Registration for Scrap Battery Import in India – Complete Compliance Guide (2026)

India is one of the world's largest consumers of lead-acid batteries for automobiles, inverters, solar storage, and industrial backup systems. As domestic battery scrap generation cannot always meet the demand of registered secondary lead smelters and recyclers, India imports significant quantities of scrap batteries and used lead-acid batteries from Africa, the Middle East, Southeast Asia, and other regions. The dollar value of scrap battery imports reached USD 893 million in FY 2020–21 alone, reflecting the scale of India's dependency on imported battery feedstock.

But unlike ordinary commodities, scrap batteries are classified as hazardous waste under India's Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, and as Annex VIII waste under the Basel Convention. They contain lead, sulphuric acid, and other toxic substances that can contaminate soil, groundwater, and air if mishandled. This is why importing scrap batteries or used lead-acid batteries for recycling without the full stack of government authorizations is illegal, and why Customs will not release such consignments without verified compliance documentation. Many importers discover these requirements only after their shipment has arrived at port, triggering demurrage charges, forced re-export, regulatory action, and significant financial losses.

The solution is obtaining Registration for Scrap Battery Import. Only authorised recyclers and secondary smelters with valid SPCB registration and verified processing capacity are permitted to import scrap batteries into India. Our service handles every step — from eligibility assessment and SPCB registration to MoEFCC application filing, Basel PIC coordination, CPCB inspection preparation, Expert Committee presentation, DGFT license, and customs clearance support — in one end-to-end compliance journey.

What Is Registration for Scrap Battery Import?

Registration for Scrap Battery Import is the mandatory set of government authorizations that a CPCB/SPCB-registered lead recycling or secondary smelting facility must obtain before importing scrap lead-acid batteries, used lead-acid batteries, lead battery plates, or lithium-ion battery scrap into India for recycling.

Basically, scrap batteries are hazardous waste. You cannot simply order them from abroad and import them like a regular commodity. You need permission from multiple government bodies, primarily MoEFCC, SPCB, CPCB, and DGFT, before a single consignment can legally enter India.

Is This Registration Mandatory?

Yes, importing any scrap battery into India without MoEFCC authorization, SPCB registration, CPCB recommendation, and DGFT import license is a criminal offence under the Environment (Protection) Act, 1986 and the HOW Rules, 2016.

Scrap lead-acid batteries are classified as:

• Basel Convention Annex VIII waste, Code A1160 (Waste lead-acid batteries, whole or crushed)
• Hazardous Waste under Schedule IV of the HOW Rules, 2016

This means the Basel Convention's mandatory Prior Informed Consent (PIC) procedure applies. Both India's MoEFCC and the exporting country's competent authority must approve the shipment before it leaves the origin port. Neither approval can be bypassed or waived.

Consequences of importing without authorization:

• Consignment seized and compulsorily re-exported at importer's cost
• Criminal prosecution under Section 15, Environment (Protection) Act, 1986 — up to 5 years imprisonment; fine up to ₹1 lakh per day of violation
• Permanent cancellation of SPCB and CPCB registrations
• Suspension of Import Export Code (IEC) by DGFT
• Blacklisting from future import authorizations

Who Needs Registration for Scrap Battery Import?

• Authorised Lead Scrap Recyclers Facilities registered with SPCB for recycling lead-bearing waste including battery plates, lead scrap, lead ash, and residues. These recyclers hold valid Consent to Operate under the Water and Air Acts and valid Hazardous Waste Authorization from SPCB.
• Lead-Acid Battery Recyclers and Secondary Lead Smelters Companies that operate SPCB-registered facilities for recycling lead-acid battery scrap, breaking down batteries, recovering lead, treating acid, smelting recovered lead into ingots, and safely disposing of residues. This is the primary category of scrap battery importers. India's total secondary lead smelting capacity depends heavily on these facilities.
• Lithium-Ion Battery Scrap Recyclers With India's EV boom driving massive growth in lithium-ion battery scrap, registered recyclers with processing capacity for lithium-ion black mass (cathode and anode material), battery modules, and cells are increasingly applying for Lithium-Ion Battery Scrap Import Licenses.
• Authorised Traders (with restrictions) Under limited provisions, authorised traders may import scrap batteries — but only if tied up with a registered actual user facility. The end-use must always be recycling at an authorised facility. Traders cannot import scrap batteries for re-export or resale without recycling.

Who CANNOT Import Scrap Batteries

• Unregistered businesses or individuals
• Facilities without valid SPCB registration for lead recycling
• Businesses importing for purposes other than recycling (energy recovery from battery scrap is not permitted)
• Businesses without verified processing capacity matching proposed import volumes
• Anyone not registered on the CPCB EPR Battery portal as a Recycler (cross-checked by CPCB before issuing recommendation)

Industries That Import Scrap Batteries

• Secondary Lead and Non-Ferrous Metal Industry The primary sector. Secondary lead smelters recycle scrap battery lead into refined lead ingots used in new battery manufacturing, ammunition, radiation shielding, and construction materials.
• Automobile and Battery Manufacturing Manufacturers of new lead-acid batteries rely on recycled lead from scrap batteries as a cost-effective raw material, often cheaper and more sustainable than primary (mined) lead.
• Renewable Energy Sector Lead-acid batteries are still widely used in off-grid solar and wind energy storage. Recyclers serve this sector by recovering and re-manufacturing battery components.
• Electric Vehicle (EV) Recycling Industry EV battery recyclers import lithium-ion scrap (black mass, cells, modules) to recover critical minerals — lithium, cobalt, nickel, and manganese — for reuse in new EV battery production.

All Authorizations Required: The Complete Compliance Architecture

Importing scrap batteries into India requires approvals from five regulatory authorities. Each is mandatory. Missing any one will result in customs refusal:

1. SPCB/PCC Recycler Registration (First and Prerequisite)
2. CPCB EPR Battery Recycler Registration
3. MoEFCC Import Permission under Form 5 (HOW Rules 2016)
4. Basel Convention Prior Informed Consent (PIC) / Movement Document
5. DGFT Import License / Import Authorization

Eligibility Criteria for Scrap Battery Import Registration

You are eligible to apply if ALL of the following apply:

• You operate a lead recycling or secondary smelting facility in India OR a registered lithium-ion battery recycling facility
• Your facility has valid SPCB registration for recycling lead-bearing waste or lithium-ion battery scrap
• Your facility has current CTE and CTO under both the Water Act and Air Act
• Your facility has valid Hazardous Waste Authorization from SPCB under HOW Rules, 2016
• You are registered on the CPCB EPR Battery portal as a Recycler under Battery Waste Management Rules, 2022
• Your verified processing capacity matches or exceeds the proposed import volume
• You have an IEC and GST registration
• You have not been blacklisted by CPCB, MoEFCC, or DGFT

You are NOT eligible if:

• You are a trader or dealer without a registered recycling facility
• Your SPCB registration, CTO, or HW Authorization has expired
• You plan to import battery scrap for energy recovery rather than recycling
• Your facility's processing capacity does not support the proposed import quantity
• You are not registered on the CPCB EPR Battery portal

Key Technical Requirements for the Recycling Facility

CPCB has prescribed Minimum Requirements — Facilities and Operating Practices for lead recycling units. Your facility must meet all of these before MoEFCC will grant import permission:

Facility Infrastructure

• Enclosed battery breaking and plate separation area with acid-resistant flooring
• Battery Breaking System (mechanised battery breaker) to prevent acid spills and lead dust release
• Emission Control System (ECS) — fabric filters, bag filters, or equivalent — to capture lead dust from smelting
• Wet scrubber or equivalent to neutralise sulphur dioxide emissions from smelting furnaces
• Effluent Treatment Plant (ETP) to treat acidic wastewater from battery breaking and scrubbers
• Covered storage for scrap batteries to prevent rainfall leaching
• Lined storage areas to prevent soil contamination by lead or acid

Environmental Monitoring (Ongoing)

• Regular testing of soil lead content (within and around facility boundary)
• Periodic ambient air quality monitoring (lead particulate matter)
• Work zone air quality monitoring (for workers handling lead)
• Groundwater monitoring from wells within and around the facility
• Treated effluent monitoring before discharge
• Stack emission monitoring from all smelting furnaces and emission control equipment
• Blood lead level monitoring of all workers (at least once every 6 months)

Worker Health and Safety

• Personal Protective Equipment (PPE) for all workers handling batteries and lead
• Blood lead level records for all workers
• Medical surveillance program for workers

Step-by-Step Process for Scrap Battery Import Registration

• Step 1: Establish and Register Your Recycling Facility with SPCB Before any import application is possible, your recycling unit must be set up and registered with the State Pollution Control Board.
• Step 2: Register on CPCB EPR Battery Portal as a Recycler Register on eprbattery.cpcb.gov.in as a Battery Recycler under the Battery Waste Management Rules, 2022. This registration is a mandatory prerequisite that CPCB cross-checks before issuing its recommendation for MoEFCC approval.
• Step 3: Prepare MoEFCC Import Application (Form 5) Prepare a comprehensive application in Form 5 prescribed under Rule 12 of the HOW Rules, 2016.
• Step 4: Obtain SPCB Recommendation The SPCB reviews the application, conducts or relies on prior site inspections, and forwards its recommendation to MoEFCC within 30 days of receipt of the application. The SPCB recommendation includes any site-specific stipulations for safe transport and processing.
• Step 5: CPCB Inspection and Recommendation CPCB inspects the recycling facility (or reviews previous inspection reports) and issues its recommendation to MoEFCC confirming that the facility meets the minimum requirements for handling and recycling imported battery scrap.
• Step 6: Expert Committee Presentation at MoEFCC The importer must attend the MoEFCC Expert Committee meeting and present their facility's compliance status with the Minimum Requirements — Facilities and Operating Practices. Attendance at both scheduled committee meetings (if required) is mandatory. Missing the scheduled meetings leads to application cancellation; a fresh application must then be filed.
• Step 7: Initiate Basel Convention PIC Procedure For scrap lead-acid batteries (Basel Code A1160), the PIC procedure must run concurrently with the MoEFCC application. This step must be planned far in advance of the expected import date because the 60-day notice period cannot be shortened.
• Step 8: MoEFCC Grants Import Permission After receiving SPCB recommendation, CPCB recommendation, and completing Expert Committee review, MoEFCC issues the Import Permission.
• Step 9: Obtain DGFT Import Authorization Apply for Import Authorization (Restricted Import License) from DGFT on the DGFT portal (dgft.gov.in). DGFT processes applications and issues the Import Authorization valid for a specific period and quantity.
• Step 10: Execute Import with Movement Documents (Form 6) For each consignment, complete Form 6 — the Movement Document under Rule 12 of the HOW Rules, 2016. This document must accompany the consignment through every stage — origin port, transit, and Indian port.
• Step 11: Customs Clearance At the Indian port (sea or air), your Customs House Agent (CHA) files the Bill of Entry.
• Step 12: Post-Import Compliance — Form 3 and Annual Returns After each import consignment clears customs:

1. Maintain records in Form 3 (Hazardous Waste import record) — must be made available for inspection at any time
2. File Annual Return in Form 4 to SPCB, reporting all quantities imported, processed, and waste disposed
3. File Annual Return on CPCB EPR Battery portal (Recycler annual return) by 30 June every year

Documents Required for Scrap Battery Import Registration

Company and Legal Documents

• Certificate of Incorporation / CIN (from MCA)
• Company PAN Card
• GST Registration Certificate
• Import Export Code (IEC) from DGFT — active and current
• MSME Registration Certificate (if applicable)
• Board Resolution authorising the signatory for the MoEFCC application

SPCB Registration and Facility Documents

• CPCB EPR Battery Recycler Registration

1. Environmental Monitoring and Facility Documents
2. Import-Specific Documents
3. Additional Documents for Expert Committee Presentation

Benefits of Getting Scrap Battery Import Registration

• Legal Right to Import Battery Scrap
• Access to a High-Value Feedstock Market
• Environmental and Public Health Protection
• Compliance with Basel Convention
• Contribution to India's Secondary Lead Industry and Circular Economy
• Critical Mineral Recovery for EV Industry
• Employment and Economic Growth
• Protection from Blacklisting and Business Disruption

Common Mistakes Scrap Battery Importers Make

• Applying for MoEFCC permission without first obtaining SPCB CTO and HW Authorization — MoEFCC will not process the application without these
• Not registering on CPCB EPR Battery portal as a Recycler before applying — CPCB cross-checks this before issuing recommendation
• Not initiating the Basel PIC procedure in parallel with the MoEFCC application — the 60-day minimum notice period will delay your entire timeline
• Missing Expert Committee presentation appointments — leads to automatic cancellation; a fresh Form 5 application must be filed
• Importing beyond the quantity permitted by MoEFCC — any excess is treated as unauthorised import
• Importing from countries that have not given Basel PIC consent — consignment will be refused at port
• Not maintaining Form 3 records for each consignment — attracts regulatory action during CPCB/SPCB inspections
• Failing to file annual returns in Form 4 to SPCB — triggers SPCB notices and possible CTO suspension
• Not conducting or recording environmental monitoring (soil, air, water, worker blood lead) — fails CPCB facility inspection requirements
• Allowing SPCB CTO or HW Authorization to expire without timely renewal — invalidates your eligibility for import permission