Battery EPR under Battery Waste Management Rule 2022: India’s Push for a Circular Battery Economy

As India embraces clean energy, electric mobility, and digital infrastructure, battery consumption has grown exponentially. From smartphones to electric vehicles, batteries are now central to modern life. But with their increased use comes a complex problem — battery waste.

To address this, the Indian government has implemented a robust Extended Producer Responsibility (EPR) system under the Battery Waste Management Rules, 2022. This framework holds producers accountable for managing the batteries they place in the market — even after their useful life is over.

What is Battery EPR?

Extended Producer Responsibility (EPR) is an environmental policy approach that assigns the responsibility of managing end-of-life products to producers. In the case of batteries, this means producers, recyclers, refurbishers must ensure proper collection, recycling, or refurbishment of the batteries they sell respectively.

The aim is to prevent environmental pollution, promote material recovery, and establish a circular economy for battery materials like lithium, cobalt, nickel, and lead.

Battery Waste Management Rules, 2022 — Key Highlights

The Ministry of Environment, Forest and Climate Change (MoEF&cc) notified the new Battery Waste Management Rules in August 2022, which inturn significantly expanded the scope and accountability of stakeholders.

 Applicability

These rules apply to:

• Portable batteries (used in electronics, toys, etc.)
• Automotive batteries (lead-acid batteries used in vehicles)
• Industrial batteries (used in backup systems, telecom, etc.)
• Electric Vehicle (EV) batteries

 Key Stakeholders

Unlike other EPR rules (e.g., for plastic waste), the battery EPR framework only involves three types of stakeholders:

1. Producers – Responsible for collection and end-of-life management of batteries
2. Recyclers – Recover valuable materials from waste batteries using authorized technology
3. Refurbishers – Extend the life of used batteries through repair, reducing the need for immediate recycling

 How Battery EPR Works

1. Registration: All producers, recyclers, and refurbishers must register on the CPCB’s Battery EPR Portal.
2. EPR Targets: Based on past sales, producers are assigned annual collection and recycling/refurbishment targets.
3. Work with authorised Recyclers/Refurbishers: Producers must engage only authorized recyclers or refurbishers.
4. EPR Certificate Generation: Recyclers/refurbishers generate certificates for recovered/refurbished batteries, which producers use to fulfil their obligations.
5. Reporting: Producers submit periodic returns to demonstrate compliance.

Why Battery EPR is Important

1. Environmental Impact

Batteries contain hazardous substances like mercury, cadmium, lead, and lithium. Improper disposal can lead to:

• Soil and water contamination
• Toxic air emissions
• Fire hazards in landfills

2. Resource Recovery

Batteries are rich in valuable metals. Recycling helps:

• Reduce dependence on mining
• Conserve natural resources
• Create a circular materials economy

3. Safety

Safe handling and recycling prevent:

• Fire/explosion risks (especially with lithium-ion batteries)
• Harmful exposure to heavy metals

Case Study: Battery EPR in Action — EV Sector Example

To understand how Battery EPR compliance works on the ground, consider the example of a mid-sized electric vehicle (EV) manufacturer operating in several Indian states. With growing sales of lithium-ion battery-powered scooters, the company faced its first round of EPR obligations under the Battery Waste Management Rules, 2022.

At the outset, the company had limited knowledge of how the EPR mechanism functioned. It lacked in-house recycling infrastructure and was concerned about meeting its collection and recycling targets in time.

Steps Taken:

• Registered as a producer on the CPCB Battery EPR Portal
• Assessed EPR obligations based on battery sales from the past 3 years.
• Work with authorized lithium-ion recyclers
• Recovered over 15 tonnes of used EV batteries via customer service centres and take-back campaigns
• Ensured all materials were processed and EPR certificates generated

Outcome:

• Achieved 100% EPR compliance in FY 2023-24
• Avoided penalties and legal action
• Enhanced sustainability branding and customer trust

Key Challenges in Battery EPR Implementation

Despite a strong policy framework, Battery EPR implementation in India faces several challenges:

• Dominance of the informal sector: A large share of waste batteries still ends up with unauthorized recyclers, causing environmental harm and undercutting formal recyclers.
• Low awareness among producers: Especially among small importers and sellers, there's limited understanding of registration and compliance obligations.
• Insufficient recycling/refurbishment infrastructure: Many regions, especially smaller towns and rural areas, lack access to CPCB-authorized battery processors.
• Weak consumer return behaviour: Most end-users lack awareness or incentives to return used batteries for proper disposal.
• Traceability gaps: Monitoring the flow of batteries from sale to end-of-life collection is still a challenge in the absence of strong digital tracking mechanisms.
• Limited enforcement: Inconsistent implementation of penalties and inspections reduces the pressure on non-compliant stakeholders to follow the rules.

The Way Forward

To make Battery EPR effective and sustainable, India needs:

1. Strengthening Enforcement
   Crackdown on unregistered producers and unauthorized recyclers.
2. Expansion of Authorized Infrastructure
   Encourage investment in battery recycling and refurbishing facilities across states.
3. Consumer Awareness Campaigns
   Promote safe return of used batteries through schools, retailers, and EV dealers.
4. Digital Tracking of Battery Lifecycle
   Use of QR codes or blockchain for traceability from sale to disposal.
5. Capacity Building for MSMEs
   Support small producers with easy compliance tools and guidance.

Final Thoughts

India's Battery EPR policy is a bold step toward a cleaner and more circular future. By holding producers accountable, encouraging material recovery, and phasing out informal dumping, the system ensures that the energy powering our future doesn’t pollute it.

As the EV revolution, solar energy, and digital tech continue to expand, the responsible management of battery waste will be vital. With active cooperation from producers, recyclers, refurbishers, and consumers, India can lead the way in sustainable battery stewardship.

About Aseries Envirotek India Pvt. Ltd.

As battery EPR regulations become more stringent and complex, compliance requires not just awareness—but expertise.

As one of India’s leading and most trusted EPR consulting companies, Aseries Envirotek India Pvt. Ltd. supports producers, recyclers, and refurbishers with seamless, end-to-end compliance solutions. From CPCB registration and target planning to authorized recycler/refurbisher onboarding, EPR certificate management, and regulatory reporting, Aseries ensures complete alignment with the Battery Waste Management Rules, 2022. If you are involved in the battery ecosystem, now is the time to act responsibly.