EPR for Battery

Key objectives of the BWM Rules, 2022:

• Promote a Circular Economy: Encourage the recovery of valuable materials and their use in new products.

• Ensure Sustainable Management: Prevent environmental pollution from hazardous battery waste.

• Establish a Clear Framework: Create a centralized online system for registration and reporting, managed by the Central Pollution Control Board (CPCB).

• Mandate Targets: Set specific, mandatory targets for collection, recycling, and material recovery for all producers.

Under the BWM Rules, 2022, the responsibility for EPR battery compliance falls on the “Producer.” This term is broadly defined and includes:

1. Manufacturers: Entities that manufacture and sell batteries, including in equipment, under their own brand.

2. Importers: Entities that import and sell batteries, including in equipment (like laptops, mobile phones, toys, or EVs), under their own brand.

3. Brand Owners: Entities that sell batteries, including in equipment, under their own brand but have them manufactured by other entities.

4. Refurbishers: Entities involved in the refurbishment of waste batteries.

5. Recyclers: Entities involved in the recycling of waste batteries.

If your business falls into any of these categories, you are legally required to register on the CPCB’s centralized EPR portal and fulfill your specific obligations.

The new EPR for battery rules are comprehensive and cover virtually every type of battery placed on the market. The rules classify them into four main categories:

• Portable Battery: Rechargeable or non-rechargeable batteries that are sealed, hand-carried, and used in appliances, electronics, or other devices. (e.g., AA/AAA cells, button cells, mobile phone batteries, laptop batteries, power banks).

• Automotive Battery: Batteries used only for starting, lighting, or ignition power in vehicles. (e.g., standard lead-acid car batteries).

• Electric Vehicle (EV) Battery: Batteries specifically designed to provide traction power to electric vehicles, such as those in e-bikes, e-scooters, electric cars, and e-buses.

• Industrial Battery: Any battery designed for industrial use, including those for backup power (UPS), telecommunications, or forklifts.

Understanding your battery category is the first step, as your EPR targets will be calculated based on the type and quantity you place on the market.

Gaining EPR battery waste certification (registration) is just the beginning. Your ongoing responsibilities are the core of the policy:

1. EPR Registration: You must register on the CPCB’s centralized online portal. This registration is a one-time process and is crucial for legally operating in the market.

2. Fulfilling EPR Targets: This is your most significant obligation. You are required to meet specific, mandatory targets for:

• Waste Battery Collection: You must ensure that a certain percentage of the batteries you sold in previous years is collected.

• Recycling or Refurbishment: The collected batteries must be sent to a registered recycler or refurbisher.

• Material Recovery: Recyclers must recover a minimum percentage of materials (like cobalt, nickel, lithium) from the waste.

These targets are progressive and increase annually, pushing the industry towards greater efficiency.

3. The EPR Certificate Model: You do not have to physically collect the waste yourself. The BWM Rules establish a “certificate” model:

• Registered Recyclers/Refurbishers process waste batteries and are “paid” by generating EPR certificates on the CPCB portal.

• Producers (like you) must “buy” these certificates from the recyclers/refurbishers to meet their mandatory EPR targets.

• This creates a clean, transparent, market-based system where producers finance the recycling industry.

4. Reporting and Filing: You are required to submit regular reports (annually) to the CPCB through the online portal, detailing the quantity of batteries you’ve placed on the market and the EPR certificates you’ve purchased to meet your targets.

5. Consumer Awareness: You must finance and organize public awareness campaigns to educate consumers on the importance of segregated waste battery disposal and where to deposit them.

While the battery EPR framework is a positive step, it presents significant administrative and logistical challenges for businesses:

• Complex Portal: The CPCB portal, while centralized, requires precise data entry and a clear understanding of all forms and annexures.

• Accurate Target Calculation: Calculating your EPR obligation (in tonnes) based on your past sales data, battery chemistry, and weight is a complex task.

• Document Management: Compiling all required legal and technical documents (GST, PAN, IEC, hazardous waste authorizations, etc.) is time-consuming.

• Finding Registered Recyclers: You must ensure you are purchasing EPR certificates only from CPCB-registered recyclers to ensure your compliance is valid.

• Audit & Reporting: Maintaining immaculate records for annual filings and potential CPCB audits is a major administrative burden.

• Risk of Non-Compliance: Failure to meet targets or register results in severe penalties, including “Environmental Compensation” (heavy fines) and potential restrictions on your business operations.

Legal Company Documents:

• PAN Card

• GST Certificate (covering all billing addresses)

• Certificate of Incorporation (CIN) or LLPIN

• Company Letterhead (for authorization)

Importer-Specific:

• Import Export Code (IEC) Certificate

Manufacturing-Specific:

• Consent to Operate (CTO) and Consent to Establish (CTE) from the State Pollution Control Board (SPCB)

• Hazardous Waste Authorisation (if applicable)

Technical Information:

• Detailed information on the types, chemistry, and weight of batteries you place on the market.

• Sales data for the past financial years (as required by the portal).

EPR Plan:

At Instacertify, we’ve refined the EPR battery certification process into a seamless, transparent, and efficient service. We handle the bureaucratic heavy lifting so you can focus on your core business.

Step 1: Free Consultation & Gap Analysis It starts with a call. Our EPR experts will understand your business model (Manufacturer, Importer, etc.), the types of batteries you handle, and your sales volume. We perform a gap analysis to identify all your obligations under the BWM Rules, 2022.

Step 2: Documentation & Strategy We provide you with a customized document checklist. Our team will meticulously review, prepare, and organize all required legal and technical files to ensure they are 100% correct and error-free, preventing any back-and-forth with the CPCB.

Step 3: Portal Registration & Application Filing We manage the entire application process on the CPCB’s centralized battery EPR portal. Our experienced filing team navigates the complex forms, uploads all documents, and submits your application accurately.

Step 4: Liasoning & Query Management If the CPCB raises any queries or requests additional information, we handle it. Our team liaises directly with the officials, provides prompt clarifications, and resolves any issues to ensure your application is processed smoothly.

Step 5: Securing Your EPR Registration Once the CPCB verifies your application, your EPR Registration (Certification) is granted. We deliver the official certificate to you, making you a fully compliant Producer.

Getting the EPR battery waste certification is only the first step. Your real challenge is the ongoing annual compliance. Instacertify is one of the few partners who will stand by you for the entire journey.

• Annual Target Management: We help you calculate your precise annual EPR targets for collection and recycling based on your sales data.

• EPR Certificate Sourcing: We connect you with our vetted network of CPCB-registered recyclers and refurbishers, helping you procure the necessary EPR certificates at competitive rates to meet your obligations.

• Annual Return Filing: We compile all your data (new batteries placed on market, certificates purchased) and file your mandatory annual returns on the CPCB portal, ensuring you are compliant year after year.

• Compliance Advisory: The rules for EPR are evolving. We keep you updated on all new amendments, notifications, and policy changes, ensuring you are never caught off guard.

• Audit Support: In the event of a CPCB audit, we provide full support by organizing your records and preparing all necessary documentation.

• Deep Domain Expertise: We live and breathe EPR. Our team has specialized knowledge of the BWM Rules, 2022, and the CPCB portal’s inner workings.

• End-to-End Solution: From the first document to your annual filings, we handle everything. You get a single, reliable partner for all your EPR battery needs.

• Speed and Efficiency: Our established process and relationships minimize errors and delays, getting you registered faster.

• 100% Transparency: You are kept informed at every stage. We believe in clear communication and no hidden fees.

• Pan-India Service: No matter where your business is located, our services are available across India.

• Peace of Mind: With Instacertify, you can be confident that your business is 100% compliant, protected from penalties, and contributing to a greener India.

Understanding the investment required for EPR battery compliance is crucial. The total cost and timeline can be broken down into three parts:

1. Registration Cost (Government & Professional Fees)

• Annual Turnover less than ₹5 Crore: ₹10,000

• Annual Turnover between ₹5 Crore and ₹50 Crore: ₹20,000

• Annual Turnover above ₹50 Crore: ₹40,000

2. Registration Timeline

• Document Preparation: 3 – 7 working days, depending on your document availability.

• Application Submission: 1 – 2 working days once all documents are in order.

• CPCB Review & Processing: This is the longest stage. The CPCB will review your application, which can take 4 to 10 weeks. This period includes time for any clarifications or query responses.

• Total Estimated Timeline: You can expect to receive your EPR Battery Waste Registration in approximately 4 to 10 weeks from the date of final application submission. Our expertise ensures there are no unnecessary delays from incorrect filing.

3. Ongoing Compliance Costs