EVBatteryRecycling
Guide · Compliance & EPR

India BWMR 2022: A Producer's Compliance Walkthrough

The Battery Waste Management Rules 2022 make producers responsible for collecting and recycling an escalating percentage of the batteries they place on the market.

PN

Priya Nair

EPR & Compliance Lead

3 min read Updated 2025-07-04
Close-up of a hand scanning a QR code on an EV battery module label

The short answer

The Battery Waste Management Rules 2022 make producers responsible for collecting and recycling an escalating percentage of the batteries they place on the market. Obligations are discharged by transferring waste to a registered recycler and acquiring EPR certificates on the CPCB portal.

On this page4 sections

Key takeaways

  1. 1The Battery Waste Management Rules 2022 place Extended Producer Responsibility on anyone placing batteries on the Indian market.
  2. 2Producers, recyclers and refurbishers must register on the CPCB centralised online portal.
  3. 3Obligations are met by purchasing EPR certificates generated by registered recyclers and refurbishers.
  4. 4Non-compliance can attract environmental compensation.
01

Who the rules apply to

The Battery Waste Management Rules 2022, notified by the Ministry of Environment, Forest and Climate Change, apply to producers of batteries, which includes manufacturers, importers and brand owners who sell batteries or equipment containing them in India. Electric vehicle batteries are a defined category, alongside portable, automotive and industrial batteries.

Recyclers and refurbishers that process waste batteries also fall within the rules and must register. Consumers, fleets and workshops are expected to hand waste batteries to registered entities rather than informal channels. The Central Pollution Control Board administers the system through a centralised online portal.

02

Registration and targets

Producers must register on the CPCB portal before placing batteries on the market and must report the quantities they sell. Their collection and recycling obligations are calculated from those quantities using the schedules in the rules, which set targets that rise over time and allow for the expected life of each battery category.

The rules also set minimum recovery requirements for recyclers and introduce obligations on the use of domestically recycled materials in new batteries, phased in over the coming years. Because schedules and portal procedures are updated through amendments and CPCB guidance, producers should check the current version of the rules when planning each year's compliance.

  • Register on the CPCB portal before sale
  • File quantities placed on the market
  • Meet category-specific EPR targets each year
  • File annual returns within the prescribed timelines
03

How EPR certificates work

Registered recyclers and refurbishers generate EPR certificates on the portal for the quantity of waste batteries they process, based on verified records. Producers then acquire those certificates to meet their obligations. The portal tracks certificate generation and transfer so that the same quantity cannot be claimed twice.

For a producer, the practical task is to secure enough certificates of the right category each year, usually through agreements with registered recyclers. Keeping records of collection, transport, processing and certificate transfers is essential, as these may be examined during audits or inspections.

PartyMain responsibility
ProducerRegister, report sales, meet EPR targets via certificates
RecyclerRegister, process waste batteries, generate certificates, meet recovery requirements
RefurbisherRegister, refurbish batteries, generate certificates where permitted
CPCBOperate portal, oversee compliance, levy environmental compensation
Who does what under BWMR 2022

Field note

Buy certificates only from recyclers registered on the CPCB portal and keep the transfer records.
Questions

Frequently asked questions

Do importers of EVs have obligations?

Yes. Importers of batteries, including batteries fitted in vehicles, are treated as producers under the rules and must register and meet EPR obligations.

What happens if targets are missed?

The rules provide for environmental compensation on unmet obligations, alongside other enforcement measures. Compensation does not remove the underlying obligation.

Can refurbishment count towards obligations?

Refurbishment is recognised within the framework, subject to the conditions set out in the rules and CPCB guidance. Check current guidance for how refurbishment certificates are treated.

Turn this into a plan for your packs

Send pack counts, chemistry and approximate state of health. You get an indicative value split, a slotted collection window and pre-filled dangerous goods paperwork.

Run the yield calculator
Keep reading

More on compliance & epr