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Battery Waste EPR in India — Who Is Actually Liable, and What Buyers Should Ask For
Last updated: · Written by the Leolus Energy compliance and engineering team, Bangalore.
Read time: 8 min · Who this is for: Anyone who manufactures, imports, rebrands or buys battery packs in volume in India
The misconception this article exists to fix
Almost every week someone tells us that battery recycling is "the recycler's problem" or "the manufacturer's problem". It is neither. Under the Battery Waste Management Rules notified in August 2022, the legal duty to ensure a battery gets collected and recycled at end of life attaches to whoever put it on the Indian market under their name.
That definition is deliberately broad. It catches the company importing a hundred power banks a year just as squarely as the company manufacturing millions of automotive batteries. If you import finished packs and put your logo on them, you are a producer. If you commission an Indian factory to build packs to your specification and sell them as your product, you are a producer. The recycler is a separate registered entity you buy services from — they discharge your obligation, they do not own it.
What the rules actually cover
The scope line is unusually clean. The rules apply to all types of batteries regardless of chemistry, shape, volume, weight, material composition and use. Lead-acid, lithium-ion, LFP, NMC, nickel-metal-hydride, sodium-ion — all in. Batteries are then grouped into categories that determine which targets apply to you.
| Category | Typical examples |
|---|---|
| Portable | Power banks, handheld instruments, POS terminals, portable printers, drone packs sold as standalone items, consumer electronics packs |
| Automotive | Starter batteries and packs for road vehicles |
| Industrial | Telecom backup strings, energy storage systems, UPS banks, solar street-light packs, industrial equipment packs |
| EV | Traction packs for electric vehicles |
Categorisation is not cosmetic. It determines your target schedule and the recycling evidence you have to produce, so getting it wrong at registration causes a mess later.
How the obligation is actually calculated
This is the part people find counter-intuitive, so it is worth walking through slowly.
You do not get handed a target. You declare your sales volumes on the CPCB portal, and the portal computes your target from those declarations using the formulae in the rules. Targets are applied with a deliberate time lag relative to the year of sale, because a battery sold today does not become waste today — it becomes waste after its service life. So the obligation you are discharging this year relates to batteries you sold several years ago.
Two consequences follow, and both catch people out:
- Your declarations are the basis of everything. Under-declaring sales to reduce a target is not a clever tax optimisation; it is a false declaration on a government portal, and the numbers are cross-checkable against your own GST filings.
- Growth is a liability generator. A company that grew fast three or four years ago inherits a target computed on those larger volumes, arriving at a time when it may have very little visibility into where those batteries physically went.
For FY 2025–26, producers of portable, automotive and industrial batteries are in a 100% collection obligation year. If you have been treating EPR as a filing formality, this is the year that stops being viable.
Finding a legitimate recycler
Only recycling evidence from a registered recycler counts. There is a large informal battery-breaking economy in India, and paperwork from it is worth nothing on the portal — worse, routing lithium waste through informal handling is genuinely dangerous, because a damaged cell in an unventilated shed is a fire waiting to happen.
The authorised list is published on the CPCB EPR Battery portal at eprbattery.cpcb.gov.in. Filter by state and battery category, then contact the recycler directly. We deliberately do not publish a curated list of names here, because registrations lapse and get added continuously, and a stale list on a supplier's website is how people end up sending waste to an entity that is no longer authorised. Go to the source.
When you speak to one, ask three things: are you currently registered for my battery category, what documentation do you issue that satisfies portal upload, and do you collect or do I ship. The third question determines your logistics cost, and lithium waste has transport restrictions that ordinary scrap does not.
If you buy packs rather than produce them
You are probably not the producer of record — but you should still care, for two reasons.
The first is continuity of supply. A supplier who is non-compliant is carrying an unquantified liability, and enforcement action against them becomes your delivery problem. Asking for an EPR registration number during vendor qualification costs you one line in a questionnaire.
The second is end-of-life logistics. When your equipment reaches end of service, someone has to deal with the packs inside it. A supplier who already has a recycler relationship can usually fold take-back into the supply arrangement. A supplier who has never thought about it will leave you holding a pallet of degraded cells and no route to dispose of them legally.
A short vendor questionnaire you can copy
- What is your EPR registration number on the CPCB Battery portal, and under which producer categories are you registered?
- Which registered recycler do you route waste through, and are they registered for the category of battery you supply me?
- Do you offer take-back for packs supplied under this contract, and at what cost?
- What documentation will you issue me at end of life, and is it in a form I can upload as evidence?
- If I export equipment containing your packs, who handles the compliance position in the destination market?
Why any of this is worth the effort
Beyond the legal exposure, there is a materials argument that is becoming hard to ignore. India imports the overwhelming majority of its lithium cells. Every recovered kilogram of lithium, cobalt and nickel is a kilogram that does not have to be imported, and the material-specific recovery targets in the rules exist precisely to build that domestic loop. A functioning collection system is not a compliance cost centre in the long run; it is the beginning of a cell supply chain.
Regulatory requirements and target schedules change. This page reflects our reading of the position as of August 2026 and is written as operational guidance, not legal advice. Verify current obligations directly on the CPCB EPR Battery portal and with the Battery Waste Management Rules as amended before acting.