Rule 4 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Rule 4 is the producer's rule. It makes every producer responsible for the batteries it puts on the market, and for those it puts to self-use, requires registration with the CPCB, sets annual returns, ties the producer to the targets in Schedule II and, in sub-rule (14), requires a minimum use of domestically recycled material in new batteries. Sub-rules (1), (2), (4) to (8) and (16) were reshaped in 2023, and the sub-rule (14) table was substituted in June 2024.
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 are a producer or importer planning registration, returns and recycled-content sourcing, our compliance documentation team can help you build the file.
Every producer carries EPR for batteries it introduces in the market and those it puts to self-use (rule 4(1)), must register with the CPCB (4(4)), whose certificate is valid until cancelled or withdrawn (4(5)), and files a return by 30 June on batteries made, assembled or imported in the preceding year (4(7)). Waste batteries go to recycling or refurbishing, not landfill or incineration (4(3)). New batteries must contain minimum recycled materials as per the table in 4(14).
Rule 4 sub-rule by sub-rule
Obligation and targets (4(1) to 4(3))
- 4(1), as substituted in 2023. Every producer has EPR for the battery it introduces in the market and the battery it puts to self-use, to ensure the recycling or refurbishing obligations as per Schedule II.
- 4(2), as substituted in 2023. Every producer has the obligation for environmentally sound management of pre-consumer waste battery generated during manufacturing, assembling or import of a battery or battery pack, and files annual returns in Form 3 for pre-consumer waste battery generated in the preceding financial year.
- 4(2A), inserted in 2023. Every producer meets the collection, recycling and refurbishment targets in Schedule II for batteries or battery packs made available in the market, including those put to self-use.
- 4(3). Waste battery collected by the producer shall be sent for recycling or refurbishing and shall not be sent for landfilling or incineration.
Registration (4(4) to 4(6A))
- 4(4), as substituted in 2023. Every producer obtains registration from the CPCB through the online centralised portal in Form 1(A).
- 4(5), as substituted in 2023. The CPCB issues a certificate of registration in Form 1(B), valid until it is cancelled or withdrawn. The original text required renewal before sixty days of expiry; the 2023 text removes renewal.
- 4(6) and 4(6A). A producer informs the CPCB of any changes in the registration information. If a producer stops its operations, it must discharge its EPR for batteries already made available in the market till closure, under the Rules.
Returns and plans (4(7), 4(11))
- 4(7), as substituted in 2023. The producer furnishes a return, in Form 1(C), on batteries manufactured, assembled or imported in the preceding financial year, to the CPCB on or before 30 June every year. Sub-rule (8), on the first plan for 2022-23, was omitted.
- 4(11). The producer files annual returns in Form 3 on waste battery collected and recycled or refurbished towards EPR with the CPCB and the State Board by 30 June of the next financial year, and gives the details of registered recyclers from whom EPR certificates were procured.
Operating choices (4(9), 4(10))
A producer may operate schemes such as deposit refund or buy back to build a separate waste stream (4(9)). It may engage itself or authorise any other entity for collection, recycling or refurbishment, but "the obligations of meeting the Extended Producer Responsibility targets shall remain with the Producer" (4(10)).
Conduct (4(12), 4(13), 4(15), 4(16))
A producer must adhere to the prohibitions and labelling requirements in Schedule I and ensure safe handling of battery and waste battery (4(12)); bring to the notice of the CPCB or State Board violations by any entity handling waste battery (4(13)); not deal with any entity lacking registration mandated under the Rules (4(15)); and, since 2023, take measures for sustainable production of batteries or battery packs, including in accordance with CPCB guidelines (4(16)). The labelling and QR code provisions of Schedule I are explained in rules 13 to 15 and the Schedules.
Rule 4(14): minimum use of recycled material
The producer must use domestically recycled materials in new batteries as per the table, assessed on the total dry weight of the battery. For imported batteries, the producer meets the obligation by getting the same quantity of recycled material utilised by other businesses or by exporting it. S.O. 2374(E) of 20 June 2024 substituted the table with the following, per cent of total dry weight, in respect of the financial year:
| Type of battery | 2027-2028 | 2028-2029 | 2029-2030 | 2030-2031 and onwards |
|---|---|---|---|---|
| Portable | 5 | 10 | 15 | 20 |
| Electric vehicle | 5 | 10 | 15 | 20 |
| Automotive | 35 | 35 | 40 | 40 |
| Industrial | 35 | 35 | 40 | 40 |
The substituted table places all four types in the same columns. The earlier table had separate columns for automotive and industrial batteries, beginning in 2024-25. A producer that planned against the earlier columns should read the June 2024 table.
Penalty
Rule 13(9), as substituted in December 2024, makes contravention of the Rules punishable under section 15 of the Act; see sections 15 to 15B of the EP Act and the article on rules 13 to 15.
Who is affected
Battery manufacturers, importers of batteries and battery-bearing equipment, brand owners, contract assemblers who are producers under rule 3(1)(u)(iv), and any business that puts batteries to self-use, for example a fleet operator that assembles its own packs.
Example
Ampere Power Private Limited makes automotive batteries under its own brand. It is registered with the CPCB in Form 1(A); the certificate is valid until cancelled. By 30 June it files its Form 1(C) return for the previous financial year and its Form 3 annual return, with the details of the recyclers whose EPR certificates it bought. It plans recycled-lead sourcing against the automotive row of the 4(14) table.
Need help with battery producer compliance?
Registration, returns, certificates and recycled-content sourcing must fit together year after year. Our compliance documentation team can help you assemble the records and set a filing calendar.
Key takeaways
- EPR covers batteries introduced in the market and batteries put to self-use.
- Registration with the CPCB is valid until cancelled or withdrawn; no renewal.
- Returns fall by 30 June; waste batteries must not go to landfill or incineration.
- The recycled-content table in rule 4(14), as substituted in June 2024, starts in 2027-2028 for all four battery types.
- Responsibility stays with the producer even when it engages others.
Read next
- Rules 13 to 15 and the Schedules: compensation, penalty, portal and targets
- Rules 5 to 9: consumers, authorities, refurbishers and recyclers
- Rules 1 to 3: application and definitions
- Licenses and registrations required for a battery business
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.