✅ 50-Point EPR Compliance Checklist for Battery Producers (India)
📅 Updated: July 2025
📍 Based on Battery Waste Management Rules, 2022
🔖 Tags: EPR Compliance, CPCB, Battery Waste Rules, Legal Checklist, CPCB Portal, Battery Producers India
🔋 Introduction
With the enforcement of the Battery Waste Management Rules, 2022, the Government of India has strengthened the accountability of battery manufacturers, importers, assemblers, and brand owners. All such entities are now bound by Extended Producer Responsibility (EPR) norms, making them responsible for the entire life cycle of batteries placed in the market.
To simplify compliance and avoid hefty penalties, we've created a comprehensive 50-point checklist to help battery producers navigate their EPR obligations efficiently.
📘 Governing Law
- Battery Waste Management Rules, 2022
- Enacted under the Environment (Protection) Act, 1986
- Nodal Agency: Central Pollution Control Board (CPCB)
📋 Full 50-Point Compliance Checklist
| ✅ Sr. | Compliance Area | Checkpoint | Legal Provision |
|---|---|---|---|
| 1 | EPR Registration | Registered on CPCB Portal | Rule 4(1) Battery Waste Management Rules, 2022 |
| 2 | EPR Registration | Uploaded GST certificate | Rule 4(2) Battery Waste Management Rules, 2022 |
| 3 | EPR Registration | Uploaded PAN card | Rule 4(2)Battery Waste Management Rules, 2022 |
| 4 | EPR Registration | Authorized Signatory Details | Rule 4(2) Battery Waste Management Rules, 2022 |
| 5 | Product Declaration | Battery type declared (portable, EV) | Schedule I Battery Waste Management Rules, 2022 |
| 6 | Product Declaration | Chemistry declared (Li-ion, Lead Acid) | Schedule I Battery Waste Management Rules, 2022 |
| 7 | Product Declaration | Weight & capacity submitted | Schedule I Battery Waste Management Rules, 2022 |
| 8 | Product Declaration | Previous FY sales quantity declared | Rule 4(5) Battery Waste Management Rules, 2022 |
| 9 | EPR Target | EPR target calculated | Rule 5(1) Battery Waste Management Rules, 2022 |
| 10 | EPR Target | Internal tracking mechanism in place | Rule 5(2) Battery Waste Management Rules, 2022 |
| 11 | Reverse Logistics | Plan prepared | Rule 6(2) Battery Waste Management Rules, 2022 |
| 12 | Reverse Logistics | Uploaded logistics info | Rule 6(2) Battery Waste Management Rules, 2022 |
| 13 | Reverse Logistics | Collection points established | Rule 6(3) Battery Waste Management Rules, 2022 |
| 14 | Reverse Logistics | Take-back details shared with customers | Rule 6(3) Battery Waste Management Rules, 2022 |
| 15 | Recycler Tie-up | Recycler MoU signed | Rule 7(3) Battery Waste Management Rules, 2022 |
| 16 | Recycler Tie-up | Recycler's authorization uploaded | Rule 8(2) Battery Waste Management Rules, 2022 |
| 17 | Recycler Tie-up | Agreement uploaded to portal | Rule 8(2) Battery Waste Management Rules, 2022 |
| 18 | Recycler Tie-up | Valid recycler license maintained | Rule 8(2) Battery Waste Management Rules, 2022 |
| 19 | Q1 Return | Filed by 30th July | Rule 8(3) Battery Waste Management Rules, 2022 |
| 20 | Q2 Return | Filed by 30th October | Rule 8(3) Battery Waste Management Rules, 2022 |
| 21 | Q3 Return | Filed by 30th January | Rule 8(3) Battery Waste Management Rules, 2022 |
| 22 | Q4 Return | Filed by 30th April | Rule 8(3) Battery Waste Management Rules, 2022 |
| 23 | Annual Return | Filed by 30th June | Rule 8(4) Battery Waste Management Rules, 2022 |
| 24 | Returns Filing | Recycler certificates included | Rule 8(4) Battery Waste Management Rules, 2022 |
| 25 | Returns Filing | Take-back records included | Rule 8(4) Battery Waste Management Rules, 2022 |
| 26 | Documentation | Sales invoices maintained | Rule 9(1) Battery Waste Management Rules, 2022 |
| 27 | Documentation | Battery movement logs maintained | Rule 9(1) Battery Waste Management Rules, 2022 |
| 28 | Documentation | Battery traceability records kept | Rule 5(6) Battery Waste Management Rules, 2022 |
| 29 | Documentation | Recycling certificates preserved | Rule 8(4) Battery Waste Management Rules, 2022 |
| 30 | Documentation | MoUs with recyclers preserved | Rule 8(2) Battery Waste Management Rules, 2022 |
| 31 | Labeling | Take-back info printed on labels | Rule 10(2) Battery Waste Management Rules, 2022 |
| 32 | Labeling | Disposal instructions on packaging | Rule 10(2) Battery Waste Management Rules, 2022 |
| 33 | Labeling | Safety warnings displayed | Rule 10(2) Battery Waste Management Rules, 2022 |
| 34 | Consumer Awareness | Website includes disposal guidance | Rule 10(3) Battery Waste Management Rules, 2022 |
| 35 | Consumer Awareness | Awareness campaigns conducted | Rule 10(3) Battery Waste Management Rules, 2022 |
| 36 | Consumer Awareness | Retailers informed about EPR | Rule 10(3) Battery Waste Management Rules, 2022 |
| 37 | Internal Systems | EPR Officer appointed | Best Practice |
| 38 | Internal Systems | Compliance tracking via ERP | Best Practice |
| 39 | Internal Systems | Quarterly internal audit done | Best Practice |
| 40 | Internal Systems | Real-time updates on portal | Rule 8(3) Battery Waste Management Rules, 2022 |
| 41 | Legal Validity | Recycler is CPCB authorized | Rule 7(1) Battery Waste Management Rules, 2022 |
| 42 | Legal Validity | Portal profile regularly updated | Rule 4(2) Battery Waste Management Rules, 2022 |
| 43 | Audit Ready | Checklist maintained | Rule 9(1) Battery Waste Management Rules, 2022 |
| 44 | Audit Ready | Files available for inspection | Rule 9(1) Battery Waste Management Rules, 2022 |
| 45 | Audit Ready | Historical compliance files stored | Rule 9(1) Battery Waste Management Rules, 2022 |
| 46 | Audit Ready | Response to show-cause notices prepared | EPA, 1986 |
| 47 | Penalty Avoidance | Timely returns filed | Rule 8(3), 8(4) Battery Waste Management Rules, 2022 |
| 48 | Penalty Avoidance | EPR target achieved fully | Rule 5(4) Battery Waste Management Rules, 2022 |
| 49 | Penalty Avoidance | No environmental compensation imposed | EPA, 1986 |
| 50 | Penalty Avoidance | No CPCB warnings or suspensions | Rule 4(7) Battery Waste Management Rules, 2022 |
📥 Download the Editable Excel Checklist
Use this checklist to monitor your company’s compliance readiness:
⚠️ Penalties for Non-Compliance
Failure to comply may result in:
-
Environmental compensation
-
Suspension of EPR registration
-
Legal prosecution under Environment (Protection) Act, 1986
🟢 Final Words
This checklist is a powerful internal tool for battery producers, importers, and brand owners to avoid penalties and ensure sustainability compliance. Adopt these checkpoints and stay on the right side of the law.
♻️ Let’s make compliance a habit, not a burden!
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