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Rules 13–15 and Schedules I and II of the Battery Waste Management Rules, 2022: environmental compensation, the penalty for contravention after December 2024, the portal, the implementation committee, labelling with QR codes and the EPR targets

Environmental compensation is levied on the polluter pays principle for activity without registration, false information, forged documents and unsound handling (rule 13(1)). Rule...

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Last updated: October 2026Verified against: Government sources

Rule 13 sets out environmental compensation and, since December 2024, a penalty under section 15 of the Environment (Protection) Act, 1986. Rule 14 provides the CPCB portal and rule 15 the implementation committee. Schedule I carries the heavy metal prohibitions and labelling, including the QR code option added in 2025, and Schedule II sets collection and recycling targets by battery type.

These Rules are current as amended up to S.O. 958(E) dated 24 February 2025. Later amendments, CPCB guidelines and notifications should be checked. If you have received a compensation notice, or need to defend a compliance position, our legal dispute resolution team can help you respond.

Rule 13: compensation and penalty

Sub-ruleContent
13(1)Compensation is also levied, on the polluter pays principle, for (i) activities without registration; (ii) false information or wilful concealment by registered entities; (iii) forged or manipulated documents; (iv) collection, segregation and treatment entities not following sound handling of waste battery
13(2)Omitted on 3 December 2024 (it had allowed such activities to be dealt with under section 15 after a hearing)
13(3)As substituted in March 2024 (G.S.R. 190(E)): the CPCB prepares and recommends guidelines for imposition and collection of compensation from producers and from refurbishing and recycling entities, may consult the Committee for Implementation, and submits them to the Ministry for concurrence
13(4), (5)The CPCB levies it on producers for non-fulfilment of EPR; the State Board levies it on refurbishing, recycling, collection, segregation and treatment entities in its jurisdiction; if the State Board does not act in sixty days, the CPCB issues directions
13(6), (7)Payment does not absolve the producer; unfulfilled EPR carries forward three years; if the shortfall is addressed within one year of levying, 75 per cent of the compensation is returned; within two years, 60 per cent; within three years, 40 per cent; after three years the entire amount is forfeited
13(8)Funds are held in a separate escrow account and used for collection and refurbishing or recycling of uncollected, non-recycled or non-refurbished waste battery against which compensation is imposed; modalities are recommended by the Committee and approved by the Central Government
13(9)As substituted on 3 December 2024: "Any person, who fails to comply or contravenes the provisions of these rules shall be liable to a penalty in accordance with the provisions of section 15 of the Act."

The notification S.O. 5210(E) has no short-title clause; it simply omits sub-rule (2) and substitutes sub-rule (9). Rule 13(9) restates no figure; see sections 15 to 15B of the EP Act. No compensation rate is printed in the Rules; it follows CPCB guidelines. The refund slabs are those of this rule and differ from other waste rules.

Rules 14 and 15

Rule 14 (portal). The CPCB established an online system for registration and returns within six months of commencement (14(1)); it reflects the material balance of waste battery against producers' EPR and audit details (14(2)); the State Boards use it for registering refurbishers and recyclers (14(3)); it is the single point data repository for orders and guidelines (14(4)); a producer may facilitate its development (14(5)). Under sub-rule (6), inserted in 2023, the Central Government may by order relax timelines for returns of producers, recyclers and refurbishers by up to nine months.

Rule 15 (Committee for Implementation). A Committee under the Chairman of the CPCB recommends measures to the Ministry, monitors implementation, removes difficulties, guides the portal and may modify the forms with Central Government approval (15(1) to (4)). Its members include the Ministries of Electronics and Information Technology, Housing and Urban Affairs, MSME, New and Renewable Energy, the Department for Promotion of Industry and Internal Trade, Chemicals and Petrochemicals, the CPCB, State Boards, NEERI and associations of producers, recyclers and refurbishers (15(5)). Since 2023 it meets at least once in six months and submits its report to the Central Government (15(6)).

Schedule I: prohibitions and labelling

Heavy metals (paragraph 1). Batteries containing up to 0.0005 per cent (5 ppm) of mercury by weight may only be placed till 2025; portable batteries containing up to 0.002 per cent (20 ppm) of cadmium by weight may only be placed (as substituted in 2023). The mercury prohibition does not apply to button zinc silver oxide and zinc air batteries with mercury content below 2 per cent by weight; the cadmium prohibition does not apply to portable batteries for emergency and alarm systems or medical equipment.

Labelling (paragraph 2).

ClauseRequirement
(i)Batteries and packs marked with labelling as per BIS standards
(ia), inserted 2023Producers shall, on or before 31 March 2025, ensure all batteries or packs are marked with the EPR registration number. The 2025 amendment (S.O. 958(E)) added a proviso that the clause does not apply to packaging covered under rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2011
(ib), inserted 2025Producers may fulfil (ia), subject to informing the CPCB in writing, by printing a barcode or QR code with the EPR registration number on the battery or pack, the equipment, the packaging of either, or bulk packaging not for retail sale, or by printing the number on the product information brochure; the CPCB publishes and updates quarterly a consolidated list of such producers
(ii) to (iv)Labels visible, legible, indelible; the crossed out wheeled bin symbol covering at least 3 per cent of the area of the largest side (maximum 5 cm x 5 cm), or 1.5 per cent for cylindrical cells; a 1 cm x 1 cm symbol on the packaging where the symbol would be smaller than 0.5 cm x 0.5 cm
(v)Batteries and button cells containing mercury, cadmium or lead carry Hg, Cd or Pb beneath the symbol. The 2025 proviso removes the Cd or Pb marking where cadmium is at or below 0.002 per cent (20 ppm) or lead at or below 0.004 per cent (40 ppm) by weight

Schedule II: EPR targets

The target includes the collection target in the tables and a hundred per cent recycling or refurbishment of the collected quantity (para (ii)). Targets are specific to the kind of battery within each type (para (iv)). Producers meet obligations through certificates from recyclers or refurbishers; where certificates are unavailable, the producer is responsible for collection (para (v), as amended in 2023). Cycle structure, as printed:

Battery type (clause)Compliance cyclePattern of the minimum collection percentage
Portable, rechargeable in consumer electronics (vi)Ten years from 2022-2350, 60 and then 70 per cent of the quantity placed in the market in an earlier year; from 2032-33 the fifth preceding year
Other portable (vii)Ten years from 2025-2650, 60 and then 70 per cent; from 2035-36 the third preceding year
Automotive (viii)Seven years from 2022-2330, 50, 70 and then 90 per cent
Industrial (ix)Seven years from 2022-2340, 50, 60 and then 70 per cent
EV, three wheelers (x), substituted 2023Seven years from 2026-2770 per cent of the quantity placed in the market in the matching earlier year
EV, two wheelers (xi)Seven years from 2026-2770 per cent
EV, four wheelers (xii)Fourteen years from 2029-3070 per cent (the 80 per cent entry for 2039-40 was changed to 70 per cent in 2023)

Collection and refurbishment or recycling of 100 per cent of the collected waste is mandatory by the end of each cycle against the batteries placed in the market during it. Since March 2024 the carry-forward wording in all tables reads: "up to 60% of the remaining quantity of battery placed in the market during the applicable compliance cycle may be carried forward to the next compliance cycle", replacing the earlier "average quantity" wording (and, for automotive batteries, the earlier twenty per cent figure).

Who is affected

Producers (targets, labelling, compensation), refurbishers, recyclers and collection entities (compensation, penalty) and State Boards and the CPCB (levy and appeals).

Example

Sunbeam Energy Private Limited sells portable batteries. It informs the CPCB in writing and prints a QR code with its EPR registration number on the packaging, as clause (ib) allows. A cadmium test shows 0.001 per cent, so the Cd marking is not required under the 2025 proviso to clause (v), but the crossed out wheeled bin symbol still is.

Need help with a battery compensation notice?

Compensation, penalty and target disputes depend on certificates, returns and registration records. Our legal dispute resolution team can help you analyse the notice and prepare a reply.

Key takeaways

  • Compensation attaches to unregistered activity, false information, forged documents and unsound handling.
  • Rule 13(2) was omitted and rule 13(9) substituted on 3 December 2024 to link contravention to section 15 of the Act.
  • Compensation does not absolve the producer; the shortfall carries forward three years, with 75, 60 and 40 per cent refunds.
  • Schedule I now allows a QR code for the EPR registration number, subject to written intimation to the CPCB.
  • Schedule II sets seven, ten and fourteen-year cycles by battery type, with carry-forward of up to 60 per cent of the remaining quantity.

Read next

Disclaimer: Based on the environment rules, guidelines and notifications named above as published in the Gazette of India, read with every amendment notified up to 3 October 2026 that the article names (consolidated reading texts from the CPCB 2021 compilation and the Goa State Pollution Control Board 2025 compilation were checked against the amending notifications), as consulted on 3 October 2026. Later amendments, CPCB guidelines, State Board orders and fees should be checked. This article is general information, not legal advice; check the official text before acting.

Quick recapKey facts & short answers

Key Facts About Rules 13

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What does rule 13(9) say?

Any person who fails to comply or contravenes the Rules is liable to a penalty in accordance with section 15 of the Act.

Who levies compensation?

The CPCB on producers and the State Board on refurbishing, recycling, collection and treatment entities (rule 13(4) and (5)).

State rules differ more than founders expect — check the State before copying another city's checklist.

— TaxClue Business Setup Desk

Rules 13: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

Any person who fails to comply or contravenes the Rules is liable to a penalty in accordance with section 15 of the Act.

The CPCB on producers and the State Board on refurbishing, recycling, collection and treatment entities (rule 13(4) and (5)).

75, 60 or 40 per cent within one, two or three years; nothing after three years (rule 13(6) and (7)).

Yes, subject to informing the CPCB in writing (Schedule I paragraph 2(ib)).

Up to 60 per cent of the remaining quantity placed in the market in the cycle may be carried to the next cycle (Schedule II, as amended in 2024).

At least once in six months (rule 15(6)).