EPR Registration for Battery Waste

In the past few years, the appetite for battery production and supply has grown on a tremendous scale. With limited non-renewable energy options, the world is pouring investments into coming up with sustainable storage options that will aid in the energy transition, one of which is electric batteries.  With their ability to store energy, they could aid in the transition as the world progressively substitutes power generated from fossil fuels with emissions-free electrification.
 

As an outcome of this fresh emphasis on sources of clean energy, the production and use of batteries are expanding. Yet, due to the country's massive increase in battery imports and production, there currently is no established procedure in place for disposing of the waste produced during the production process in a way that is environmentally safe.
 

Hence, it is crucial to have a proactive approach to address the issue of growing battery waste, for which the Government has introduced the Battery Waste Management Rules, 2022. With the objective to ensure that the used batteries are disposed of responsibly, the above-mentioned guidelines were introduced in August 2022, which replaced the Battery Management & Handling Rules, 2001.

The Extended Producer Responsibility or EPR initiative has been implemented by the Indian government, which calls for battery importers and producers to manage and dispose of the battery waste in a way that is environmentally conscious whilst simultaneously holding them accountable for the volume of waste they produce throughout the products' shelf lives. 
 

In light of this, it is the responsible party's obligation under the regulations to assure that batteries are recycled through CPCB-authorized recyclers and to acquire an EPR certificate from recyclers that reflects the quantity of batteries recycled. 
 

For the purposes of the guidelines and rules, waste batteries may include the used and/or end-of-life batteries and/or their components, spares, parts, or consumables, which could or couldn't be harmful; and Utilized and/or end-of-life batteries and/or their components or spares. 
 

Pre-consumer Off-Spec Battery, together with any of its spare parts, supplies, or components; Battery whose date of suitable usage has passed; and Batteries that have been abandoned by the user.

1. Registration of Producers and Importers: According to the aforementioned regulations, a producer is referred to as an entity that produces, sells, imports, and uses batteries, including used batteries, within devices, either its brand or a brand that has been produced by other suppliers or manufacturers. Every producer is responsible under EPR for collecting, recovering, and reconditioning spent batteries, as well as using recovered waste materials for producing new batteries. Rule 4 of the BWM Rules 2022, every producer and anyone or entity engaged in the production of batteries must register with the CPCB via a centralized online portal.
    

2. Registration of Refurbishers and Recyclers: The State Pollution Control Board requires that all recyclers and refurbishers register on the centralized portal to acquire a one-time registration.

1. Streamline Supply Chain and Waste Management: EPR authorization allows businesses to identify and improve points of weakness in the waste distribution system. This reduces overhead costs and places fewer demands on budget-conscious organizations. EPR license enables the accessibility of a definite framework that allows businesses to operate effectively while eliminating needless inefficiencies and expenses.
    
2. Optimise Waste Management Methods: EPR permission provides entities with greater clarity on how waste should be collected, handled, recycled, or disposed of. It enables them to reinforce their existing waste management structure while rendering it more effective and smoother.
    
3. Enhance Interaction with Affiliate Units: High costs are unavoidable in the early stages of EPR implementation. By strengthening collaboration with linked units, this can be reduced. Under EPR authorization, the company has a clear grasp of how to carry out waste management activities, such as directing battery waste to recycling and disposal facilities.
    
4. Higher Business Goodwill: The approval of EPR has a favorable impact on the company's image and goodwill. Having EPR certification at disposal indicates the business is devoted to environmentally friendly resource usage and lower waste generated by their battery products. To strengthen their reputation in the industry, most of the major players devote careful consideration to these standards.
    
5. Ensure Cost-Cutting in Waste Management: Waste management and cost-cutting are often viewed as incompatible, but EPR authorization can overcome complexities and make waste management more cost-efficient. This allows entities to focus on cost-efficient activities while maintaining productivity. 

• Copy of GST Registration Certificate
• PAN details of the person/business entity
• CIN of a business entity in the case of a company
• IEC certificate issued by the Ministry of Commerce & Industry for battery importers
• District Industries Center, DIC registration for units registered with DIC
• Aadhar & PAN of the authorized person
• Details of the battery sales during the previous fiscal years.
• Air and Water Act approval and other hazardous authorization issued by SPCB or PCB

1. Create of Login ID and Password with the CPCB Portal: The applicant must create login credentials on the EPR portal for battery waste (http://www.eprbatterycpcb.in/) by filling in basic details such as the name of the applicant entity, contact details, business data, official email address, and password.
    
2. Drafting of Application and Submission: After forming an account, the applicant will need to sign in and start the registration procedure by filling out the EPR registration form either as a manufacturer or recycler and attaching a PDF copy of any necessary documents. The applicant shall pay the application fees as applicable. 
    
3. Application Processing and Verification: The CPCB must examine and process the application after receiving it for EPR registration for battery waste. The whole process may take around 10-15 days for the application to be accepted or denied. If the application comes out to be incomplete during processing owing to an insufficient document or missing information, the applicant will be notified via the portal. However, if any fraudulent or irrelevant information or documents are included in the application, it will be denied, and the application money will be forfeited.
    
4. Grant of Authorization Certificate: Upon being approved by the CPCB, the EPR authorization for battery waste shall be issued on the website portal in a downloadable format bearing the signature of the Competent Authority. Once issued, the certificate shall be valid for 5 years starting from the date of registration.

Producers, Manufacturers, Recyclers have to submit a request for renewal 60 days before their registration expires, accompanied by the necessary documents. Then, CPCB will renew the authorization granted to the Producer for a term of five years within fifteen business days after receiving of complete application from the Producer. While granting renewal of the EPR registration certificate, the following shall be taken into consideration. Annual Returns must be completed by June 30th of the following year (by the rules) for the interim Registration term; otherwise, the application for renewal will not be entertained, and the Findings of the Audit completed by the CPCB.

EPR authorization acts as a basic requirement for the country's plastic and EEE producers. Holding EPR authorization means that responsible entities and persons must follow the underlying legislation of the relevant authorities to manage waste effectively. Hence, though it is a legal requirement for a business, EPR authorization could act for the benefit of the business by saving its costs and increasing its goodwill. If you require consultation, guidance, or assistance to obtain an EPR registration, feel free to contact Agile Regulatory.