Battery & E-Waste EPR: India’s 2025–26 Compliance Shake-Up

CPCB Freezes EPR Certificate Exchange from 1 April 2026 — What You Need to Know Now

If your business manufactures, imports, or brands batteries or electronic equipment in India, a critical operational change took effect on 1 April 2026: the Central Pollution Control Board (CPCB) has suspended the exchange of EPR certificates on its battery waste portal, with a statement that it “shall revert on this shortly.” At the same time, CPCB has consolidated access across all its waste-stream portals by launching a unified Single Sign-On (SSO) platform at https://epr.cpcb.gov.in. These two changes, taken together, signal a significant administrative reset that has direct implications for how producers and recyclers manage their compliance returns for FY 2025–26.

This post focuses specifically on the Battery Waste and E-Waste EPR frameworks — two distinct but closely related compliance obligations — and covers the latest regulatory targets, the February 2025 amendment to the Battery Waste Management Rules, upcoming deadlines, and the real-world consequences of non-compliance.

Regulatory Backdrop: Two Separate but Parallel Frameworks

Battery Waste Management Rules, 2022 (BWM Rules)

The Battery Waste Management (BWM) Rules, 2022, notified by the Ministry of Environment, Forest and Climate Change (MoEFCC) on 22 August 2022, replaced the old Batteries (Management and Handling) Rules, 2001. They apply to all types of batteries regardless of chemistry, shape, volume, weight, material composition and use — covering EV batteries, portable batteries, automotive batteries, and industrial batteries. Producers (manufacturers and importers) bear the primary EPR obligation for batteries they introduce into the Indian market.

A significant update followed: the Battery Waste Management Amendment Rules, 2025, issued by MoEFCC on 24 February 2025, introduced two key changes. First, it clarified that packaging materials covered under Rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2011 are exempt from certain packaging obligations under the BWM Rules. Second, and more practically impactful, producers must now print barcodes or QR codes displaying their EPR registration number on batteries and product information brochures — tightening traceability and making paper-only compliance impossible.

E-Waste (Management) Rules, 2022

The E-Waste (Management) Rules, 2022, effective from 1 April 2023, govern electrical and electronic equipment (EEE). Every stakeholder — producer, manufacturer, refurbisher, and recycler — must register on the dedicated CPCB portal at eprewastecpcb.in. Critically, in 2026 the e-waste portal has been integrated with GST and Customs (ICEGATE) data, making it technically difficult for producers to underreport sales volumes.

Escalating Recycling Targets: FY 2025–26 and FY 2026–27

Battery Waste Targets

For portable and automotive batteries, Schedule II of the BWM Rules mandates a minimum collection and recycling target of 70% of the quantity placed in the market in the corresponding preceding year for FY 2025–26 and FY 2026–27. For material recovery specifically, the rules set a trajectory from 80% material recovery by 2026 rising to 90% by FY 2026–27 onwards for EV and portable batteries. Automotive and industrial batteries face a 60% material recovery target by FY 2026–27.

For EV batteries, the framework is structured by vehicle type (two-wheeler, three-wheeler, four-wheeler) with differentiated phase-in schedules. By FY 2027–28, producers must ensure 70% collection of EV batteries placed in the market. Looking further ahead, from FY 2027–28, new batteries manufactured in India must incorporate a minimum of 5% recycled content derived from domestically recovered materials, scaling up to 20% by FY 2030–31.

E-Waste Targets

Under the E-Waste (Management) Rules, 2022, the recycling target for most IT and consumer electronics producers stands at 70% of the sales figure from the relevant preceding year (Y-X) for FY 2025–26 and FY 2026–27, stepping up to 80% from FY 2027–28 onwards. Targets for FY 2026–27 are calculated based on sales data from two to five years prior depending on product category, as set out in Schedule I of the rules. Recyclers must now also possess Zero-Liquid Discharge (ZLD) and Advanced Material Recovery (AMR) facilities to maintain their authorisation.

CPCB SSO Portal Migration: Immediate Action Required

As of 18 February 2026, CPCB launched a unified Single Sign-On (SSO) portal to provide consolidated access across six EPR portals: ELV, Used Oil, Plastic Waste, Battery Waste, Waste Tyre, and E-Waste Management. All stakeholders must now log in exclusively through https://epr.cpcb.gov.in. FAQs and user manuals have been uploaded on this common portal. Businesses that have not yet migrated their login credentials to the SSO system risk being locked out of return-filing workflows — a serious compliance risk given the annual return deadline.

The suspension of EPR certificate exchange on the Battery Waste portal from 1 April 2026 adds further urgency. Producers who had not purchased sufficient EPR certificates before this freeze to cover their FY 2025–26 obligations may face a compliance gap. CPCB has indicated it will advise on the timeline for resumption.

Who Must Register — and What Documents Are Required

Under the BWM Rules, producers, recyclers, and refurbishers of all battery types must register on the CPCB portal — regardless of size or production volume. Recyclers and refurbishers must additionally register with the concerned State Pollution Control Board (SPCB) through the same centralised portal. For e-waste, the obligation extends to manufacturers, importers, brand owners, and e-commerce sellers of EEE listed in Schedule I of the 2022 Rules.

Documents required for producer registration typically include:

• Company PAN, GST registration certificate, and CIN
• Details of battery or EEE types (by category, chemistry, and sales volume)
• MoU with a CPCB-registered recycler or refurbisher
• EPR registration number (for QR/barcode printing on products under the 2025 amendment)
• Board resolution or authorisation letter for the signatory

Government processing time for new registrations is typically 30 to 60 working days. Incomplete or inaccurate applications may be rejected outright, delaying market entry. Importers must note that absence of a valid EPR registration can result in customs clearance delays at Indian ports.

Return Filing Deadlines and Reporting Obligations

Under the BWM Rules, compliance reporting is structured as follows:

• Form 3 (Annual Return for Producers): Filed annually with CPCB detailing waste battery collected, recycled, or refurbished.
• Form 4 (Quarterly Returns for Recyclers/Refurbishers): Filed every quarter with sales data and corresponding EPR certificate generation.
• Annual EPR Return for E-Waste (Form 3): Due by 30 June of the following financial year.
• Half-yearly compliance return: Due by 31 October.

A real-world illustration of the risks: a Gujarat-based battery distributor that imported approximately 3,200 tonnes of lithium batteries in FY 2024–25 purchased EPR certificates for only 140 tonnes. When the company attempted to file its annual return, the CPCB portal flagged the compliance gap, delaying approval by nearly 50 days. This case underlines the importance of calculating recycling obligations accurately at the start of each financial year and purchasing certificates well before the filing deadline.

Environmental Compensation: The Penalty Mechanism

Non-compliance triggers Environmental Compensation (EC) under the Polluter Pays Principle. The CPCB portal has built-in mechanisms to calculate EC amounts based on the quantum of unfulfilled recycling obligations. Crucially, paying EC does not extinguish the underlying obligation — the shortfall must still be addressed in subsequent years.

The carry-forward regime works as follows: unfulfilled EPR obligations may be carried forward for up to three years. Partial fulfillment within that window attracts partial EC refunds — 75% refund if fulfilled within one year, 60% within two years, and 40% within three years. After three years, the full EC amount is forfeited. For recyclers who fail to meet obligations, penalties can escalate to suspension of registration or prosecution under Section 15 of the Environment (Protection) Act, 1986, which allows for fines of up to ₹1,00,000 and imprisonment of up to five years, or both.

Practical Takeaways for Producers and Importers in FY 2026–27

1. Migrate immediately to the CPCB SSO portal at https://epr.cpcb.gov.in if you haven’t already. Use the “Forgot Password” feature if credentials are lost.
2. Assess your FY 2025–26 EPR certificate position now, given the suspension of the certificate exchange mechanism from 1 April 2026. Contact CPCB at 011-43102350 for guidance on resolution timelines.
3. Ensure QR/barcode labelling compliance per the February 2025 amendment — your EPR registration number must appear on all batteries and product brochures placed in the Indian market.
4. Calculate your FY 2026–27 recycling obligation early based on relevant preceding-year sales data, and enter into or renew MoUs with CPCB-registered recyclers well before year-end.
5. Recyclers and refurbishers should verify their ZLD and AMR facility status to avoid authorisation suspension, which directly affects the producers relying on them for EPR credits.
6. EV battery producers should map their collection targets by vehicle type against the BWM Rules Schedule and begin planning for the 5% recycled content mandate that kicks in from FY 2027–28.
7. File annual returns on time — e-waste producers by 30 June 2026 for FY 2025–26 — and maintain accurate material flow records to withstand CPCB audits.

ACPL’s regulatory experts can help you navigate Battery Waste and E-Waste EPR compliance. Contact us at info@acplgroupindia.co.in or call +91-9266665201 for a consultation.