Introduction of EPR Battery 

In 2024, the estimated size of India's Battery Market is USD 7.20 billion. It is expected to reach USD 15.65 billion by 2029, with a growth rate of 16.80% CAGR from 2024 to 2029.

With the increasing need for batteries, it is essential to properly handle battery waste in order to prevent harm to the environment. This is the reason why, just 2 years ago, the Indian Government had chosen to establish guidelines for handling battery waste.

The Ministry of Environment Forest and Climate Change announced the Battery Waste Management (BWM) Rules on 22nd August 2022. Based on these regulations, all individuals or entities producing batteries must register with the Central Pollution Control Board (CPCB).

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EPR and Its Significance

Extended Producer Responsibility (EPR) is a policy method that makes producers responsible for their products throughout their entire lifecycle, including their retrieval, recycling, and ultimate disposal. This is particularly important for batteries because of their environmental consequences. An EPR Battery certification indicates that a company is meeting these obligations.

What Do The Battery Waste Management (BWM) Rules Entail?

The Battery Waste Management Rules of 2022 pertain to every type of battery, regardless of their shape, size, weight, usage, chemical composition, and material makeup. The responsibility of Extended Producer Responsibility is placed on Producers (manufacturers and importers) of batteries that they release into the market according to these regulations. Thus, the Producer must achieve the collection and recycling goals to fulfill EPR responsibilities.

Producers and manufacturers of batteries must follow the Rules by registering themselves with CPCB through its centralized online portal. Producer registration must be completed using Form 1(A) The Form 1 (B) will be given as the certificate of registration.

In case of any modifications to the details in the EPR Registration, the producer must notify the CPCB. To renew EPR Registration, Form 1(A) must be submitted within 60 days before its expiration. The Producers/Manufacturers are required to submit Annual Returns by June 30 of the following year for the registration period in between. Failure to submit all required annual reports will result in the renewal application not being processed.

Battery manufacturers must obtain EPR certificates from recyclers based on the amount of recycled waste batteries, using these certificates to achieve their EPR goals. Battery waste must be sent for recycling or refurbishing, not for landfilling or incineration, as stated in the BWM Rules.

Read Our Blog: EPR For Battery Waste Management Rules, 2022

What Are The Precise Requirements For EPR Registration?

Producers/manufacturers registered with EPR must adhere to specific requirements.

• Battery producers or manufacturers must obtain EPR registration through CPCB's centralized online portal to conduct business.
• The producers or manufacturers must only work with entities registered on CPCB's online portal to fulfill EPR targets.
• If CPCB discovers that a producer or manufacturer registered with them has given inaccurate information, intentionally hidden information, or breached the conditions of EPR registration under the Battery Waste Management Rules, 2022, their registration will be terminated for one year following a chance to explain themselves.
• Battery producers must meet the EPR Target specified in Schedule II of the BWM Rules, 2022, every year and according to categories.
• Producers and manufacturers must adhere to the Battery Waste Management Rules, 2022 provisions. If they do not follow these rules, appropriate action will be taken against them.

Terms And Conditions That Apply To Registered Entities.

Entities registered with the CPCB must adhere to the regulations outlined in the Environmental (Protection) Act of 1986 and its accompanying rules. In case of any alterations in the approved EPR form, they must be promptly communicated to the CPCB.

Steps to Surrender ERP Battery Certificate    

Comprehend the Regulations Needed

• Laws and Regulations: Become knowledgeable about the particular laws and rules regarding Extended Producer Responsibility (EPR) for batteries in your country. An example is the Waste Batteries and Accumulators Directive in the European Union, which offers specific instructions.
• Regulatory Authority: Determine the appropriate environmental regulatory body. This may be a governmental organization on a national or local level that oversees EPR adherence.

Evaluate Your Responsibilities

• Certificate Conditions: Thoroughly examine the terms and conditions outlined in your EPR certificate. There might be certain circumstances or times when giving up is allowed
• Compliance Status: Make sure that you have fulfilled all your EPR responsibilities, such as reporting, fee payments, and battery waste management, by the date of surrender.

Get all required paperwork ready for the task

• Compliance Records: Collect all compliance records, such as previous reports, payment receipts, and documentation of efforts in managing battery waste.
• Surrender Form: Get the official surrender form from the governing body. This document will usually need specific details about your company, the certificate number, and the reason for giving up.

Request to surrender must be submitted

• Complete the Form: Fill out the surrender form completely and accurately. Make sure all information is accurately inputted to prevent any delays.
• Attach Documents: Include all necessary supporting documents, such as compliance records and evidence of meeting all EPR requirements, when submitting.
• Method of submission: Send the filled-out form and accompanying documents through the specified method of choice, which may include online email or postal submission.

Follow-Up

• Confirmation: Upon submission, ask for a confirmation receipt or acknowledgment from the regulatory authority.
• Communication: Keep in touch with the regulatory authority for any further questions or additional needs.
• Record Keeping: Keep duplicates of all documents and communication that you submit for your own records.

Notify Stakeholders

• Update Partners: Notify pertinent stakeholders, such as business partners and customers, about the surrender of your EPR certificate.
• Update your Record: Check your EPR status to make sure that your business records and public information are up to date.

Wrap up financial and legal issues

• Settlement of Financing: Payment of outstanding fees or financial obligations associated with your EPR certificate is required.
• Legal Advice: Seek legal counsel if necessary to deal with any legal consequences of giving up the certificate.

What Reasons Could Lead To The Cancelation Of EPR Registration?

Producers and manufacturers with EPR registration may have their registration revoked if they fail to adhere to the BWM Rules, 2022. Several factors may result in the termination of EPR Registration.

• If the documents from the producers or manufacturers are determined to be untrue, the EPR registration may be revoked or put on hold at any point.
• If producers or manufacturers do not meet the EPR requirements outlined in Schedule II, the Central Pollution Control Board has the authority to revoke or terminate EPR registration.
• If a registered entity breaches the Battery Waste Management Rules, 2022, the Central Pollution Control Board has the authority to suspend or revoke the producer's EPR registration and may also enforce environmental compensation.
• Producers or manufacturers will have a chance to present their case within 15 days after receiving notice before CPCB can decide on cancelling/suspending their Registration.
• The Appellate Authority for this case is the Joint Secretary or an equivalent officer in the Ministry of Environment, Forest and Climate Change.

Read Our Blog: How to Surrender The EPR Plastic Certificate

Conclusion

Handing in your EPR Battery certificate involves paying close attention to regulatory specifics and thorough documentation. By adhering to the steps provided in this manual, you can guarantee that the procedure is executed seamlessly and by all applicable rules. If you face any challenges or doubts, it is recommended to seek assistance from the regulatory authority or consult with a legal expert who specializes in environmental compliance.