Battery Waste Management Rules 2022: EPR Targets, Deadlines and Fines for FY 2026

Updated: June 26, 2026 · 16 min read

When the Ministry of Environment, Forest and Climate Change (MoEFCC) notified the Battery Waste Management Rules, 2022 in August of that year, many Indian battery producers treated registration on the CPCB portal as a distant administrative formality. That calculation has aged poorly. With EPR collection targets for FY 2025-26 now at their highest scheduled levels, and the Central Pollution Control Board (CPCB) tightening authorisation audits across the battery recycling chain, companies that have not yet aligned their procurement, logistics, and documentation are operating on borrowed time.

Why FY 2025-26 Is the Reckoning Year for Battery EPR Compliance

The battery waste management rules 2022 were framed on a phased compliance philosophy: the first two financial years after notification were relatively soft-touch, designed to let producers, importers, and recyclers build infrastructure. That runway has closed. FY 2025-26 is the year in which the steepest single-year EPR target jump takes effect for multiple battery categories, and CPCB enforcement actions — including show-cause notices to non-registered entities — have picked up noticeably since the close of FY 2024-25.

The broader regulatory context matters here. The Battery Waste Management Rules, 2022 sit within a layered compliance architecture alongside the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 (which govern the movement of spent lead-acid batteries as hazardous waste) and the E-Waste (Management) Rules, 2022 (which cover battery-embedded electronic devices separately). Understanding where each rule’s jurisdiction begins and ends is not a legal nicety — it determines which CPCB authorisation your recycler must hold before you can claim EPR credit.

Recent CPCB enforcement actions in Maharashtra and Gujarat have flagged recyclers operating without valid battery processing authorisations, which in turn invalidates the EPR credit certificates their producer-clients were counting on. Fleet operators in Delhi-NCR running large lead-acid battery inventories have received compliance notices for failing to channel end-of-life batteries through registered dismantlers. The message from regulators is unambiguous: the grace period is over.

What the Battery Waste Management Rules, 2022 Actually Require

The Battery Waste Management Rules, 2022, notified under the Environment (Protection) Act, 1986, apply to every entity that manufactures, imports, sells, or uses batteries in India — across four principal categories: portable batteries, automotive batteries (lead-acid), industrial batteries, and electric vehicle (EV) batteries. Each category carries its own EPR target schedule under Schedule I of the Rules.

The Rules place primary obligation on producers — defined broadly to include manufacturers, brand owners, and importers placing batteries on the Indian market. Under Rule 5, producers must (a) register on the CPCB Battery Waste EPR portal, (b) submit an annual EPR action plan, (c) meet category-specific collection and recycling targets, and (d) maintain records for a minimum of five years. Importers are treated as producers for the quantity they import. Bulk consumers — entities consuming batteries in operations (think telecom towers, data centres, EV fleet operators) — have separate obligations under Rule 13 to channel spent batteries only to registered dealers or recyclers.

Critically, Rule 10 of the Battery Waste Management Rules, 2022 introduces the EPR credit mechanism: producers can meet their targets either by setting up their own collection and recycling infrastructure or by purchasing EPR certificates from CPCB-registered recyclers. This credit market is now operational on the CPCB portal, and credit prices for lithium-ion battery recycling have been firming up given the anticipated volume surge from the EV sector.

Year-Wise EPR Targets: The Schedule You Cannot Afford to Misread

Schedule I of the Battery Waste Management Rules, 2022 sets out collection and recycling targets as a percentage of the weight of batteries placed on the market in the preceding year. The targets differ by battery category and step up year on year. The table below consolidates the key figures producers and importers must plan against for FY 2023-24 through FY 2026-27.

Battery Category	FY 2023-24	FY 2024-25	FY 2025-26	FY 2026-27
Portable Batteries	40%	50%	60%	70%
Automotive (Lead-Acid)	60%	70%	80%	90%
Industrial Batteries	40%	50%	60%	70%
EV Batteries (Lithium-Ion)	—	—	25%	35%
Recycled content mandate (EV Li-ion, new batteries)	—	—	5%	10%

Two figures in this table demand attention. First, the automotive (lead-acid) EPR target hits 80% for FY 2025-26 — one of the highest EPR collection obligations anywhere in Indian environmental regulation. Given that lead-acid batteries already have a well-developed informal recycling chain, the compliance challenge is not collection per se but channelling that collection through CPCB-registered entities so that credits are audit-proof. Informal smelters do not generate valid EPR certificates.

Second, the EV battery (lithium-ion) EPR target kicks in for the first time at 25% of weight placed on market in FY 2025-26. Because most EV batteries sold in India in FY 2022-25 are still in service, the actual tonnage coming back for recycling in FY 2025-26 is manageable — but producers must demonstrate a collection and recycling pathway exists. The 5% recycled-content mandate for new EV batteries is a forward-looking provision that will reshape procurement for battery manufacturers from FY 2025-26 onwards, since it requires sourcing lithium, cobalt, or nickel from certified domestic recyclers.

CPCB Portal Registration: Who Must Register, and By When

Registration on the CPCB Battery Waste EPR portal at batterywaste.cpcb.gov.in is not optional and carries no fee — but the consequences of operating without registration are severe. Under Rule 6 of the Battery Waste Management Rules, 2022, the following categories must register before placing batteries on the Indian market or commencing battery processing operations:

• Battery producers (manufacturers and brand owners)
• Importers of batteries or battery-embedded products
• Recyclers of end-of-life batteries
• Refurbishers of used batteries
• Bulk consumers (defined as organisations consuming 100 or more batteries per year)

The registration process requires submission of: a valid GST certificate, factory licence or import-export code (IEC) issued by DGFT, details of battery categories handled, annual production or import volume (in metric tonnes), and — for recyclers — the relevant authorisation under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 from the concerned State Pollution Control Board (SPCB). Maharashtra-based operators must additionally comply with Maharashtra Pollution Control Board (MPCB) conditions on storage and processing.

Once registered, producers must file an annual EPR action plan by 30 June of each financial year for the year ahead, and an annual return by 30 June of the following year detailing actual collection and recycling achieved. CPCB cross-references action plan commitments with recycler-submitted data, so a mismatch between what a producer claims and what its recycling partner reports will trigger a compliance flag — and increasingly, a show-cause notice.

Refurbishment vs Recycling: A Distinction That Changes Your EPR Maths

The Battery Waste Management Rules, 2022 make a deliberate distinction between refurbishment and recycling, and misclassifying the two can quietly erode your EPR target fulfilment. Under the Rules, a refurbished battery is one that has been repaired or partially rebuilt to restore performance — it re-enters commerce. A recycled battery has been dismantled and its constituent materials (lead, lithium, cobalt, nickel, electrolyte) extracted and processed. Only recycling generates EPR credits under Rule 10.

Why Refurbishment Does Not Count Towards Recycling Targets

Several EV fleet operators and telecom tower companies in Karnataka and Telangana have been refurbishing lithium-ion battery packs — swapping cells, replacing battery management systems — and internally accounting for this activity as “recycling” in their sustainability reports. Under the Battery Waste Management Rules, 2022, this is non-compliant. Refurbishers must register separately on the CPCB portal, pay a refurbishment fee (Schedule IV), and may only extend battery life; they may not generate recycling credits. When the refurbished battery eventually reaches end-of-life, it must go to a registered recycler for credit generation.

The commercial implication is material. If you are a fleet operator in Chennai managing a 500-unit EV fleet, and you have been routing spent battery packs to a refurbisher rather than a registered recycler, your entire EPR credit position may be zero — regardless of what your sustainability team has filed internally. For our EPR compliance services, this distinction between eligible recycling and ineligible refurbishment is one of the most common corrective actions we help clients address before an audit.

Penalties and Enforcement: What Non-Compliance Costs in FY 2026

The Battery Waste Management Rules, 2022 do not themselves specify a discrete penalty schedule — instead, enforcement flows through the parent statute, the Environment (Protection) Act, 1986. Under Section 15 of that Act, a first offence carries a fine of up to ₹1 lakh and/or imprisonment of up to five years. For each day the violation continues after the first conviction, an additional ₹5,000 per day is chargeable. Where the violation persists beyond one year from the first conviction, imprisonment can extend to seven years. These are not civil penalties — they are criminal provisions, and they apply to the company’s officers in charge, not merely the legal entity.

In practice, CPCB’s enforcement pathway begins with a show-cause notice, followed by a direction under Section 5 of the Environment (Protection) Act, 1986, requiring the entity to take specific corrective action within a stipulated time. Failure to comply with a Section 5 direction is what triggers criminal proceedings. Recent CPCB enforcement actions in FY 2024-25 have included directions to battery producers to either demonstrate recycling of shortfall quantities within 90 days or deposit an environmental compensation amount calculated at a notified rate per kilogramme of shortfall — a provision inserted in the battery EPR credit framework to quantify the cost of missing targets.

For lead acid battery EPR specifically, the stakes are compounded by the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, which classify spent lead-acid batteries as listed hazardous waste. Routing spent lead-acid batteries through unregistered channels is simultaneously a violation of both the battery waste management rules 2022 and the hazardous waste rules — a dual liability that has caught several automotive aftermarket distributors in Gujarat off-guard in recent enforcement cycles.

Lithium-Ion Supply Security and the Recycler’s Rising Role

India currently imports nearly all of its lithium and a significant share of its cobalt requirements from overseas — a strategic vulnerability that the NITI Aayog has flagged in its reports on India’s EV transition. The recycled-content mandate embedded in the Battery Waste Management Rules, 2022 is partly an industrial policy instrument: by requiring battery manufacturers to incorporate a minimum 5% recycled material in new EV batteries from FY 2025-26, MoEFCC is seeding a domestic secondary materials market. This is expected to rise to 20% by FY 2030-31 under the Rules’ long-term schedule.

The commercial arithmetic here is straightforward. An EV battery pack for a mid-range passenger car contains roughly 8-12 kg of lithium carbonate equivalent, 10-15 kg of cobalt compounds, and 30-50 kg of nickel compounds. With lithium carbonate prices on the London Metal Exchange having experienced sharp swings between 2022 and 2024, the ability to source recycled lithium domestically — even at a modest price premium — de-risks procurement for battery manufacturers such as those supplying the growing EV passenger vehicle segment in Pune, Chennai, and Bengaluru.

CPCB-authorised recyclers who can demonstrate lithium recovery rates above 85% and issue BIS-traceable material quality certifications are already being approached by battery manufacturers seeking to fulfil the recycled-content mandate. This positions compliant recyclers not merely as waste handlers but as supply-chain partners — a structural shift in how the industry will work through the next decade. Our metal scrap recycling services, which already handle lead recovery from automotive batteries, are being extended to accommodate lithium-ion battery dismantling as volumes from the EV sector begin to materialise at scale.

Your FY 2026 Battery EPR Compliance Checklist

With Q2 FY 2025-26 already underway, the window for course-correction before annual return deadlines is tightening. The following checklist covers the minimum actions battery producers, importers, EV manufacturers, and bulk consumers should complete this quarter.

1. Verify CPCB portal registration is active and current. Log in to batterywaste.cpcb.gov.in, confirm your registration certificate is valid, and update any changes in battery categories handled or annual volume estimates. Expired or stale registrations are treated as non-registration under Rule 6.
2. Cross-check your recycler’s authorisations. Confirm that every recycler you are using holds (a) CPCB Battery Waste EPR portal registration as a recycler, and (b) a valid authorisation under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 from their state SPCB. Request certified copies — do not rely on verbal assurances.
3. Separate refurbishment volumes from recycling volumes in your records. Maintain distinct tonnage registers for batteries sent to refurbishers versus recyclers. Only the latter generates EPR credits. Review your FY 2025-26 action plan to ensure your credit procurement covers the full shortfall.
4. File or confirm your FY 2025-26 EPR action plan submission. The deadline is 30 June of the financial year in which the targets apply. If your plan has not been submitted or acknowledged on the CPCB portal, file it immediately — late filing is itself a compliance gap.
5. Map your EPR credit gap against the Schedule I targets. Calculate the weight of batteries placed on market in FY 2024-25, apply the relevant FY 2025-26 target percentage (e.g., 80% for lead-acid automotive), and compare against credits already secured. If a gap exists, procure additional EPR certificates from registered recyclers before 31 March 2026.
6. Audit your bulk consumer supply chain (if applicable). Fleet operators, telecom companies, and data centre operators consuming 100 or more batteries annually must channel all spent batteries to registered dealers or recyclers. Confirm your logistics partner holds the necessary SPCB storage authorisation.
7. Prepare BRSR and sustainability disclosures. Listed companies must disclose battery waste generation, EPR target adherence, and recycling credentials under SEBI’s Business Responsibility and Sustainability Reporting (BRSR) Core framework (SEBI circular dated 12 July 2023). Align your CPCB data with your BRSR disclosures before the annual report cycle opens.
8. Retain all documentation for five years. Rule 5(1)(d) of the Battery Waste Management Rules, 2022 requires producers to maintain records of EPR fulfilment, recycler certificates, and collection data for a minimum of five years, available for CPCB inspection on demand.

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Frequently Asked Questions

Who is required to register under the Battery Waste Management Rules, 2022?

Under Rule 6 of the Battery Waste Management Rules, 2022, registration on the CPCB Battery Waste EPR portal is mandatory for battery producers (manufacturers and brand owners), importers, recyclers, refurbishers, and bulk consumers (entities using 100 or more batteries annually). Registration must be completed before placing batteries on the market or commencing processing operations. There is no registration fee, but operating without valid registration exposes entities to enforcement under the Environment (Protection) Act, 1986.

What is the EPR target for EV (lithium-ion) batteries in FY 2025-26?

Under Schedule I of the Battery Waste Management Rules, 2022, the EPR collection and recycling target for EV (lithium-ion) batteries is 25% of the weight of batteries placed on market in FY 2024-25, applicable in FY 2025-26. This is the first year the target applies to the EV category. Additionally, a recycled-content mandate of 5% is triggered from FY 2025-26, requiring new EV battery manufacturers to incorporate a minimum 5% recycled material sourced from CPCB-registered domestic recyclers.

What are the penalties for non-compliance with battery EPR targets?

The Battery Waste Management Rules, 2022 enforce penalties through the parent Environment (Protection) Act, 1986. Under Section 15, a first offence attracts a fine of up to ₹1 lakh and/or imprisonment of up to five years. Continuing violations incur an additional ₹5,000 per day after the first conviction. Violations persisting beyond one year from first conviction carry imprisonment of up to seven years. CPCB may also direct deposit of environmental compensation calculated per kilogramme of EPR target shortfall before criminal proceedings are initiated.

Does battery refurbishment count towards EPR recycling targets?

No. The Battery Waste Management Rules, 2022 explicitly distinguish between refurbishment and recycling. Refurbishment — repairing or rebuilding a battery to restore performance for re-use — does not generate EPR recycling credits under Rule 10. Only certified recycling, where a battery is fully dismantled and its constituent materials are extracted and processed by a CPCB-registered recycler, qualifies for EPR credit generation. Refurbishers must register separately on the CPCB portal and are governed by a distinct fee and compliance regime under Schedule IV of the Rules.

How long must battery EPR compliance records be retained?

Under Rule 5(1)(d) of the Battery Waste Management Rules, 2022, producers, importers, recyclers, and refurbishers must retain all records relating to EPR target fulfilment — including recycler certificates, EPR credit certificates, collection data, and annual return filings — for a minimum of five years. These records must be made available for inspection by CPCB or the concerned State Pollution Control Board upon demand. For companies subject to SEBI’s BRSR Core reporting requirements, the same documentation also feeds annual sustainability disclosures.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered B2B recycling and scrap trading company with pan-India operations across Maharashtra, Gujarat, Delhi-NCR, Karnataka, Tamil Nadu, and Telangana. Our battery waste management services are built for the compliance demands that the Battery Waste Management Rules, 2022 place on producers, importers, EV manufacturers, and bulk consumers — not for ceremonial documentation.

We work with CPCB-authorised battery recycling partners who hold valid authorisations under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, ensuring that every EPR credit certificate we facilitate is audit-proof. Our documentation is GST-compliant, BRSR-grade, and structured to align with the annual return formats required by the CPCB Battery Waste EPR portal. For clients with large lead-acid battery inventories — automotive fleets, telecom tower operators, UPS manufacturers — we offer scheduled collection with fair-market pricing referenced to prevailing lead recovery rates. For lithium-ion battery volumes emerging from EV fleets and consumer electronics, we provide full chain-of-custody documentation from collection to material recovery.

Our services include:

• Pan-India battery collection and logistics for producers, importers, and bulk consumers
• EPR credit certificate procurement from CPCB-registered recyclers — matched to your Schedule I target obligation
• Pre-audit EPR documentation review and gap analysis
• GST-compliant invoicing and full chain-of-custody records
• Certificate of Recycling / Destruction issued per batch for BRSR and internal sustainability reporting
• BRSR-grade material flow documentation for listed companies
• Fair-market pricing for lead, lithium-ion, and other battery chemistries indexed to current recovery rates

To discuss your FY 2026 battery EPR compliance position or schedule a collection, contact us today. You can also learn more about our broader EPR compliance services and how we support producers across e-waste, plastic, and battery waste categories.

Sources and References

• Central Pollution Control Board (CPCB) — Battery Waste EPR portal and regulatory notifications
• Ministry of Environment, Forest and Climate Change (MoEFCC) — Battery Waste Management Rules, 2022 gazette notification
• CPCB — Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016
• NITI Aayog — India EV transition and critical mineral supply security reports
• Bureau of Indian Standards (BIS) — Battery and material quality standards
• London Metal Exchange (LME) — Lithium, cobalt, and nickel price benchmarks
• CPCB — E-Waste (Management) Rules, 2022 portal and EPR registration
• Business Standard and Economic Times — press reports on CPCB enforcement actions in FY 2024-25 (battery EPR sector)