Date for Annual Return for Battery Waste Extended to 30 June 2024

Introduction to the Notification for Annual Returns for BWM 

The Ministry of Environment, Forest and Climate Change (MoEF&CC) regulates the environmentally sound management of battery waste in India through the Battery Waste Management Rules, 2022, which in fact, mandates the Extended Producer Responsibility (EPR) obligations for battery producers. These rules mainly aim to ensure proper collection, recycling, as well as safe disposal of battery waste while promoting accountability across the supply chain.

In order to address implementation challenges and clarify compliance timelines, the Ministry issued an Office Memorandum dated 14 November 2023, providing guidance on how EPR targets and annual returns for different categories of batteries are to be recorded and processed for during the transition from the erstwhile E-Waste (Management) Rules, 2016 to the Battery Waste Management Rules, 2022. 

However, this new notification extends the annual returns deadline for battery waste to 30 June 2024. 

Key Changes You Need to Know

As per the Office Memorandum, the Ministry has clarified and aligned EPR compliance obligations as follows:

1. EPR compliance for FY 2022–23 related to batteries covered under 21 products that are listed in Schedule I of the erstwhile E-Waste (Management) Rules, 2016 shall continue to be accounted under the E-Waste Rules, 2016.
2. For batteries not covered under the above category, EPR compliance for FY 2022–23 must be fulfilled during FY 2023–24.
3. Annual returns are required to be filed for:
   1. FY 2022–23 (only for batteries not covered under the E-Waste Rules, 2016)
   2. FY 2023–24 (for all types of batteries)
4. All compliance activities must be carried out strictly in accordance with the Battery Waste Management Rules, 2022, to stay eligible in the Indian market.
5. Producers must purchase EPR battery recycling credits only from CPCB-registered recyclers for ensuring credibility as well as compliance in the market. 

What is the Date of Implementation?

The extended deadline is provided in the notification for compliance with EPR targets, and submission of annual returns for FY 2022–23 and FY 2023–24. The new extended date of implementation is 30 June 2024.

All producers are required to complete their filings on the EPR portal within this revised timeline.

Now, What to Do?

Battery producers should immediately assess their pending EPR obligations, have a look at the recycling targets, and ensure procurement of valid EPR credits from authorised recyclers in the Indian market. Timely filing of annual returns on the EPR portal is definitely important in order to avoid regulatory action, including environmental compensation, penalties, or any hindrances to market entry or operational restrictions.

With 10+ years of compliance experience, Brand Liaison supports battery producers through simplified documentation, expert consultancy, EPR target assessment, credit procurement guidance, as well as complete end-to-end regulatory support. Backed by in-depth industry knowledge as well as absolutely practical EPR expertise, Brand Liaison helps businesses meet Battery Waste Management compliance in an efficient manner and within the notified deadlines.