

Recyclers and refurbishers now earn certificates on the weight they process and the material they produce, within one category, and none on imported waste. Their prices are bounded, and they may not deal with entities lacking the registration the rules require.

For collectors, the text that matters most didn't change. Rule 7 still says a collector must “hand over Waste Battery to registered refurbisher or recycler”, and that is how we work: every pack stickered and weighed, every lot delivered to a registered recycler with the records that support its returns. See How it works.