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  • End-to-end assistance regarding any query related to a quarterly compliance filing
  • Prompt solutions for all your business-related problems
  • Complete legal assistance at every step
  • Accurate dealing with authorities and PCBs for seamless proceeding of your requirements

General overview of the quarterly compliance for a battery recycler

Batteries are indeed expensive but have a relatively short life span. As discarded batteries surge by the tonnage, entrepreneurs are lured to start a battery recycling business. Battery recycling has been in demand for many years due to waste legislation mandates and increased environmental awareness.

With the rise in environmental sensibility, attention is being paid to the sustainable management of natural resources. Besides, the concern for hazardous and e-waste, including waste batteries, is also increasing. Various regulations have been implemented over time, and as per these rules, batteries are tagged as hazardous. One such regulation was the Battery Waste Management Rules, 2022. The rules promote effective and efficient recycling of waste batteries before final disposal. This can be achieved by performing the following tasks in order of priority:

  1. Recovery of valuables from wastes (if possible).
  2. Placing producer and importer of batteries at the centre of battery recycling guidelines with Extended Producer Responsibility (EPR).
  3. The producers can fulfil the EPR obligations with the help of recyclers. The recyclers can offer the EPR certificates to the producer in exchange for waste batteries.

In addition, the rules stipulate various functions of several entities involved in the battery recycling business. For instance, the rules mandate that recyclers and refurbished abide by quarterly compliance for a battery recycling business. Other roles and responsibilities are briefed in the following sections.

Functions of recycler as per the BWM Rules, 2022

  1. Battery recyclers must submit the quarterly returns in Form 4 providing the information on the number of waste batteries received or collected from various producers or entities, compliance with material-wise recovery percentage according to the recovery targets stated in sub-rule 4 of rule 10, recycled quantities,quantity of hazardous and/or other waste including plastic or solid waste generated after recycling and of such quantity according to the BWM rules, 2022. The quarterly return must be filed by the month's end following the end of the quarter.
  2. All recyclers must register with the SPCBvia the online portal. The registration certificate must be issued in Form 2(B).
  3. The recycler also stands responsible to –
    • Submit Form 2(A) to the SPCB for a grant of one-time registration;
    • Make sure that the hazardous waste produced is managed according to the Hazardous & Other Wastes (Transboundary Movement and Management) Rules, 2016;
    • Make sure that all activities are performed according to the CPCB guidelines;
    • Make sure that battery recycling businesses and activities abide by the rules and regulations stated by CPCB; and
    • Guarantee that other waste produced during recycling and handling must be managed according to theE-waste (Management) Rules, 2016, SWM Rules, 2016 and Plastic Waste Management Rules, 2016.
  4. Ensure that the waste battery is removed from collected equipment if a battery is included in the appliance.
  5. Besides filing the quarterly compliance, the battery recycler must also not deal with any other facility which is not registered as per these rules.
  6. The total count of waste battery processed by the battery recycling unit must be made available quarterly on the portal created by CPCB andon the entities' websites.
  7. The BWM Rules, 2022 also hold the CPCBresponsible for deciding the fee for processing applications, quarterly returns, registration and annual returns.

What is the need for battery recycling?

Setting up battery recycling is indeed advantageous. The recycling process helps to reduce toxic materials that otherwise end up in landfills in huge quantities and in return, pollute the environment. Interestingly, even the NITI Aayog has also emphasized the need for battery recycling units. Indeed, there are several benefits associated with this.


  • Materials such as cadmium, lead acid and lithium-ion are counted as some of the most dangerous environmental pollutants. If not recycled properly, they end up in a house in many forms affecting your life and health.
  • Moreover, recycling batteries is an easy and innovative way to decrease costs and reward you with a profit margin.
  • Protects human health and the environment.
  • Battery recycling also helps to extract raw materials from used batteries. These are then sent to manufacturing firms for reuse. This, in return, reduces the cost of new batteries.
  • Recycling waste batteries implies conserving natural and other resources while decreasing the ever-increasing need for raw materials.

Form 4 for quarterly compliance for a battery recycler

As per the newly introduced Battery Waste Management Rules, 2022, a recycler must submit a quarterly return in Form 4. The following details must be provided in the form –

  • Name of the recycler
  • Registered address
  • Email id
  • Phone number
  • Name of the authorised person
  • GST Number
  • Registration Number with SPCB
  • Capacity of recycling unit(s) (in MTA)
  • Details of waste battery collected from different facilities, including producer(s)
  • Details of waste battery recycled or refurbished
  • Details of waste disposed of and generated during refurbishing or recycling operations
  • EPR certificate details

The detailed process of filling the quarterly compliance for a battery recycler

  • The battery recycler must submit quarterly compliance by the end of the month, succeeding by the end of the quarter. One copy of the quarterly compliance must be submitted to the SPCB, and one must be sent to CPCB.
  • CPCB must create an online system for the filing and registration by recyclers, producers and refurbishers of waste batteries within six months of the commencement of the rules.
  • The SPCB will also use this portal for registering units involved in the refurbishing and battery recycling business and for the registration of producers.
  • This portal would serve as the single-point data repository regarding guidelines and orders for implementing BWM rules.

The system must guarantee a process wherein the material balance of waste battery according to the EPR obligations of producers is reflected. The portal must also reflect the information regarding auditing the entities and producers involved in waste battery recycling.

Provision of certificate for battery waste

  • The waste battery recycling business registered under the BWM rules must give a certificate for waste battery processing.
  • The certificate for a waste battery provided by registered entities must be given for the quantity and type of battery recycled or refurbished. However, this can be transacted to meet EPR obligations.
  • In no situation, the amount of recycled waste battery by the facility must be more than the unit's installed capacity. These certificates will be for waste battery category-wise and shall include the GST data of the entity.
  • Central Pollution Control Board will provide for issuing such certificates online.

EPR Certificates

Besides filing quarterly compliance by a battery recycler, the BWM Rules, 2022 mandated obtaining an EPR certificate. Given below are the details of the same -

  • EPR certificates for battery waste recycling business are generated depending on the geographical source of battery obtained, such as imported or domestic, percentage fulfilment of material recovery targets for a particular year and weight of the processed battery.
  • CPCB will generate EPR certificates through the centralised online portal based on the recycled waste battery quantities allotted to recyclers. However, the recyclers can offer the granted EPR certificates to the producer in return for the waste battery.
  • Given below is the formula to be used to evaluate the EPR certificates for recyclers:

EPR certificates (in kg) = [Actual recovery of battery materials (in percentage) / Recoverytarget for the mentioned year of the battery type (in percentage)] x quantity of battery processed (kg) x (1-A).

Note: A=0 or 0.2 for waste battery sourced through imports permitted as per the Hazardous and Other Wastes (Transboundary Movement &Management) Rules, 2016.

  • A Surplus Extended Producer Responsibility certificate under recycling can be used for recycling.
  • EPR certificates bought by the producer must be automatically adjusted against their liability. However, EPR certificates used by the producer to meet EPRobligations can’t be exchanged again.
  • Thus, the recyclers must record and submit all such transactions on the online portal while filing quarterly compliance for a battery recycler.
  • The certificates generated by the recycler remain valid for seven years to meet the producer's obligations.

How can Enterclimate help you?

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