Question 1

What are the Battery Waste Management Rules, 2022, and when did they take effect?

Accepted Answer

They are the central rules governing waste batteries, notified by the Ministry of Environment, Forest and Climate Change on 22 August 2022 under the Environment (Protection) Act, 1986, and in force from their publication in the Official Gazette. They replace the earlier Batteries (Management and Handling) Rules, 2001 and apply across battery chemistries.

Question 2

Which batteries and which entities do the Rules cover?

Accepted Answer

The Rules cover all battery types - portable, automotive, industrial and electric-vehicle batteries. They apply to producers, dealers and consumers, and to every entity involved in the collection, segregation, transportation, refurbishment and recycling of waste batteries.

Question 3

What is Extended Producer Responsibility (EPR) under the Rules?

Accepted Answer

EPR makes the producer responsible for the environmentally sound management of the batteries it places on the market. Producers must register with the Central Pollution Control Board (CPCB) and meet the collection and recycling or refurbishment targets set out in Schedule II, either themselves or through authorised entities - but the obligation always remains with the producer.

Question 4

How do EPR certificates work?

Accepted Answer

Registered recyclers and refurbishers generate EPR certificates for the quantities of waste battery they process against the applicable recovery targets. Producers discharge their EPR obligations using these certificates and may purchase surplus certificates from others to meet a shortfall, within the limits prescribed by the Rules.

Question 5

Can waste batteries be sent to landfill or incinerated?

Accepted Answer

No. The Rules prohibit the disposal of waste batteries in landfills and by incineration. Waste batteries must be channelled to environmentally sound refurbishment or recycling, and recovered materials must meet the minimum recovery targets prescribed for each battery type.

Question 6

Do the Rules mandate the use of recycled material in new batteries?

Accepted Answer

Yes. Producers must ensure a minimum use of domestically recycled materials in new batteries, measured against the total dry weight of the battery and phased in over time. This recycled-content obligation is a deliberate step towards a circular battery economy rather than mere end-of-life disposal.

Question 7

What are the consequences of non-compliance?

Accepted Answer

Failure to meet EPR obligations attracts Environmental Compensation on a polluter-pays basis, determined in line with Schedule II and CPCB guidelines. Paying environmental compensation does not extinguish the underlying obligation - the producer must still fulfil its collection and recovery targets.

Question 8

What is BRSR Core, and how is it different from BRSR?

Accepted Answer

BRSR Core is a focused sub-set of BRSR, a set of Key Performance Indicators (KPIs) across nine ESG attributes, designed to standardise quantified disclosures and enable their verification and comparability.

Question 9

Which companies must report BRSR Core, and from when?

Accepted Answer

BRSR Core is mandatory for the top 1,000 listed entities by market capitalisation (as on March 31 of the relevant financial year), from FY 2022-23 onward. Third-party verification of BRSR Core has been phased in by market-cap tier, covering all top 1,000 listed entities from FY 2026-27.

Question 10

What are the nine ESG attributes covered under BRSR Core?

Accepted Answer

(1) GHG footprint, (2) Water footprint, (3) Energy footprint, (4) Waste management/circularity, (5) Employee wellbeing and safety, (6) Gender diversity, (7) Inclusive development (MSME/local sourcing), (8) Fairness to customers and suppliers, (9) Openness of business (concentration/related-party transactions).

Question 11

Is Green Credit disclosure part of the nine BRSR Core attributes?

Accepted Answer

No, Green Credits introduced by the SEBI March 2025 circular (SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42) under Principle 6 of BRSR is a voluntary Leadership Indicator in the broader BRSR framework, it is not one of the nine mandatory BRSR Core attributes.

Question 12

What changed for assurance requirements in March 2025?

Accepted Answer

Previously, BRSR Core required reasonable “assurance” only. But, the March 2025 circular (SEBI/HO/CFD/CFD-PoD-1/P/CIR/2025/42) allows companies to obtain either “assessment” or “assurance,” two alternative third-party verification routes. Assessment follows standards developed by the Industry Standards Forum (ISF, comprising ASSOCHAM, FICCI, and CII) in consultation with SEBI; assurance follows the applicable assurance framework.

Question 13

Who is a “value chain” partner?

Accepted Answer

Under the revised March 2025 framework, a value-chain partner is any upstream or downstream partner individually accounting for 2% or more of the entity’s total purchases or sales. Earlier, the framework covered partners cumulatively accounting for 75% of purchases or sales. Entities may still voluntarily limit disclosures to partners representing 75% of purchases or sales.

Question 14

Who is required to make value-chain ESG disclosures, and is it mandatory?

Accepted Answer

Value-chain ESG disclosures apply to the top 250 listed entities by market capitalisation. Under the July 2023 framework, disclosure was on a “comply-or-explain” basis, but the March 2025 framework made such disclosures fully voluntary, with no comply-or-explain requirement.

Question 15

Is there a separate framework for value chain?

Accepted Answer

No, SEBI did not create a separate ESG framework for the value chain, it extends the same nine BRSR Core KPIs to the specified portion of the entity’s value chain, reported only to the extent attributable to the listed entity’s business with those partners.

Question 16

What relief exists for first-year value-chain reporting?

Accepted Answer

For companies that choose to report value-chain ESG data first time, reporting of the previous year’s comparative figures is voluntary, companies are not required to reconstruct historical value-chain data they may not have previously collected.

Question 17

What must accompany a voluntary value-chain disclosure?

Accepted Answer

Companies must disclose the percentage of its total purchases and total sales that are covered by the value-chain partners for which ESG data is being reported. This indicates how representative the reported data is of the company’s actual purchasing/ sales activity, given that companies now have flexibility on how much of the value chain to cover.

Question 18

What is the CCTS and when was it notified?

Accepted Answer

The Indian Carbon Market has been operationalised under the Carbon Credit Trading Scheme (CCTS). It was notified on June 28, 2023 by the Ministry of Power under the Energy Conservation (Amendment) Act, 2022. It replaces the earlier PAT (Perform, Achieve and Trade) energy efficiency scheme.

Question 19

What are the market segments of CCTS?

Accepted Answer

CCTS operates in two market segments - the compliance market and the offset market. The compliance market is for obligated entities, and the offset market is for voluntary players.

Question 20

Who is mandatorily covered under the compliance mechanism?

Accepted Answer

Currently, nine sectors are notified for operating in the compliance market: aluminium, chlor-alkali, cement, fertiliser, iron & steel, pulp & paper, petrochemicals, petroleum refining, and textiles. Obligated entities and their units have been identified under these sectors and targets have been notified, except for the fertiliser and iron & steel sectors.

Question 21

What is a Carbon Credit Certificate (CCC) and what does it represent?

Accepted Answer

A CCC is the tradeable unit under CCTS. Each certificate represents one tonne of CO₂ equivalent (tCO₂e) reduced or removed beyond an entity's assigned emissions intensity target. CCCs can be traded on designated power exchanges under the oversight of the Central Electricity Regulatory Commission (CERC).

Question 22

How are targets set for obligated entities under the CCTS? Is it a cap-based system or a rate-based system?

Accepted Answer

It is an intensity-based (rate-based) scheme and not an absolute cap. Obligated entities are assigned GHG emissions intensity targets expressed as tonnes of CO₂e per unit of output. The targets have been notified under the GHG Emission Intensity Target Rules 2025 for the first two compliance years FY2025–26 and FY2026–27, using FY2023–24 as the baseline.

Question 23

What is the offset mechanism and who can participate?

Accepted Answer

Non-obligated entities - those outside the mandatory sectors - can voluntarily register projects to generate CCCs. BEE has published the first set of offset methodologies.

Question 24

How will the price of CCCs be determined in the compliance market?

Accepted Answer

Prices will be determined by market forces. Demand and supply of CCCs will determine the price at which CCCs will be traded. There will be a floor price and a forbearance price fixed by CERC on the recommendation of BEE.

Question 25

What are floor price and forbearance price?

Accepted Answer

They determine the range within which the price of CCCs will vary. The floor price is the lower limit beyond which the price of CCCs cannot drop, in order to protect the market from crashing. The forbearance price is the higher limit beyond which the price of CCCs cannot increase, thereby avoiding unchecked spikes and market turbulence.

Question 26

Can the same entity operate in the compliance market and voluntary offset market?

Accepted Answer

There is no restriction per se at an entity level for operating in both markets. Of course, there should not be double counting. However, an obligated entity may face challenges in the additionality test to enter the voluntary market, in which case the specifics have to be examined in detail before reaching a conclusion.

Question 27

Can any entity from any industry generate credits from the voluntary market?

Accepted Answer

There is no restriction regarding the business, industry or constitution of the entity registering with the voluntary market. However, there are more nuanced factors - determining the methodology, having a robust monitoring, reporting and verification (MRV) system in place, taking care of additionality and double counting risks - which have to be considered and fulfilled. With a firm strategy and clear pathway in place, any entity can monetise its emission reduction in the voluntary market.

Question 28

What is the Ecomark and what do the Ecomark Rules, 2024, do?

Accepted Answer

The Ecomark Rules, 2024 were notified by the Ministry of Environment, Forest and Climate Change vide G.S.R. 596(E) on 26 September 2024 under the Environment (Protection) Act, 1986, and took effect on publication in the Official Gazette. They establish an eco-labelling scheme: an 'Ecomark' may be granted to a product that meets specified environmental criteria - reduced pollution and emissions, recyclability or recycled content, lower use of non-renewable resources, and reduced use of environmentally harmful materials. The stated purpose is to help consumers make informed choices, encourage greener production, and curb misleading information about the environmental aspects of products (Rules 1 and 3).

Question 29

What must a product satisfy to be granted the Ecomark?

Accepted Answer

Under Rule 3, a product must (a) hold a licence or certificate of conformity to the relevant Indian Standard under the Bureau of Indian Standards Act, 2016 and/or the applicable Quality Control Order issued by the Central Government, and (b) meet the product-specific criteria set out in column (3) of the First Schedule. Those criteria can address pollution reduction, recyclability or recycled content, reduced use of non-renewable resources, and substitution of hazardous materials - and are framed considering the production process and raw-material sources, natural-resource use, environmental impact, waste and emissions, disposal and packaging, and Extended Producer Responsibility compliance where applicable (Rule 3).

Question 30

Who administers the Ecomark, and how long does it last?

Accepted Answer

Applications are made to the Central Pollution Control Board (CPCB) in Form 1 (Rule 4). CPCB - itself or through a registered verifier - checks compliance and a report is submitted within sixty days; if satisfied, CPCB grants the Ecomark. An Ecomark is valid for three years or until the Ecomark criteria for that product change, whichever is earlier, and is renewable (Rule 4). Holders file an online annual report to CPCB, which compiles them with its recommendations for the Ministry by 31 July each year. A Central Government Steering Committee oversees implementation (Rule 7). CPCB may suspend or cancel an Ecomark for false information or wilful concealment after a hearing, with an appeal to the Central Government within thirty days (Rule 5).

Question 31

When is 'consent' required under India's water-pollution law, and from whom?

Accepted Answer

Under section 25 of the Water (Prevention and Control of Pollution) Act, 1974, no person may - without the previous consent of the State Pollution Control Board - establish any industry, operation, process or treatment and disposal system likely to discharge sewage or trade effluent into a stream, well, sewer or on land; bring a new or altered outlet into use; or begin a new discharge. The Board may grant consent subject to conditions or refuse it for reasons recorded in writing, and if it does not decide within four months the consent is deemed to have been given (section 25(7)). Separately, section 24 prohibits knowingly causing or permitting poisonous, noxious or polluting matter to enter a stream, well, sewer or land.

Question 32

What did the 2024 amendment change for water-pollution offences?

Accepted Answer

The Water (Prevention and Control of Pollution) Amendment Act, 2024 (Act 5 of 2024, in force from 15 February 2024) decriminalised most offences, replacing imprisonment with monetary penalties. Contraventions of section 24 (pollution) or the section 25/26 consent requirements now attract a penalty of not less than ten thousand rupees and up to fifteen lakh rupees, with an additional ten thousand rupees per day for continuing contraventions (sections 42, 43, 44 and the residual section 45A). Penalties are determined by a Central Government-appointed adjudicating officer of at least Joint Secretary / State Secretary rank after a hearing (section 45B), and appeals lie to the National Green Tribunal (section 45C). The amendment also lets the Central Government, in consultation with CPCB, exempt certain categories of industrial plants from the consent requirement (proviso to section 25(1)).

Question 33

What does the Energy Conservation Act say about using a deceptive name resembling the Bureau of Energy Efficiency?

Accepted Answer

Section 13A of the Energy Conservation Act, 2001 ("Prohibition of use of deceptive name, etc.") bars two things. First, no person may - without the previous permission of the Bureau of Energy Efficiency - use any name that so nearly resembles the Bureau's name as to deceive, or be likely to deceive, the public (section 13A(1)). Second, notwithstanding anything in any other law in force, no registering authority may register any company, firm or other body of persons bearing a name or mark resembling the name of the Bureau (section 13A(2)). In short, the Bureau's identity is protected: you cannot trade on, or register an entity under, a confusingly similar name without the Bureau's prior consent.

Question 34

What is the "Energy Management Centre" under the Energy Conservation Act?

Accepted Answer

Under section 2(l) of the Energy Conservation Act, 2001, the "Energy Management Centre" is the body originally set up under a Government of India Resolution of the erstwhile Ministry of Energy (Department of Power), No. 7(2)/87-EP(Vol. IV) dated 5 July 1989, and registered as a society under the Societies Registration Act, 1860. It was the predecessor institution for the country's energy-efficiency work. When the Bureau of Energy Efficiency was established under the Act, section 12 transferred the Centre to the Bureau: its assets and properties vest in the Bureau, its rights, liabilities, debts, contracts, dues and pending legal proceedings pass to the Bureau, its employees continue in the Bureau on the same terms, and any reference to the Energy Management Centre in other laws or contracts is now read as a reference to the Bureau.

Question 35

What is the EU Packaging and Packaging Waste Regulation (PPWR)?

Accepted Answer

The PPWR is the European Union's new regulation governing the entire lifecycle of packaging, from design and manufacture to reuse, recycling, and waste management. It replaces the previous Packaging and Packaging Waste Directive and aims to reduce packaging waste while promoting a circular economy.

Question 36

To whom is PPWR applicable? When is it effective from?

Accepted Answer

PPWR applies to all packaging, regardless of the material used, and to all packaging waste, regardless of where it comes from and whether it originates from industry, manufacturing, retail, distribution, offices, services, or households. PPWR entered into force on February 11, 2025, and its primary general application and enforcement date is August 12, 2026.

Question 37

Does PPWR require packaging to be recyclable?

Accepted Answer

Yes, but in two stages. From 1 January 2030, all packaging placed on the EU market must be designed so it can be recycled. From 1 January 2035, it must go a step further and be recyclable at scale, meaning it's not just theoretically recyclable, but gets collected, sorted, and recycled in practice across the EU.

Question 38

Are there mandatory recycled content requirements under PPWR?

Accepted Answer

Yes. Plastic packaging must contain a minimum share of recycled content from 2030 onwards. Depending on the category of packaging (as specified in the Regulation), this requirement ranges from 10% to 30%, rising further from 2040 to as high as 65% for certain categories.

Question 39

Does PPWR regulate substances used in packaging?

Accepted Answer

Yes. PPWR requires the substances of concern in packaging to be kept to a minimum overall and sets specific limits. For example, there is a combined cap on lead, mercury, cadmium, and hexavalent chromium, plus restrictions on PFAS in food-contact packaging from August 2026. Suppliers will accordingly be expected to furnish documented proof of compliance within these limits.

Question 40

Does PPWR restrict excessive packaging?

Accepted Answer

Yes. Packaging must be limited to the minimum volume and weight necessary to perform its function. This is assessed against factors defined in the Regulation, such as product protection, safety, hygiene, and proper handling, not left to the manufacturer's own judgment. Features like unnecessary layers, false bottoms, double walls, and excessive empty space are specifically targeted.

Question 41

What documentation is required under PPWR?

Accepted Answer

Before placing packaging on the EU market, manufacturers must carry out a conformity assessment against the Regulation's requirements, compile supporting "technical documentation", covering the packaging's design, materials, intended use, and risk assessment, along with test reports, and draw up a written EU Declaration of Conformity for each packaging type, retaining both for inspection by authorities.

Question 42

Does PPWR introduce new labelling requirements?

Accepted Answer

Yes. PPWR establishes harmonised labelling requirements to help consumers identify packaging materials and sort packaging waste correctly. For instance, a material-composition pictogram will help consumers sort waste correctly from 2028, and reusable packaging (like returnable bottles) will need to carry a "reusable" label along with a QR code or other digital carrier.

Question 43

Who is responsible for compliance under PPWR?

Accepted Answer

PPWR defines several categories of "economic operator", such as manufacturer, importer, distributor, and others with different obligations applying to each. Manufacturers are primarily responsible for conformity assessment and technical documentation, while importers and distributors must verify compliance before placing or making packaging available on the EU market. Other categories also exist. Suppliers must provide manufacturers with the information needed to prove compliance, and fulfilment service providers must ensure their handling doesn't compromise it.

Question 44

How will PPWR affect Indian businesses exporting to the EU?

Accepted Answer

Although PPWR is an EU regulation, its impact is likely to extend to Indian businesses that place packaged products on the EU market through importers, distributors, or direct sales channels. Indian exporters may increasingly face requests relating to recyclability, recycled content, packaging composition, conformity documentation and supply chain traceability as EU customers seek to meet their own compliance obligations.

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