Battery Scrap EPR Regulatory Updates for H1 FY 2026-27

Battery EPR entered a more operational phase in H1 FY 2026-27.

Until this year, many producer discussions began with the portal target and ended with the purchase of an EPR certificate. The first half of FY 2026-27 made that approach harder to defend.

On 19 June 2026, the Central Pollution Control Board told battery recyclers that GST e-invoices would become mandatory from 1 July for sales of recovered key battery metals and metal compounds used to support certificate generation. In July, CPCB issued one guideline for collection, handling, storage and transportation and another for recycling lead-acid and lithium-ion batteries.

Together, the three instruments create a connected compliance trail. The condition of incoming battery scrap, the entity collecting it, the way it is stored and moved, the process used to recover materials, the sale of those materials and the certificate transferred to a producer can no longer be treated as unrelated records.

H1 at a glance

H1's real update was implementation, not a new amendment

No Battery Waste Management amendment was identified in the Official Gazette between 1 April and 30 September 2026. The Battery Waste Management Rules, 2022 and amendments notified through February 2025 remained the legal base.

That matters because the H1 guidelines did not replace producer responsibility. They made parts of the existing responsibility more concrete.

The rules apply to batteries regardless of chemistry, shape, volume, weight, material composition or use. They cover portable, automotive, industrial and electric-vehicle batteries. The producer definition includes a business that manufactures or sells batteries under its own brand, sells own-brand batteries made by another supplier, imports batteries or equipment containing them, or manufactures batteries for another producer without using its own brand.

A producer may appoint another entity for collection, recycling or refurbishment. The obligation still remains with the producer.

The practical H1 message is therefore simple: outsourcing battery-scrap handling does not reduce the producer's need to understand and verify the chain.

The 1 July GST cutover changed certificate due diligence

CPCB's 19 June notice addressed recyclers under the battery rules. It said recyclers must maintain proper records for sales of recovered key battery metals and metal compounds, supported by GST-linked invoices.

From 1 July 2026, recyclers were required to upload GST e-invoices for those sales on the Battery Waste EPR Portal. The notice further stated that certificates generated from sales invoices other than GST e-invoices would not be considered after 30 June 2026. Certificates generated on that basis beyond the cut-off would be treated as false certificates and non-compliance.

This is more than an invoice-format change.

Battery certificates are linked to recovered materials. The GST control creates an external commercial record for the sale that supports certificate generation. A producer purchasing a certificate should therefore be able to test not only whether the recycler is registered, but also whether the certificate was generated under the evidence standard applicable on its generation date.

A brand-side certificate check should include:

1. Recycler registration and approved battery category.
2. Certificate category, quantity, generation date and portal status.
3. Recovered key metal or compound supporting the certificate.
4. GST e-invoice reference for certificates generated under the post-cutover process.
5. Transfer, adjustment and annual-return treatment.
6. Exception approval where the portal or invoice record does not reconcile.

The certificate remains a portal instrument. The new control means its credibility is increasingly tested through a real downstream transaction.

Battery-scrap collection now has a defined operating perimeter

The July collection guideline applies across the value chain, including producers, recyclers, refurbishers, collection centres and entities transporting waste batteries.

It says producers may build collection systems using dealers, collection centres and other collection entities. They may use take-back, deposit-refund, buy-back or another model. The producer is expected to make the system workable and accessible and to communicate drop points, contact details and relevant take-back information.

The guideline then draws a sharper boundary around formal collection centres.

Only producers, recyclers or refurbishers are to be allowed to establish collection centres. The guideline says these centres should obtain consent to establish, consent to operate or hazardous-waste authorisation from the relevant State Pollution Control Board or Pollution Control Committee under the applicable classification. A site plan should be submitted for assessment of storage capacity.

Collection centres are also expected to file the previous financial year's annual return with the relevant state authority by 30 June in Form 4 under the Hazardous and Other Wastes framework.

For brands, this changes the due-diligence question. It is not enough to ask whether an aggregator can collect batteries. The producer should know who legally operates the collection centre, what approvals apply to the site, where the scrap is stored and which authorised recycler or refurbisher ultimately receives it.

A collection point is not a dismantling or trading point

The July guideline separates collection from processing.

Collection centres may receive, sort and temporarily store battery scrap. They should not dismantle, shred or process it. The guideline also states that a collection centre should not sell waste batteries to traders or dealers. Collected batteries should move to registered or authorised recycling or refurbishing units.

This distinction is commercially important.

Battery scrap often passes through several hands because collection is geographically fragmented. If a producer's programme allows material to move from a branded collection point into an undocumented trading chain, the physical tonnes may survive while the compliance evidence does not.

The stronger contract model identifies:

• the approved operator of each collection centre;
• every drop point linked to it;
• permitted battery categories and chemistries;
• maximum approved storage quantity;
• pickup frequency and transporter responsibility;
• destination recycler or refurbisher;
• weight, date and handover records at each transfer;
• responsibility for incidents, damaged packs and rejected loads.

This is not a requirement to eliminate commercial aggregation. It is a requirement to preserve an authorised and auditable route from collection to processing.

Storage is now a category, chemistry and condition control

The guideline says producers, collection centres, recyclers and refurbishers may store waste batteries for up to 90 days while maintaining collection, sale, transfer and storage records. A state board or pollution control committee may extend the standard period under the applicable hazardous-waste provision.

The storage model is not a single pile of battery scrap.

Facilities should separate batteries by application category, including portable, automotive, industrial and EV, and by chemistry, including lead-acid, lithium-ion, zinc-based and nickel-cadmium. Damaged or leaking batteries should be isolated and protected. Storage should be cool, dry and away from direct sunlight, with suitable fire detection, extinguishing, spill-control and emergency-response measures.

Collection centres should have weighing equipment and record each delivery. The guideline calls for fire-rated separation, trained personnel, inspection records and controlled access. It also says no acid draining, dismantling or seal removal should occur at drop points.

For lithium-ion packs, the guidance says storage may be at about 30% state of charge at or below 35 degrees Celsius. It also recommends protection of terminals and non-conductive, non-combustible cushioning where required.

These details turn battery-scrap quality into a compliance issue. A mixed, damaged or poorly stored load is not merely less valuable. It can create fire, worker-safety, transport and documentation risk before it reaches a recycler.

Transport records must travel with the battery risk

The collection guideline ties waste-battery transport to the Battery Waste Management Rules, Motor Vehicles framework and relevant hazardous-waste requirements.

It calls for chemistry-appropriate packaging, prevention of short circuits and protection from heat, water and mechanical damage. Battery terminals should be taped where required. Lithium-ion waste battery packs may be transported below 30% state of charge. Large EV packs should be stored upright on pallets without stacking and secured with non-conductive strapping.

For waste sent for recycling, the guideline says the sender should intimate the relevant state board before handover to the transporter under the applicable hazardous-waste provision. Used lead-acid batteries should travel upright in sealed, shock-resistant and acid-resistant containers using leak-proof vehicles.

Brands do not need to operate every truck to control this risk. They do need contract terms and evidence that identify the sender, transporter, packaging standard, weight, source, destination and date of movement.

The recycling guideline separates plant capability from registration alone

CPCB's July recycling guideline covers waste lead-acid and lithium-ion batteries. It sets out indicative plant infrastructure, operating processes, pollution-control equipment, emission or work-zone parameters, monitoring and portal records.

For lead-acid batteries, the guideline addresses furnaces, air-pollution-control systems, acid-proof storage, neutralisation, effluent treatment and handling of contaminated plastic and residues. Facilities above 5,000 tonnes per year are expected to install mechanical or automated battery-breaking systems within one year of the guideline. Smaller units are given three years.

For lithium-ion batteries, the guideline distinguishes physical dismantling and black-mass generation, black-mass refining and integrated processing. It specifies dedicated storage, discharge equipment, safe shredding, electrolyte capture, physical separation, black-mass handling and pollution controls.

The guideline also requires recyclers to provide financial-year-wise procurement, recycling and recovered-material sales data on the portal, generate and transfer certificates through the portal and file quarterly returns. Violations are linked to the environmental-compensation framework.

For producers, the implication is direct. Registration confirms that an entity has entered the formal system. It does not, on its own, confirm that every process, chemistry or certificate category is covered by the facility's actual infrastructure and approval scope.

FY 2026-27 targets must be calculated category by category

Battery EPR does not have one universal FY 2026-27 percentage.

The Schedule II target depends on battery category, application and the applicable compliance cycle. Some portable, automotive and industrial categories use different percentages and different historical reference years. EV batteries are further separated by vehicle type and life cycle.

This is why a headline number should never replace the product ledger.

Each producer should map:

• battery category and chemistry;
• whether the battery is sold alone or inside equipment;
• quantity placed on the market in the applicable reference year;
• dry-weight basis used for reporting;
• target percentage and compliance cycle;
• certificates purchased, adjusted and carried forward;
• recycled-material requirement that begins in FY 2027-28.

The next major product-side milestone is already visible. From FY 2027-28, minimum recycled material begins at 5% of dry weight for portable and EV batteries and 35% for automotive and industrial batteries. That requirement affects sourcing and product design, not only certificate procurement.

Domestic battery scrap remains strategically important

The 2023 amendment says certificates cannot be generated from waste batteries imported under the Hazardous and Other Wastes framework. Imported waste must be accounted for separately.

The January 2026 policy report estimates more than 80 kilotonnes of announced lithium-ion recycling capacity against about 15 kilotonnes of end-of-life supply requiring recycling in 2025. It estimates 115 kilotonnes of announced capacity against around 60 kilotonnes of end-of-life supply in 2030.

These are research estimates, not statutory figures. They point to a commercial reality: plant capacity and certificate-eligible domestic feedstock are different things.

The H1 controls increase the value of properly sourced domestic battery scrap because its collection, movement, processing and recovered-material sale must support one coherent record.

What brands should change after H1

Audit the collection map. Confirm who operates each centre and drop point, what approvals apply and where the battery scrap goes next.

Separate battery streams at source. Record category, chemistry, condition and weight before aggregation. Do not wait for the recycler to reconstruct the load.

Update recycler due diligence. Review actual facility capability, approval scope and July guideline gaps, not only portal registration.

Add GST evidence to certificate approval. For post-cutover certificates, confirm the applicable recovered-material e-invoice trail.

Write safety into contracts. Include packaging, storage, state of charge, transport, incident reporting and damaged-battery procedures.

Prepare recycled-material sourcing. FY 2027-28 product requirements require early engagement with procurement and suppliers.

What to watch in H2 FY 2026-27

1. Implementation of the July guidelines by state boards and registered facilities.
2. Portal enforcement of GST e-invoices and treatment of certificate exceptions.
3. The extended FY 2025-26 annual-return deadline of 30 November 2026.
4. Evidence of mechanical battery-breaking upgrades at lead recyclers.
5. Further guidance on recycled-material reporting before FY 2027-28.

The bottom line

H1 FY 2026-27 turned battery EPR into a more complete chain of custody. For brands, compliance now begins with battery classification and safe collection, continues through authorised storage and transport, and ends with real recovered-material sales, eligible certificates and reconciled portal returns. Battery scrap is not simply the input to recycling. It is the first record in the EPR evidence chain.