Extended Producer Responsibility for Batteries

Extended Producer Responsibility (EPR) makes producers responsible for the environmentally sound management of products after they become waste. Waste batteries are governed by the Battery Waste Management Rules, 2022, while scheduled electrical and electronic equipment is governed by the E-Waste Management Rules, 2022. Both frameworks use registration, quantified targets and certificates to assign responsibility to producers.

Scope and regulated producers

The battery rules cover portable, automotive, industrial and electric-vehicle batteries, including batteries contained in equipment, irrespective of chemistry, shape, weight or material composition. The e-waste rules cover electrical and electronic equipment listed in Schedule I, but exclude waste batteries covered by the battery rules.

• A battery producer includes an entity manufacturing and selling batteries under its own brand, selling under its brand batteries made by others, or importing batteries or equipment containing batteries.
• An e-waste producer broadly includes own-brand manufacturers or sellers and importers of electrical and electronic equipment, including importers of used equipment.
• The battery rules exclude batteries used in equipment connected with essential security interests and equipment designed to be sent into space.

Obligations for waste batteries

A producer must register with the Central Pollution Control Board through the centralised portal and fulfil the collection, recycling or refurbishment targets prescribed in Schedule II.

• Prescribed quantities of waste batteries must be collected and sent only for recycling or refurbishment, not landfilling or incineration.
• Producers must use the prescribed minimum share of domestically recycled materials in manufacturing new batteries.
• Producers must maintain records and file prescribed returns through the online system.

Obligations for electrical and electronic equipment

Under the E-Waste Management Rules, 2022, a producer must register on the centralised portal and meet its prescribed recycling targets through registered recyclers.

• The producer fulfils EPR by purchasing and submitting EPR certificates generated in favour of registered recyclers for eligible quantities of e-waste recycled.
• Producers may engage producer responsibility organisations, collection centres, dealers or other entities, but this does not transfer their EPR liability.
• Producers must file prescribed returns and create awareness regarding e-waste management.

Compliance and enforcement

Certificates and portal-based reporting permit verification of recycling or refurbishment claims. Non-compliance can attract environmental compensation under the polluter-pays principle, and its payment does not extinguish the unfulfilled EPR obligation.