What is Battery?
“Battery” means new or refurbished cell and/or battery and/or their component, including accumulator, which is any source of electrical energy generated by direct conversion of chemical energy and includes disposable primary and/or secondary battery.
What does ‘Waste Battery’ include?
Waste Battery includes:
(i) Used and/or end-of-life battery and/or its components or spares or parts or consumables which may or may not be hazardous in nature;
(ii) Pre-consumer off-spec battery and its components or spares or parts or consumables;
(iii) Battery whose date for appropriate use has expired;
(iv) Battery which has been discarded by the user.
What is the meaning of EPR?
EPR stands for “Extended Producer Responsibility”, which means responsibility of any Producer of Battery for environmentally sound management of waste battery.
What are EPR targets for Producers/Manufacturers?
EPR target is the quantity of battery placed in the market by the Producer/Manufacturer. Details are given in Schedule II of the Battery Waste Management Rules, 2022.
Who all come under the definition of ‘Producer’?
“Producer” means an entity who engages in:
(i) Manufacture and sale of battery including refurbished battery, including in equipment, under its own brand; or
(ii) Sale of battery including refurbished battery, including in equipment, under its own brand produced by other manufacturers or suppliers; or
(iii) Import of battery as well as equipment containing battery.
Does manufacturer of battery need to obtain registration from CPCB?
As per Rule 4(4), the person or entity involved in manufacturing of battery shall have to register through the online centralized portal as Producer in Form 1(A). The certificate of registration shall be issued in Form 1(B).
Does importer of battery need to obtain registration from CPCB?
As per Rule 3(1)(u), importer of battery as well as equipment containing battery will be called “Producer”. The importer has to obtain registration from CPCB to carry out import activities related to battery.
Which entities shall register on the online portal developed by CPCB?
The following entities shall register on the online portal developed by CPCB:
(i) Producer (Importers come under the definition of Producer as per Rules)
(ii) Manufacturers of Battery
(iii) Recyclers and Refurbishers
What are the documents required for KYC for registration of Producers / Manufacturers?
PDF copy of Company’s PAN, CIN & GST of the Producer/Manufacturers.
Is registration provided by CPCB to importers of lead-acid batteries under Batteries (Management and Handling) Rules, 2001 still valid?
No. Importers have to obtain fresh registration from CPCB to carry out any import activities related to battery as well as equipment containing battery.
Which type of batteries are covered under the Battery Waste Management Rules, 2022?
All types of batteries regardless of chemistry, shape, volume, weight, material composition and use.
In case of Proprietorship/Partnership, under company details, what should be provided in PAN?
PAN of the authorized person is to be provided.
When will the Importer be liable for EPR obligations?
Importers shall have EPR obligations under the following conditions:
a. Importers who sell the imported battery in the market under their own brand name.
b. Importers supplying the imported battery to other manufacturers/dealers and the manufacturers/dealers sell those batteries under the brand name provided by the importer.
c. Importers supplying the imported battery directly to bulk consumers.
d. Importers selling the imported battery in the market under the name of the brand imported.
When will the Importer NOT be liable for EPR obligations?
Importers shall not have EPR obligations under the following condition:
a. Importers supplying the imported battery to other manufacturers/dealers and those manufacturers/dealers sell the batteries in the market under their own brand name.
Do the Dealers of Battery have to register with CPCB/SPCB?
a. If the dealer purchases the battery from a manufacturer or producer and sells the battery under its own brand name, the dealer will be called a Producer and must register with CPCB and will have EPR obligations.
b. If the dealer purchases or supplies the battery from manufacturer/producer and sells under the brand name provided by the manufacturer or producer, the dealer is not required to obtain CPCB/SPCB registration.
Do exporters of battery need to register with CPCB and have any EPR obligations?
If the company/brand is not placing the battery in the Indian market, it will not have EPR obligations.
Do manufacturers using battery as a component (UPS, inverters, medical equipment, emergency lights, instruments, signage, printers, etc.) fall under Producer definition?
a. If a manufacturer uses a battery as a component and sells under its own brand, it will have EPR obligations and must register as Producer.
b. If the battery is provided by another battery manufacturer/producer, then it will not have any EPR obligations.
Where can I find the EPR Registration Certificate?
There is no separate registration certificate for EPR. Registration is granted under Form 1(B) of the Rules.
We manufacture batteries and supply to manufacturers only. Do we need CPCB registration?
As per Rule 4(4), manufacturer of battery has to register as Producer with CPCB.
Do manufacturers of battery have EPR obligations?
I. Manufacturers shall have EPR obligations if:
a. They sell batteries under their own brand name.
b. They supply batteries to other manufacturers/dealers who sell under the original manufacturer’s brand name.
c. They supply batteries directly to bulk consumers.
II. Manufacturers shall NOT have EPR obligations if:
a. They supply batteries to other manufacturers/dealers who sell under their own brand name.
As per Battery Waste Management Rules, 2022, are users/consumers required to submit returns?
Consumers/users are not required to submit annual or half-yearly returns. However, if a brand/company/user imports batteries for in-house use, registration with CPCB is mandatory and EPR obligations apply. Annual returns must be submitted by 30th June.
Where can I find the list of registered recyclers and refurbishers?
The list can be obtained through SPCBs/PCCs.
We refurbish batteries and sell under our own brand. Will we have EPR obligations?
Yes. Such entities are considered “Producers”, must register with CPCB, and will have EPR obligations.
What documents are required while applying for registration?
Refer to SOP provided on CPCB website.
In Form 1(A), what brand name should be mentioned for imported batteries?
Importer shall mention their own brand name(s) and not the brand name of the battery imported.