EPR Certification Update 2026: GST e-Invoice Is Now Mandatory for Battery Waste Recyclers

Introduction to the Battery Waste Management Rules, 2022

The Battery Waste Management Rules, 2022, that have been earlier notified by the Ministry of Environment, Forest and Climate Change (MoEFCC) on 22 August 2022, mainly introduced the Extended Producer Responsibility (EPR) framework for batteries that are being sold or imported in India. Under these Rules, registered recyclers are mainly required to generate EPR Certificates through the Battery Waste EPR Portal, which is based on the recycling of waste batteries as well as the sale of recovered battery materials.

In order to strengthen transparency as well as to prevent misuse of the EPR system, the Central Pollution Control Board (CPCB) has now issued a new advisory making GST e-invoices mandatory for generating EPR Certificates.

Key Changes You Should Know

1. GST e-Invoices have now become mandatory

From 1 July 2026, all registered battery recyclers must upload GST e-invoices for the sale of recovered key battery metals as well as metal compounds on the Battery Waste EPR Portal.

2. EPR Certificates will be issued only against GST e-Invoices

Only sales that are supported by valid GST e-invoices will be considered for generating EPR Certificates.

Note: Invoices that are not generated through the GST e-invoicing system will no longer be accepted after the prescribed deadline.

3. Deadline for existing invoices

• Recyclers may use the existing invoice system only up to 30 June 2026.
• It is important to consider that after this date, only GST e-invoices will be accepted for EPR Certificate generation.

4. GST Registration is essential for recyclers to continue EPR Compliance

Recyclers that are not yet registered for GST e-invoicing have been directed to complete the registration process immediately in order to avoid disruption in EPR Certificate generation.

5. Non-GST invoices treated as non-compliant after 30 June 2026 

Any EPR Certificates that are generated using invoices other than valid GST e-invoices after 30 June 2026 will be treated as false certificates and will be considered a violation of the Battery Waste Management Rules, 2022.

What is the Date of Implementation?

The GST e-invoice has become mandatory for issuing EPR certificates from 1 July 2026. The last date for using non-GST invoices is 30 June 2026, after which they will become invalid for generating EPR Certificates from the official portal.

Benefits of this Update for the Industry/Businesses

This new requirement offers several benefits to recyclers of battery waste management in the Indian market, mainly including the following:

• This improves transparency in the EPR Certificate generation process.
• This also ensures better compliance with GST and EPR regulations in the Indian market.
• This also creates a more reliable as well as accountable battery recycling ecosystem.
• It helps to reduce the risk of fraudulent or duplicate EPR Certificates.
• This initiative mainly enhances confidence among producers who are purchasing EPR Certificates.
• Moreover, this strengthens the traceability of recycled battery materials.

Now, What to Do?

Battery recyclers should take immediate steps in order to ensure uninterrupted EPR compliance by the following:

• It is important to register for GST e-invoicing if not already registered for it.
• Recyclers must generate GST e-invoices for every sale of recovered key battery metals as well as metal compounds.
• They have to upload GST e-invoices on the Battery Waste EPR Portal while applying for EPR Certificates.
• It is of utmost importance to maintain accurate records of sales as well as the supporting documents.
• Recyclers must ensure that all EPR Certificate applications submitted after 1 July 2026 are supported by valid GST e-invoices.

At Brand Liaison, we help battery recyclers to easily navigate evolving EPR compliance requirements with utmost ease and confidence. Our experts assist in reviewing compliance processes, ensuring that the documentation aligns with CPCB requirements, supporting EPR Portal filings, as well as helping businesses adapt to new regulatory updates in order to avoid delays in EPR Certificate generation.