Introduction
On 24 February 2025, the Ministry of Environment, Forests, and Climate Change (MoEF&CC) officially notified the Battery Waste Management Amendment Rules, 2025, in the Gazette of India. These rules amend key labelling provisions under Schedule I of the original Battery Waste Management Rules, 2022, with immediate effect upon publication.
The latest updates significantly impact how battery manufacturers, importers, and brand owners must label and track their battery products. Designed to strengthen Extended Producer Responsibility (EPR), ensure digital traceability, and promote sustainable waste management, these battery labelling requirements are now legally enforceable and non-negotiable.
Whether you’re selling lithium-ion cells, battery packs, or electronics embedded with batteries, understanding and complying with the updated labelling rules is essential to maintain market access, avoid penalties, and support India’s transition to a circular economy.
What Are the Battery Labelling Requirements for 2025?
The Ministry of Environment, Forest and Climate Change (MoEF&CC), through the Battery Waste Management Rules 2025, has amended Schedule I to clarify labelling provisions for all types of batteries — from lithium-ion cells to batteries embedded in electronic devices.
🔹 Clause (ia) – Legal Metrology Exemption
If a battery’s packaging is already compliant with Rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2011, it is exempt from this provision.
🔹 Clause (ib) – New Labelling Methods
Producers can comply with the updated battery labelling requirements by:
- Printing a QR code or barcode that includes the EPR registration number on:
- The battery or battery pack
- Any equipment that contains the battery
- The battery packaging, whether individual or bulk
- Alternatively, printing the EPR number inside the product’s information brochure
These updated battery packaging regulations offer flexibility while ensuring complete traceability.
Imported Batteries: What the CPCB Notice Says
A key update from CPCB battery compliance authorities (Notice dated May 28, 2024) clarifies that imported batteries are deemed compliant if:
- The EPR registration number is marked on the equipment itself, or
- It appears on the outer packaging of the equipment
This update makes the rules for battery labelling easier to implement for foreign manufacturers and importers who face challenges in labelling small battery components individually.
CPCB’s Centralized Portal for Producers
To maintain compliance, producers must:
- Submit a declaration of their chosen labelling method to the Central Pollution Control Board (CPCB)
- CPCB will publish a list of compliant producers on a centralized online portal
- This list is updated quarterly to ensure transparency and enforcement
This aligns with CPCB battery compliance practices aimed at digital traceability and public accountability.
Recycled Material Obligation Under Rule 14(4)
In addition to labelling, producers must adhere to the Battery Waste Management Rules 2025 regarding material sourcing.
Producers are now required to use domestically recycled materials — including lithium, cobalt, graphite, plastic, paper, and aluminium — not just from battery waste but from any type of recycled source.
This initiative supports India’s movement toward a circular economy, reducing dependency on virgin raw materials and encouraging eco-friendly practices.
What Happens If You Don’t Comply?
Failure to meet battery labelling requirements or CPCB guidelines may result in:
- Delays in import approvals
- Seizure of non-compliant batteries or electronic equipment
- Monetary penalties and legal consequences
- Negative reputation and supply chain delays
On the flip side, proactive compliance ensures smoother logistics, a strong market presence, and alignment with national sustainability goals.
How NKG Advisory Supports Compliance
At NKG Advisory, we work with battery manufacturers, electronics brands, and importers to:
- Handle EPR registration
- Ensure label design and placement meets all legal requirements
- Prepare CPCB declarations and manage portal submissions
- Review your packaging against the latest battery packaging regulations
📩 Want help complying with India’s battery labelling rules?
Contact NKG Advisory today to get expert regulatory support.
Frequently Asked Questions (FAQs)
1. What is the EPR registration number and where should it be printed?
The EPR (Extended Producer Responsibility) registration number is a unique ID issued by CPCB.
It can be printed as a QR code or barcode on:
- The battery or battery pack
- The equipment housing the battery
- The packaging (retail or bulk)
Alternatively, include it in the product brochure.
2. Are imported batteries required to have the EPR number printed directly on them?
No. As per CPCB’s 2024 notice, imported batteries are compliant if the EPR number appears on:
- The equipment that contains the battery, or
- The outer packaging of the equipment or battery
3. If we already comply with Legal Metrology Rules, do we need to follow battery labelling again?
Not necessarily. Clause (ia) exempts such packaging.
However, you must still notify CPCB of your EPR display method under Clause (ib).
4. Is printing the EPR number mandatory for every battery model we sell?
Yes. Every model or SKU must carry the EPR number in one of the approved formats to ensure traceability and compliance.
5. How can we notify CPCB of our labelling format?
Submit a written declaration to CPCB via the centralized online portal.
Your name will appear on a quarterly updated public list of compliant producers.
6. What materials are accepted under the ‘domestically recycled content’ rule?
Recycled lithium, cobalt, aluminium, graphite, plastic, paper, and carbon — sourced from any type of waste — are all valid under Rule 14(4).
Conclusion
The updated battery labelling requirements under the Battery Waste Management Rules 2025 mark a shift toward stricter environmental oversight. Whether you produce or import batteries, staying ahead of CPCB battery compliance is essential to protect your operations and reputation.
Clear labelling, traceable EPR codes, and the use of recycled materials aren’t just regulatory mandates — they are steps toward building a greener, more responsible future for India’s energy sector.
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