Battery Waste Management Rules: EPR obligations for EV and inverter companies

The Battery Waste Management Rules, 2022 replaced the older lead-acid battery rules with an Extended Producer Responsibility framework covering all battery chemistries and all uses: portable, automotive, industrial and electric vehicle. The obligation falls on the 'producer', which is defined broadly enough to include companies that import batteries, sell them under their own brand, or sell equipment with batteries built in. That last point is what catches EV makers, inverter and UPS brands, solar storage companies and electronics importers who do not think of themselves as battery companies.

Who is a producer

• Manufacturers of batteries sold under their own brand.
• Importers of batteries, whether sold as spares or installed in equipment.
• Companies that sell equipment containing batteries under their brand, including electric two-, three- and four-wheelers, inverters, UPS systems, power tools, laptops and solar storage.
• Businesses that assemble packs from imported cells for sale in India.

What the obligation involves

Producers register on the CPCB Battery EPR portal and are assigned collection and recycling targets as a percentage of the batteries they placed on the market in earlier years, with the percentages rising over time as currently notified. The targets are met by purchasing EPR certificates from registered battery recyclers and refurbishers, who generate certificates for the quantity they process. Producers also carry minimum recycled-content obligations for new batteries that phase in over the coming years, and they must file an annual return by 30 June reporting batteries placed on the market and certificates acquired.

Why EV companies find this harder than it looks

For lead-acid batteries there is a mature reverse supply chain, and certificates are relatively easy to source. For lithium-ion packs the picture is different: recycling capacity is still growing, certificate prices move, and the quantity of a vehicle's battery that counts towards the target depends on how the pack is reported at registration. EV and storage companies also need to think about battery weight data by model, by chemistry and by year of sale, which most dealer and warranty systems were not designed to produce.

Your battery EPR target is set by what you sold two or three years ago. The time to understand it is before the compliance year begins, not when the portal shows a shortfall.

Non-compliance is enforced through environmental compensation, which is calculated on the shortfall and does not extinguish the obligation; the uncollected quantity carries forward. We register battery producers, work out the correct reporting of built-in batteries, source certificates from recyclers whose registrations and returns are in order, and file the annual return. If you also sell electronics, we align the battery filing with your e-waste and plastic EPR so the three regimes do not contradict each other.