Extended Timeline for Battery Producers for Filing Annual Returns Under Battery Waste Management Rules

Introduction to the Order for Battery Producers

The Battery Waste Management Rules, 2022, which became effective on 24 August 2022, contained Battery Waste Management Rules 2022/AR, which is an Annual Returns reporting requirement where battery producers registered under their Extended Producer Responsibility (EPR) obligations reported the collection, recycling, and refurbishment of waste batteries. Afterwards, under an amendment of 25 October 2023, the Central Government was given the power to shorten compliance schedules to facilitate the successful enforcement of the rules. To follow up on this provision, the Ministry of Environment, Forest and Climate Change (MoEF&CC) has now provided an order that the deadline to file Annual Returns for FY 202324 may be extended, on a request by the Central Pollution Control Board (CPCB) to meet the practical and operational difficulties on the part of battery producers.

Key Provisions of the Order

• Battery manufacturers are required to submit Annual Returns in Form 3 as provided by the Battery Waste Management Rules, 2022.
• In order to comply with the requirements of EPR, returns should reveal information about the waste batteries they are collecting, recycling, or refurbishing.
• These should be submitted to the CPCB and relevant State Pollution Control Boards (SPCBs) on an annual basis.
• It is issued under the relaxation provision, instituted on 25 October 2023, in order to issue the order.
• The extension applies specifically to battery manufacturers in the case of FY 202324.

What Is the Date of Implementation?

• Earlier deadline: 30 June 2024
• Extended deadline: 30 August 2024

Battery manufacturers should make sure that they have submitted Annual Returns concerning the FY 202324 on or before 30 August 2024.

Now, What to Do?

The battery manufacturers ought to use the long time span to:

• Test and certify EPR compliance data.
• Arrange with licensed recyclers and refurbishers.
• Full and lodged Form 3 Annual Returns.
• Fix any portal submission discrepancies.
• Compliance should be taken in time to prevent regulation.

Brand Liaison provides complete adherence support in Battery Waste Management Rules, such as Annual Return filing, EPR data verification, CPCB and SPCB coordination, documentation support, and continued regulatory advisory. Battery producers also have no hassles in ensuring that their environmental compliance and EPR frameworks are smooth and timely, with the experience that Brand Liaison has had in this area.