EPR for small importers: which thresholds and exemptions really apply, and what a small business actually has to do

Yes, in almost every case that matters to an electronics importer. EPR in India is triggered by what you do (import and sell), not by how big you are. Under the battery rules, a producer includes anyone who imports batteries or equipment containing batteries^[11]. Under the plastic rules, importers of plastic packaging and of the plastic packaging of imported products are obligated^[6]. Under the e-waste rules, a producer includes anyone who offers imported electrical and electronic equipment for sale^[4].

The size-based reliefs that do exist are narrower than many small businesses assume, and the most common one, the micro-enterprise exclusion in the e-waste rules, is not obviously available to a trader. What size does change is the fee you pay and, through your import volumes, the size of your obligation.

This article goes rule by rule: what relief exists, who qualifies, and then what a small importer actually has to do each year. For the forms and steps, use the EPR registration checklist; for the regimes themselves, see battery EPR, plastic EPR and e-waste EPR.

Only one size-based exemption exists, in the e-waste rules, and it covers micro enterprises only. The other two regimes offer lower fees, not exemptions.

Usually battery and plastic EPR, plus e-waste EPR for products named in Schedule I. The table applies the cited rules to common products. Our approval checker does the same for other products.

Possibly, if it is a micro enterprise under the MSMED Act, but a pure trader may not qualify. The E-Waste (Management) Rules, 2022 apply to manufacturers, producers, refurbishers, dismantlers and recyclers, but do not apply to micro enterprises as defined in the MSMED Act^[4]. The exclusion covers micro only, not small enterprises.

The official Udyam portal gives the limits from 1 April 2025 as investment up to Rs 2.5 crore and turnover up to Rs 10 crore for micro, and Rs 25 crore and Rs 100 crore for small^[5], matching earlier reports^[16]. On those numbers, many small importers would look "micro".

The difficulty is that MSME status under the MSMED Act is built around manufacturing and services. When retail and wholesale traders were brought into the MSME definition in July 2021, it was only for the limited purpose of priority sector lending, as RBI's circular records^[7]. A pure trading importer may therefore not be a micro enterprise for other legal purposes, and we found no CPCB guidance saying traders can use the e-waste exclusion. Treat it as unclear, and get CPCB's view in writing before relying on it.

Even if you qualify, the exclusion covers e-waste only. The battery inside the product and the plastic around it are governed by separate rules^[4].

It costs nothing, so it is worth having if you also assemble, service or manufacture, but it is not an EPR exemption by itself. The Udyam portal states that registration is free and paperless, and that one enterprise may not file more than one registration^[5].

Udyam matters more for BIS than for EPR. Scheme-I marking fee concessions of 80% for micro and 50% for small enterprises run until 31 May 2029^[17], and DPIIT set a common Udyam exemption threshold in eight QCOs in February 2026^[18]. Note that those QCO exemptions apply to goods made by the Udyam-registered enterprise, not to imported goods. See ISI mark fees and the QCO tracker.

Not directly. Since 2024 the plastic rules list producers of plastic packaging "other than micro and small enterprises" and brand owners "other than micro and small enterprises", but importers of plastic packaging and of the packaging on imported products appear without that carve-out^[6]. For micro and small producers, EPR is met by the manufacturer or importer of the plastic raw material supplied to them^[6]. That shifts obligations up the chain to raw-material suppliers, which is the opposite of what helps a small finished-goods importer.

The scale of registrations reflects this. As of 25 June 2026 the plastic EPR portal had 62,175 registered PIBOs, of which 52,935 were importers^[8]. The rules were amended again on 31 March 2026^[19]; see plastic EPR targets for what changed.

No. The Battery Waste Management Rules apply to all batteries regardless of chemistry, shape, volume, weight, material composition or use^[12], and CPCB's FAQ says importers of batteries and of equipment containing batteries must register before importing^[9]. A shipment of 500 Bluetooth earphones makes you a battery producer.

There is one route to having no obligation: CPCB's FAQ says an importer does not carry EPR obligations where its buyers resell under their own brand; the obligation arises when the importer sells under its own brand or the imported brand, supplies others selling under its brand, or supplies bulk consumers directly^[9]. Most small importers selling online under their own or the factory's brand are inside the obligation. See battery EPR targets for the percentages.

Registration fees are set by size bands, so small importers pay the lowest slab: Rs 10,000 each for battery and plastic, and Rs 2,500 for e-waste. All figures exclude GST.

Certificates are the real cost, and their price is bounded by law at 30% to 100% of environmental compensation. Producers fulfil e-waste EPR only by buying EPR certificates from registered recyclers; the liability stays with you even if a PRO handles it^[4]. CPCB fixes the highest and lowest e-waste certificate prices at 100% and 30% of the environmental compensation for non-fulfilment^[20]. For IT and telecom equipment (ITEW), EC is Rs 112 per kg, so the floor price is Rs 34 per kg^[21]. For Li-ion batteries, EC is set per kg of recovered metal, for example Rs 2,400 for lithium with a credit band of Rs 720 to Rs 2,400^[10].

For a new importer, targets start small. Producers whose sales history is shorter than the product's average life follow Schedule IV, which from 2025-26 is 20% of sales of the financial year two years earlier^[4]. Battery targets for consumer-electronics batteries are 70% of placement five years earlier from 2024-25^[22], and a new producer's targets apply by average battery life^[22]. For plastic, an importer's eligible quantity is based on average imports over the last two years^[23].

Certificates keep differently: battery certificates are valid for seven years^[12], e-waste certificates for two years from the end of the year they were generated^[4]. See EPR registration costs and the compliance cost estimator for worked figures.

A small importer bringing in its own-brand power banks for the first time would typically face two registrations and two returns in year one, with small or nil recycling targets. The table uses only cited fees and rules; the volumes are illustrative.

On CPCB's EPR portals, all reached through one login at epr.cpcb.gov.in^[25]. Plastic EPR used to have its own 'Centralized EPR Portal for Plastic Packaging' at eprplastic.cpcb.gov.in^[26]; CPCB is reported to have shut it on 28 June 2026 and moved plastic registration and filing, with users' data, to the Common EPR Portal at epr.cpcb.gov.in, and a 27 August 2026 notice reportedly made registration there mandatory^[27]. If you registered on the old portal, log in to the common portal and check that your migrated data is correct. Battery EPR is on the 'EPR Portal for Battery Waste Management' at eprbattery.cpcb.gov.in^[25]. E-waste EPR is on the 'E-Waste Management System' at eprewaste.cpcb.gov.in^[28].

KYC is light: battery registration needs the company's PAN, CIN and GST^[9], and plastic registration adds the authorised person's Aadhaar and PAN^[23]. Plastic registration goes to the state board if you operate in one or two states, and to CPCB if more^[23]; units in different states register separately^[23]. Our CPCB EPR portal guide walks through the screens.

Register before the first import, mark products, keep weight records and file returns by 30 June. Stripped down, the yearly workload for a small electronics importer is:

Each step comes from the rules or CPCB's procedures. Battery registration is in Form 1(A), valid until cancelled^[11], with KYC of PAN, CIN and GST^[9] and deemed registration after two weeks^[11]. Plastic registration goes to the state board or CPCB depending on how many states you operate in^[23]. E-waste registration is mandatory before carrying on business^[4]. Battery marking for imports can go on the equipment or its packaging^[24], or in a QR code^[29]. Returns: battery Form 1(C)^[11] and annual return^[12], plastic annual return^[6], all by 30 June; e-waste returns are quarterly and annual^[4]. Certificates must be bought proportionately each quarter^[4].

Deadlines do move. The battery annual return for FY 2025-26 was extended to 30 November 2026^[30], and the government can relax return deadlines by up to nine months^[11]. Our EPR annual returns guide has the filing calendar.

Most dates cluster around 30 June, with renewals spread across the year. Put these in your diary, or use the compliance calendar and the licence renewal date tool.

They can do the work, but the legal liability stays with you. The e-waste rules let producers use third parties such as producer responsibility organisations, but say EPR lies entirely on the producer^[31]. The battery rules let a producer authorise another entity for collection or recycling, but the obligation to meet targets stays with the producer^[32]. The plastic guidelines do not use the term PRO at all; only certificates from registered plastic waste processors count^[33].

For a small importer, outsourcing the filings is often sensible. Choose on track record and transparency of certificate sourcing, not price alone. Our EPR consultants directory lists firms, and the glossary entry on PROs explains the term.

The common ones are registering in the wrong place, guessing weights and forgetting the labels. Each has a cited rule behind it:

• One registration for several states or sub-categories. An entity in more than one plastic sub-category must register separately for each, and units in different states register separately^[23]. Opening a second warehouse in another state can change your plastic registration authority too^[23].
• Estimated figures in the application. False information or concealment can get a plastic registration revoked for one year, with no re-registration in that time^[23], and an e-waste registration revoked for up to three years on top of EC^[4]. Build every number from Bills of Entry.
• Forgetting the plastic label. Plastic packaging of imported goods must show the producer's or brand owner's name and registration number^[34]; since 1 July 2025 this can go in a barcode or QR code^[35]. Our product label checklist and label checker cover it with the BIS and Legal Metrology marks.
• Assuming recycled content in imports counts. For importers, recycled plastic in imported material does not count towards the recycled-content obligation; they buy certificates instead^[19].
• Treating a PRO's work as a transfer of liability. It is not, as the section above explains.

Customs checks, environmental compensation and show-cause notices, regardless of size.

• At the port. CPCB has asked CBIC to have Customs verify battery EPR registration^[36] and plastic EPR registration^[8]. Keep the certificates with your customs clearance documents.
• Environmental compensation for paperwork failures. Under the battery rules, not filing returns or not following labelling draws EC of Rs 20,000 for a first default, rising for later ones^[10]. The e-waste rules use the same Rs 20,000, Rs 40,000 and Rs 80,000 ladder for producers^[21]. Missing the plastic annual return brings a notice and then EC that escalates by the day^[37].
• EC for unmet targets. For plastic, Rs 2,900 to Rs 7,900 per tonne depending on category, doubled for a second default^[37]. Paying it does not remove the obligation; unmet EPR carries forward and EC is partly refunded only if you catch up^[23].
• Unregistered businesses are not safe. EC can be levied on unregistered producers too^[4].
• Enforcement is active. CPCB issued revised show-cause notices in March 2026 to PIBOs that had not met obligations or filed returns for FY 2022-23^[8].

Assume you are in. Budget for two registrations (battery and plastic) at the lowest slabs, decide e-waste carefully, and put your energy into clean import records by weight, because that is what every return and target is built on. If you sell on marketplaces, keep the EPR certificates in the same file as your BIS and Legal Metrology papers; see Amazon compliance documents, before listing on Flipkart and compliance for first-time importers. Not sure which regimes apply to your catalogue? Ask us for a free compliance check.