News Alert
MoEFCC has issued revised Battery Waste Management Rules with enhanced Extended Producer Responsibility targets, a centralised EPR portal for certificate trading, and stricter penalties for non-compliance.
Revised EPR Targets and Coverage
The Ministry of Environment, Forest and Climate Change has notified the Battery Waste Management (Amendment) Rules 2026, which significantly increase the Extended Producer Responsibility (EPR) collection and recycling targets for battery manufacturers, importers, and brand owners. For lithium-ion batteries used in electric vehicles and consumer electronics — the fastest-growing category — the EPR collection target for FY 2026-27 has been set at 40% of batteries placed on the market in the preceding three financial years, up from the earlier 30% target.
The revised rules expand the scope of "producers" subject to EPR obligations to include e-commerce marketplace operators who sell batteries or battery-containing products. Marketplaces that act as "sellers of record" for imported batteries are now directly responsible for ensuring EPR compliance, rather than being able to rely entirely on individual vendors. This change significantly expands the EPR compliance universe and requires e-commerce platforms to implement systems to track battery sales and attribute EPR obligations to the appropriate marketplace entity.
Centralised EPR Certificate Portal
MoEFCC has launched a centralised EPR certificate portal — hosted by the Central Pollution Control Board (CPCB) — for the registration, issuance, and trading of EPR certificates. Producers must register on the portal before April 1, 2026 and submit a complete inventory of batteries placed on the market in FY 2025-26. The portal enables producers who have collected more batteries than required by their EPR target to sell surplus EPR certificates to producers with shortfalls, creating a market-based mechanism that improves the overall economics of battery collection.
The EPR certificate trading mechanism requires that all transactions be recorded on the centralised portal and that the transfer of certificates is authenticated by both the buyer and seller. Certificates must be used within the same financial year or the following year — they cannot be carried forward indefinitely. Producers whose EPR obligations exceed their collection capacity should explore certificate purchases early in the financial year, as the portal history from FY 2025-26 suggests that surplus certificates become scarce in Q3 and Q4 as producers rush to meet year-end targets.
Penalties and Enforcement
The Amendment Rules introduce a tiered penalty structure for EPR non-compliance. Producers who fall short of their EPR target by up to 20% are liable to an environmental compensation of Rs 2,000 per tonne of uncollected battery waste. Shortfalls of 20% to 50% attract Rs 5,000 per tonne, and shortfalls above 50% attract Rs 10,000 per tonne plus a potential suspension of the producer's EPR registration. Repeated non-compliance over two consecutive years can result in cancellation of product-specific import licences and restrictions on domestic manufacturing.
Companies subject to Battery Waste EPR obligations should conduct a mid-year EPR compliance review by September 2026 to assess their collection performance against the annual target. If a shortfall is projected, corrective actions — intensifying collection campaigns, engaging CPCB-authorised battery recyclers, or purchasing EPR certificates — should be implemented with sufficient lead time before the year-end deadline. EPR compliance is now increasingly scrutinised by institutional investors as part of ESG due diligence, adding reputational dimensions to the regulatory compliance imperative.
This regulatory update is provided for general information purposes. It does not constitute legal or tax advice. Please consult a qualified advisor before taking any action based on this information.