# Does a battery recycler in India earn extended producer responsibility certificates for the waste batteries it imports?

Canonical: https://senseible.earth/answers/battery-imported-waste-no-epr-certificate

Not since October 2023. The 2022 Battery Waste Management Rules gave imported waste batteries 80% of the certificate a domestic battery earns, through a factor of 0.2. The October 2023 amendment replaced that: no extended producer responsibility (EPR) certificate is generated for imported waste batteries, which are accounted for separately.

## What the rule said in 2022 and what it says now

- 2022, rule 10(8): certificates in kilograms = (actual recovery of battery materials in percentage / recovery target for the year in percentage) x quantity of battery processed in kilograms x (1 minus A). A is 0 for waste battery generated domestically and 0.2 for waste battery sourced through imports allowed under the hazardous waste rules of 2016.
- October 2023, rule 10(8) as substituted: no EPR certificate shall be generated for the recycling or refurbishment of waste battery imported under the hazardous waste rules, and separate accounting shall be maintained and reported for imported waste battery.
- October 2023, rule 10(7) as substituted: certificates are generated on the weight of waste battery processed or refurbished and the weight of battery material produced, as per the Central Pollution Control Board (CPCB) guidelines. The old formula is no longer printed in the rule.

## A second change in the same amendment

The 2022 text had a table of minimum material recovery percentages in rule 10(4), with a four-yearly review in rule 10(5). The October 2023 amendment omits both sub-rules. I could not read the amendment text, so treat this as unconfirmed: the percentages may now sit in CPCB guidelines, not in the rule. Check the guidelines for the recovery level your certificates are measured against.

## What it means for a recycler

- The amendment does not itself stop imports under the hazardous waste rules. It stops the certificates.
- Keep imported and domestic batches in separate records from the gate onwards, because the rule asks for separate accounting.
- My inference, not rule text: certificates you sell trace to domestic waste, because none is generated for imported waste.

## What it means for a producer buying certificates

Certificates in the market come from domestic waste. A recycler's certificate is valid for seven years for meeting a producer's obligation, a producer may buy up to its liability plus leftover liability plus 10%, and a surplus certificate is used only within the same battery category.

## A recycler processes 1,000 tonnes in 2025-26, example

- Target for automotive batteries in the 2022 table: 60%. Actual recovery: 66%. Ratio 66 / 60 = 1.1
- Domestic waste: 1.1 x 1,000 x (1 minus 0) = 1,100 tonnes of certificates
- Imported waste under the 2022 formula: 1.1 x 1,000 x (1 minus 0.2) = 880 tonnes
- Imported waste since October 2023: 0 tonnes

The tonnage and the 66% are examples. The 60% is the 2022 rule 10(4) table figure for automotive batteries in 2025-26. The 2022 formula is shown only to explain what changed, and the 2022 table is the part the 2023 amendment is said to omit.

## What Senseible does here

Senseible reads fuel invoices and electricity bills into records, so the diesel and power your plant uses are on file. These rules are filed on government portals, outside Senseible's records.

- [Battery waste rules and carbon data](https://senseible.earth/answers/battery-waste-rules-epr-and-carbon-data)
- [Lead acid battery recycling emissions per tonne](https://senseible.earth/answers/lead-acid-battery-recycling-emissions-per-tonne)
- [Lithium-ion battery recycling emissions per tonne](https://senseible.earth/answers/lithium-ion-battery-recycling-emissions-per-tonne)
- [Waste certificate validity and buying limits](https://senseible.earth/answers/epr-certificate-validity-and-buy-limit-by-stream)

Sources: [MoEFCC, Battery Waste Management Rules, 2022 (rule 10)](https://moef.gov.in/uploads/2022/08/BWMR-2022.pdf)

Last reviewed 2026-11-05. The 2022 rule 10 text was read in the gazette; the October 2023 changes are as described in the amendment notice and not read line by line. CPCB guidelines now carry the certificate method, so check them before you sell or buy.