Silver oxide
Silver oxide primary cells and batteries
HSN 8506 40 00 (silver oxide primary cells and batteries) is covered by a Bureau of Indian Standards Quality Control Order. Conformity to IS 8144:2018 is mandatory under the ISI Mark Scheme, with the QCO obligation tracing to the Ministry of Consumer Affairs notification dated 25 May 1987. Extended Producer Responsibility authorisation under the Battery Waste Management Rules and the E-Waste Management Rules applies as a separate customs-clearance overlay administered by the Central Pollution Control Board.
- 1Source only from a Bureau of Indian Standards CM/L-licensed manufacturer holding a current licence against IS 8144:2018 for multipurpose dry batteries. Verify the supplier's CM/L number, licensed product scope, and manufacturing facility address on the BIS online register before placing the purchase order.IS 8144:2018 · BIS notification F.No.BS/11/11/2018 dated 04-06-2018, Ministry of Consumer Affairs, Food and Public Distribution
- 2Ensure every silver oxide cell and battery bears the ISI mark and the supplier's CM/L number under Scheme-I of Schedule-II to the BIS (Conformity Assessment) Regulations, 2018. Marking must appear on the product or its primary packaging; marking on outer cartons alone does not satisfy the requirement.BIS (Conformity Assessment) Regulations, 2018, Scheme-I of Schedule-II · S.O. 516(E) dated 25-05-1987
- 3Obtain Extended Producer Responsibility authorisation from the Central Pollution Control Board under the Battery Waste Management (Amendment) Rules, 2023 before import. EPR certificates must be current and in force on the date of the bill of entry.Battery Waste Management (Amendment) Rules, 2023 · S.O. 3984(E) dated 22-08-2022 · S.O. 4669(E) dated 25-10-2023
- 4Verify separately whether EPR authorisation under the E-Waste Management Rules, 2022 is triggered by the product category. Micro enterprises as defined in the MSMED Act, 2006 are exempt from both EPR obligations; document the exemption basis if relied upon.Schedule-I of the E-Waste Management Rules, 2022 · G.S.R. 801(E) dated 02-11-2022 · G.S.R. 338(E) dated 23-03-2016
- 5Quote the supplier's BIS CM/L number and the CPCB EPR authorisation reference on the bill of entry. Customs verifies the CM/L in real time against the BIS register; an absent, expired, or scope-mismatched CM/L triggers consignment detention.BIS Act, 2016 · Customs Act, 1962 · Battery Waste Management (Amendment) Rules, 2023
The most common failure on this tariff line is treating the Battery Waste Management EPR obligation as the headline compliance item while overlooking the underlying BIS QCO. IS 8144:2018 governs the product itself; an importer who secures EPR authorisation but sources from a manufacturer whose CM/L is lapsed, facility-specific scope is mismatched, or does not cover the silver oxide chemistry will face detention and potential confiscation regardless of EPR status. Confirm CM/L scope maps precisely to silver oxide chemistry and cell size before the purchase order, not at the port.