Three Changes in Twelve Months — And Most Businesses Haven’t Caught Up
Between February 2025 and February 2026, India’s Extended Producer Responsibility (EPR) framework for battery and electronic waste underwent three discrete but interconnected structural changes: a gazette amendment reshaping labelling obligations, a unified Single Sign-On (SSO) portal consolidating all EPR access, and the rollout of a regulated electronic trading platform for EPR certificates. Layered on top are escalating collection targets for FY 2025-26 and a looming recycled-content mandate effective FY 2027-28. If your compliance strategy is still anchored to the original Battery Waste Management (BWM) Rules, 2022, you are operating on an outdated map.
The February 2025 Gazette Amendment: What Actually Changed
The Battery Waste Management Amendment Rules, 2025 were published in the Official Gazette on 24 February 2025 (notification S.O. 958(E)) and came into force on the same date. This was the fifth amendment to the principal rules since their original notification as S.O. 3984(E) on 22 August 2022 — following S.O. 4669(E) (October 2023), G.S.R. 190(E) (March 2024), S.O. 2374(E) (June 2024), and S.O. 5210(E) (December 2024).
The February 2025 amendment focused on three specific areas:
1. QR Code and Barcode Labelling as a Digital Alternative
Producers can now satisfy mandatory EPR marking requirements by printing a barcode or QR code containing their EPR registration number on one of five permissible locations: the battery or battery pack itself, the equipment containing the battery, the retail packaging of the battery, the retail packaging of the equipment, or bulk packaging not intended for retail sale. Alternatively, the EPR registration number can be printed on the product information brochure. CPCB will publish and maintain a consolidated, quarterly-updated list of all producers opting for the digital labelling route. This digital alternative significantly reduces the physical labelling burden — particularly for importers handling diverse product lines — while preserving full traceability.
2. Packaging Exemption Under Legal Metrology Rules
Packaging covered under Rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2011 is now exempt from certain EPR labelling requirements under Schedule I. Producers should audit their packaging formats to determine whether this exemption applies to any of their SKUs and document the basis for any exemption claim, as CPCB inspections may require written justification.
3. Relaxed Hazardous Substance Marking Thresholds
For batteries with cadmium content at or below 0.002% (20 ppm) or lead content at or below 0.004% (40 ppm), the obligation to mark ‘Cd’ or ‘Pb’ on the battery has been removed. This is a meaningful cost and design relief for manufacturers of modern lithium-ion cells where trace cadmium and lead fall within these thresholds, though compliance teams must conduct chemistry-specific verification before discontinuing any existing markings.
The February 2026 SSO Portal: One Login, All Portals
On 18 February 2026, CPCB launched a Single Sign-On (SSO) portal that consolidates access to all EPR compliance portals under a single login at epr.cpcb.gov.in. The SSO covers the EPR portals for Battery Waste Management, E-Waste Management, Plastic Waste Management, Waste Tyre Management, Used Oil Management, and End-of-Life Vehicles (ELV).
For businesses with obligations across multiple waste streams — for example, an EV importer liable under both battery and e-waste rules — this is operationally significant. Registration, return filing, and certificate transfers across all six portals can now be managed through a single authenticated session. CPCB has also uploaded FAQs and user manuals directly on the SSO portal. Existing users who experience login issues are advised to use the ‘Forget Password’ feature and re-login with dedicated email IDs and mobile numbers linked to their CPCB accounts.
EPRETP: The Formal EPR Certificate Trading Exchange
A structural change with significant commercial implications is the introduction of EPRETP — the EPR Electronic Trading and Settlement Platform — operated under CPCB oversight by MSTC Limited. EPRETP functions as a regulated digital marketplace for the listing, buying, and settlement of EPR certificates across all notified waste streams, including battery waste and e-waste.
Under the EPRETP architecture, the SSO portal manages identity verification and registration approvals; waste-specific EPR portals continue as the source of certificate issuance and validity; and EPRETP handles trading, price discovery, and settlement. The platform enforces role-based access control and requires mandatory KYC and verified bank account linkage. Crucially, prices are discovered exclusively through exchange-based orders — bilateral price negotiation outside the platform is not permitted.
This has direct implications for how companies procure EPR credits. The informal, off-portal arrangements that some businesses previously relied on are no longer compliant. CPCB’s monitoring systems now cross-check every certificate against the issuing recycler’s registered capacity in real time, flagging oversubscribed certificates and rejecting filings that rely on them.
FY 2025-26 Collection Targets: The 100% Threshold Is Here
Under the progressive compliance model established by Schedule II of the BWM Rules, 2022, FY 2025-26 marks a significant escalation point. Producers of portable, automotive, and industrial batteries are now in a year where collection obligations are at their highest to date. Separately, under the E-Waste (Management) Rules, 2022, established producers face a recycling target of 70% of waste generation obligation for FY 2025-26, up from 60% in FY 2024-25, with the target stepping up further to 80% from FY 2026-27 onwards. New producers must meet 20% of FY 2023-24 sales volumes.
The annual return for e-waste (Form EPR-1) for FY 2025-26 is due by 30 June 2026. CPCB has previously extended similar deadlines — FY 2024-25 returns were extended to 15 August — but businesses should not plan around extensions that have not been formally announced.
EV Battery Second-Life and the FY 2027-28 Recycled Content Mandate
Two forward-looking provisions that compliance teams must begin planning for now:
EV Battery Second-Life Declarations
Batteries with remaining capacity above 70% of original can be repurposed in stationary energy storage applications rather than entering the recycling stream immediately. However, such second-life usage must be formally declared to CPCB. Importantly, this declaration does not extinguish the producer’s eventual recycling obligation — it defers it. Auto OEMs, battery importers, and energy storage companies must build second-life declaration workflows into their compliance programmes.
Mandatory Recycled Content From FY 2027-28
The 2025 amendments introduced a phased recycled content mandate: from FY 2027-28, producers manufacturing batteries in India will be required to incorporate a minimum percentage of recycled material derived from domestically recovered sources. This means recycling is no longer just a disposal mechanism — it becomes an integral input into battery supply chains. Businesses that have not yet built relationships with CPCB-authorised recyclers are now running behind on supply chain planning.
Penalties and Enforcement: What Non-Compliance Costs
Non-compliance with EPR obligations triggers Environmental Compensation (EC) charges calculated on the shortfall in declared recycling targets. These are not discretionary — they are legally mandated and collected through the CPCB portal and cannot be offset by purchasing EPR certificates after the fact. Under Section 15 of the Environment (Protection) Act, 1986, initial monetary penalties begin at ₹1,00,000 with an additional ₹5,000 per day of continued delay, escalating up to ₹1 crore. CPCB can also halt production or import operations until compliance is restored. Repeated non-compliance may result in public disclosure of defaulting entities and exclusion from government tenders for one to five years.
Immediate Action Checklist for Producers, Importers, and Recyclers
- Migrate to SSO login: Ensure all authorised users in your organisation are registered and active on epr.cpcb.gov.in — the dedicated portals now route through SSO for all transactions.
- Audit your labelling: Review whether your battery products and packaging carry a valid EPR registration number via QR code, barcode, or brochure as required by the February 2025 amendment. Verify cadmium and lead content levels against the new thresholds.
- File FY 2025-26 e-waste returns by 30 June 2026: Confirm quarterly returns (Q1 through Q4) have been sequentially filed before attempting the annual return.
- Verify your EPR certificates: Before purchasing credits through EPRETP, confirm the issuing recycler is active and within their registered processing capacity on the portal — oversubscribed certificates will be rejected.
- Plan for the recycled content mandate: Audit your battery supply chains now to identify domestic CPCB-authorised recyclers capable of supplying verified recycled material from FY 2027-28.
- Declare EV battery second-life use: If any of your EV batteries are being repurposed, ensure written declarations are filed with CPCB before the relevant annual return period closes.
ACPL’s regulatory experts can help you navigate battery waste and e-waste EPR compliance, including registration, annual return filing, EPR certificate procurement, and the transition to the new SSO and EPRETP platforms. Contact us at info@acplgroupindia.co.in or call +91-9266665201 for a consultation.