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Under the Battery Waste Management Rules, who you hand a battery to is not a commercial detail. A producer “shall not deal with any other entity not having registration mandated under these rules”, and since the 2023 amendment the same applies to recyclers. Collectors must hand waste batteries over to a registered refurbisher or recycler, and nowhere else.
So before an EV maker, a fleet or a collector sends a single lot, it needs to know the recycler on the other end is registered, for the right batteries, with the capacity it claims. This piece explains how to check, with rule numbers so you can verify each point. It's our reading as a battery collector, not legal advice.
Registered on the EPR portal for lithium-ion batteries
Entities registered, as reported to Parliament in December 2025
| Producers | 3,391 |
|---|---|
| Recyclers | 43 |
Why there's no simple lookup
CPCB's EPR portal for batteries has a public page of registration certificates issued. It lists each holder's name, address, certificate number and date, but it doesn't say whether a holder is a producer or a recycler, which batteries it covers, or at what capacity, so it can't tell you on its own that a name is a registered lithium-ion recycler.
Across all battery chemistries, 487 recyclers were registered on the portal by December 2025. CPCB's own answer on where to find them is that the list sits with the states: registered recyclers are registered by their State Pollution Control Board. Some state boards publish lists; many don't. The practical route is to ask the recycler for its documents and confirm them with the board that issued them.
The list of registered Recyclers and Refurbishers can be obtained through SPCBs/PCCs.
What registration does a recycler hold?
Rule 9 is direct: “All recyclers shall register with the State Pollution Control Board through the online portal. The certificate of registration shall be issued in Form 2(B).” The recycler applies in Form 2(A), and the certificate is issued by the state board's Member Secretary.
CPCB's procedure for registering recyclers adds the working details. A fresh registration is valid for five years from the date it's granted, and renewal is applied for 60 days before expiry. The recycling capacity on the registration has to match the consent to operate issued by the state board. The application has to attach that consent, the authorisation under the hazardous waste rules, and a District Industries Centre certificate. Once registered, a recycler files quarterly returns in Form 4 on what it receives and processes.
A recycler's registration, in brief
- Issued by
- The State Pollution Control Board, through CPCB's online portal
- Application
- Form 2(A)
- Certificate
- Form 2(B), with a registration number
- Validity
- Five years from the date of grant, renewed 60 days before expiry
- Capacity
- As per the consent to operate from the state board
- Returns
- Quarterly, in Form 4
Which documents should you ask for?
A registered recycler holds more than one permission, and you should see all of them. Under the Hazardous and Other Wastes Rules, 2016, any facility that recycles hazardous waste needs an authorisation from its state board, and it needs consent to establish and operate under the Air and Water Acts. For lithium-ion batteries specifically, CPCB wrote to every state board in December 2023 that recycling facilities “shall also be authorised under Rule 6 of HOWM Rules, 2016”, and that plants turning black mass into metal compounds need a further permission under Rule 9 of the same rules.
Check that the documents agree with each other and with the company you're dealing with: the same legal name and plant address, dates still valid, and a scope and capacity that cover lithium-ion batteries in the volumes on offer.
Ask for the Form 2(B) certificate
The registration number, date of issue and validity, under the Battery Waste Management Rules.
Ask for the consent to operate
Under the Air and Water Acts, from the state board, with its validity and the capacity it allows.
Ask for the hazardous waste authorisation
Under Rule 6 of the Hazardous and Other Wastes Rules, 2016, and Rule 9 too if the plant processes black mass.
Match the details
Legal name, plant address, battery type and capacity should agree across every document and your contract.
Confirm with the state board
The board that issued the registration can confirm it's genuine and current.
These facilities shall also be authorised under Rule 6 of HOWM Rules, 2016
What are the warning signs?
Most of the risk sits in a few patterns, and each one breaks a specific rule. A “recycler” that can't or won't show a Form 2(B) certificate is not one the rules let a producer or another recycler deal with. Anyone other than a registered recycler or refurbisher offering EPR certificates is describing something Rule 10 doesn't provide for: CPCB generates certificates through its portal from recycled or refurbished quantities, and assigns them to registered recyclers and refurbishers.
Price is a signal too. Since March 2024, certificates trade between registered entities through the portal, at between 30% and 100% of the environmental compensation for non-fulfilment. And Rule 10 caps what a recycler can process at its installed capacity, so volumes far beyond its consent should prompt questions.
Red flags, and the rule each one breaks
- No Form 2(B) certificate, or a refusal to share it (Rules 4(15), 9(1) and 9(5))
- A collector or trader offering EPR certificates (Rule 10)
- Certificates priced outside 30% to 100% of environmental compensation (Rule 10(17) and 10(18))
- Volumes beyond the installed capacity in the consent to operate (Rule 10(2))
- An expired consent, authorisation or registration
- Papers that don't cover lithium-ion batteries
How we handle it
We deliver only to CPCB-registered recyclers, as Rule 7 requires of a collector, and the check is built into how we work. Before a recycler can receive a lot, its CPCB registration number and certificate have to be on file and in date. A lot can't be sealed for a recycler without a registration number, and an expired certificate takes the recycler off the ready list until it's renewed.
If you're choosing a collection partner, ask the same of them: which recyclers they deliver to, and whether they can show those recyclers' certificates. We answer that in the consignment record, which records the registered recycler on every lot, and on our Trust and compliance page.
Frequently asked questions
- Is there a public list of CPCB-registered battery recyclers?
- Not a reliable national one. The EPR portal lists registration certificates by name, address and certificate number, without saying which holders are recyclers or for which batteries. CPCB says the list of registered recyclers and refurbishers can be obtained through the State Pollution Control Boards.
- What certificate shows a battery recycler is registered?
- A certificate of registration in Form 2(B), issued by the State Pollution Control Board through CPCB's online portal under Rule 9 of the Battery Waste Management Rules, 2022.
- How long is a recycler's registration valid?
- CPCB's procedure for registering recyclers says a fresh registration is valid for five years from the date it's granted, with renewal applied for 60 days before expiry.
- What other permits should a lithium-ion battery recycler hold?
- Consent to establish and operate from its state board, and authorisation under Rule 6 of the Hazardous and Other Wastes Rules, 2016. CPCB has told state boards that plants turning black mass into metal compounds also need permission under Rule 9 of those rules.
- Can a collector sell EPR certificates?
- No. CPCB generates EPR certificates through its portal from recycled or refurbished quantities and assigns them to registered recyclers and refurbishers, which can sell them to producers.
We’d rather commit to a number we can hit than a number that sounds good.