Who is affected and what they must do
The rules place obligations on producers, and also set requirements for recyclers and refurbishers, who must register and report the quantities they process. Producers must establish collection and take-back arrangements, meet their obligations through registered entities and file returns on the portal.
Obligations are calculated from battery quantities placed on the market in earlier years, with targets that increase over time. Minimum use of domestically recycled materials in new batteries is also phased in. Non-compliance can lead to environmental compensation, so obligations should be tracked through the year rather than at the deadline.
- Register as a producer on the CPCB EPR portal
- Set up collection and take-back channels
- Work only with registered recyclers and refurbishers
- File returns supported by EPR certificates
Running compliance through the year
A simple quarterly rhythm prevents most problems. Producers review quantities placed on the market, compare certificates received against the obligation and plan collections to close any gap. Registered recyclers generate certificates on the portal based on verified recycled weight, and those are transferred to the producer.
State Pollution Control Boards also play a role in consents and inspections for processing sites. Keeping manifests, weighbridge records and certificates organised makes inspections and audits straightforward.
| Activity | Owner | Frequency |
|---|---|---|
| Review quantities placed on market | Producer | Quarterly |
| Plan collections against obligation | Producer and recycler | Quarterly |
| Generate EPR certificates | Registered recycler | Per processed quantity |
| File returns on the portal | Producer | As required by CPCB |
Field note