On this page
- Key facts
- How to use this EPR registration checklist
- Which EPR registrations does an importer need?
- EPR registration checklist at a glance: 14 checks and the rule behind each
- In what order should an importer register for EPR?
- Step 1: Work out which rules apply to your products
- Which EPR registrations do common imported electronics need?
- Step 2: Gather the documents all three need
- Step 3: Register for battery EPR
- Step 4: Register for plastic packaging EPR
- Step 5: Register for e-waste EPR
- Step 6: What must you do every year after registering?
- EPR pass marks: the fees, deadlines and limits to meet
- What does it cost to miss an EPR target or return?
- Worked example: registration fees for a small power bank importer
- Worked example: a laptop importer that needs all three registrations
- Common EPR registration mistakes
- What should you do when an EPR check fails?
- Which tools and pages help with EPR registration?
- Frequently asked questions
- Sources
Key facts at a glance
- Battery EPR timing
- Register before importing[1]
- Battery EPR fee
- Rs 10,000 under Rs 5 crore turnover[2]
- Battery registration validity
- Until cancelled[3]
- Plastic EPR fee
- Rs 10,000 under 1,000 TPA[4]
- Plastic registration validity
- 1 year fresh, 3 years renewed[4]
- E-waste EPR fee
- Rs 2,500 under 50 MT target[5]
- E-waste registration validity
- 5 years[5]
- E-waste annual maintenance
- Rs 5,000[5]
- Customs check
- CPCB asked CBIC to verify battery EPR[6]
- Battery returns FY 2025-26
- Extended to 30 November 2026[7]
Checked 2 November 2026 against the regulator's own documents.
How to use this EPR registration checklist
EPR (Extended Producer Responsibility) makes whoever places a product on the Indian market pay for collecting and recycling it at end of life. For an importer, three separate sets of rules can apply to one shipment: the battery inside the product, the plastic it is packed in, and the product itself if it is electrical or electronic equipment. The e-waste rules exclude waste batteries and packaging plastics, which are covered by their own rules[8], so registering under one does not cover the others.
Work out which of the three apply (Step 1), gather the common KYC once (Step 2), then file each registration (Steps 3 to 5). Step 6 covers what you must do every year once registered. For the costs, see EPR registration costs; for small businesses, see EPR for small importers.
Which EPR registrations does an importer need?
Use this table to decide which registrations you need and where each one is filed.
| Battery EPR | Plastic packaging EPR | E-waste EPR | |
|---|---|---|---|
| Who is caught | Importers of batteries or equipment containing batteries[3] | Importers of plastic packaging and of products in plastic packaging[9] | Anyone who offers imported EEE for sale[8] |
| When to register | Before importing[1] | Before doing business[10] | Before carrying on business[8] |
| Application fee | Rs 10,000 / 20,000 / 40,000 by turnover[2] | Rs 10,000 / 20,000 / 50,000 by tonnage[4] | From Rs 2,500, by recycling target[5] |
| Validity | Until cancelled or withdrawn[3] | 1 year fresh, 3 years renewed[4] | 5 years[5] |
| CPCB processing time | Two weeks, then deemed registered[3] | 15 days, then deemed registration[4] | Shortcomings flagged within 25 working days[5] |
| Yearly filing | Form 1(C) and Form 3 by 30 June[3][11] | Annual return by 30 June[10] | Quarterly and annual returns[8] |
EPR registration checklist at a glance: 14 checks and the rule behind each
Fourteen checks cover registration and the first year under the three EPR regimes. Each traces to a rule or CPCB SOP; the third column is the failure we see most. The full rules are on battery EPR, plastic EPR and e-waste EPR.
| Check | Rule | What goes wrong |
|---|---|---|
| Battery producer status decided | Producer definition[3] | Importer of earphones assumes the battery is the factory's problem |
| Battery registration before import | CPCB FAQ[1] | First container lands before Form 1(A) is filed |
| Battery type and chemistry recorded | [11] | Li-ion and Ni-MH lumped together |
| Plastic importer status decided | 2024 definition[10] | Blister packs and polybags ignored |
| Right plastic authority | One or two states: SPCB; more: CPCB[12] | Registered with a state board while selling nationally |
| Plastic categories sorted | [10] | Multilayer pouches entered as rigid |
| E-waste coverage checked by EEE code | Schedule I[13] | Unlisted accessory registered under a guessed code |
| RoHS declaration from the factory | [8][14] | No declaration when CPCB asks |
| KYC consistent across portals | [1][12] | Different addresses on GST and CIN |
| Accurate information | Revocation rules[12][8] | Import tonnage under-declared |
| EPR number on product or pack | [15] | Number not sent to the factory before printing |
| Returns diarised | [3][10][8] | First 30 June deadline missed |
| Certificates bought from registered recyclers | [8] | Relying on a PRO's promise without certificates |
| Renewal dates set | [4][5] | Plastic registration lapses after its first year |
In what order should an importer register for EPR?
Register for battery EPR first, then plastic, then e-waste if it applies. Battery comes first because CPCB expects it before import and has asked Customs to check it[6].
- 1List products and packaging
For each product note whether it has a battery, the packaging plastics and the Schedule I EEE code if any. The approval checker flags all three.
- 2
- 3Pull import data from Bills of Entry
Weights by financial year for batteries, packaging and EEE. Bills of Entry are kept five years anyway[16].
- 4
- 5File plastic EPR
On the CPCB EPR portal with the right authority[12]; processed within 15 days[4]. Plastic filing is reported to have moved to the Common EPR Portal at epr.cpcb.gov.in after the old plastic portal shut on 28 June 2026[17]. See the CPCB EPR portal.
- 6
- 7Send numbers to the factory
Put the battery EPR number and plastic details on the artwork; check it with the label checker.
- 8Diarise returns and renewals
Add every return and renewal date to the compliance calendar.
Step 1: Work out which rules apply to your products
Which EPR registrations do common imported electronics need?
Almost every imported gadget triggers plastic EPR through its packaging, and most trigger battery EPR. E-waste EPR depends on whether the product is named in Schedule I. The table shows common cases.
| Product | Battery EPR | Plastic EPR | E-waste EPR |
|---|---|---|---|
| Bluetooth earphones | Yes[19] | Yes[9] | Not named; possibly CEEW13[13] |
| Power banks | Yes[19] | Yes[9] | Not named; unclear[13] |
| Smartwatches | Yes[19] | Yes[9] | Not named; possibly TLSEW4 or ITEW17[13] |
| Mobile phones | Yes[19] | Yes[9] | Yes, ITEW15[8] |
| Laptops | Yes[19] | Yes[9] | Yes, ITEW3[8] |
| Wi-Fi routers | Portable units only[19] | Yes[9] | Yes, ITEW22[13] |
| UPS and inverters | UPS with internal batteries, likely[19] | Yes[9] | Yes, ITEW24 or ITEW25[8] |
| LED bulbs | Rechargeable only[19] | Yes[9] | Likely CEEW18[13] |
| Solar panels | No | If plastic-packed | Register; recycling targets do not apply[8] |
Step 2: Gather the documents all three need
The three portals ask for overlapping KYC. Collect it once, in PDF, and keep the same legal name and address everywhere.
Step 3: Register for battery EPR
Battery EPR comes first because it must be in place before you import[1], and CPCB has asked Customs to check it at clearance[6]. Full detail: battery EPR.
Step 4: Register for plastic packaging EPR
Plastic EPR has the most registrations on the portal: as of 25 June 2026 there were 62,175 PIBOs, of which 52,935 were importers[22]. Full detail: plastic EPR.
Step 5: Register for e-waste EPR
E-waste registration is filed on CPCB's E-Waste Management System[18]. Full detail: e-waste EPR.
Step 6: What must you do every year after registering?
Registration is the easy part. Each regime then needs returns and, for e-waste and batteries, EPR certificates bought from registered recyclers. See EPR annual returns.
EPR pass marks: the fees, deadlines and limits to meet
These are the numbers that decide whether an EPR registration is complete and stays valid. All fees exclude GST.
| Item | Battery | Plastic | E-waste |
|---|---|---|---|
| Smallest application fee | Rs 10,000 under Rs 5 crore turnover[2] | Rs 10,000 under 1,000 TPA[4] | Rs 2,500 under 50 MT target; Rs 10,000 for new sellers[5] |
| Recurring charge | Renewal fee equals registration fee[2] | 25% of application fee each year[4] | Rs 5,000 a year[5] |
| Decision time | Two weeks, then deemed[3] | 15 days, then deemed[4] | Shortcomings within 25 working days[5] |
| Validity | See battery EPR | One year fresh, three years renewed[4] | Five years[5] |
| Renew by | Before expiry | Four months before expiry[4] | 120 days before expiry[5] |
| Returns | Form 1(C) and Form 3 by 30 June[11] | By 30 June[10] | Quarterly and annual[8] |
| Certificate life | Seven years[11] | Same category only for surplus[12] | Two years after the FY of generation[8] |
What does it cost to miss an EPR target or return?
Missing a target or a return brings environmental compensation (EC), which does not cancel the obligation. Shortfalls carry forward, and EC is partly refunded only if you make them up later[12][11][8]. The environmental compensation entry explains the mechanism.
| Breach | Rate | Rule |
|---|---|---|
| Plastic EPR target shortfall | Rs 2,900/t (Cat I), Rs 5,000/t (Cat II), Rs 7,900/t (Cat III and IV); doubled then tripled for repeats | [23] |
| Plastic annual return not filed | Rs 5,000, then Rs 10,000 after the notice period | [23] |
| Battery breach other than shortfall (returns, labels) | Rs 20,000, Rs 40,000, Rs 80,000 for first to third default | [24] |
| Li-ion battery shortfall | Lithium Rs 2,400 per kg recovered metal; cobalt, nickel, manganese Rs 555 | [24] |
| E-waste shortfall, IT equipment | Rs 112 per kg (ITEW); Rs 74 (CEEW) | [25] |
| E-waste breach other than shortfall | Rs 20,000, Rs 40,000, Rs 80,000 | [25] |
| Unregistered producer | EC can be levied on unregistered producers too | [8] |
Worked example: registration fees for a small power bank importer
A trading company with turnover under Rs 5 crore imports power banks in plastic blister packs and sells in five states. Its first-year registration fees would be:
| Registration | Why it applies | Fee | Source |
|---|---|---|---|
| Battery EPR | Power banks contain lithium cells; importer of equipment containing batteries | Rs 10,000 (turnover under Rs 5 crore) | [2] |
| Plastic EPR (with CPCB, as it sells in more than two states) | Imported goods in plastic packaging | Rs 10,000 (under 1,000 TPA) | [4][12] |
| Plastic annual processing fee | Paid with the annual return | 25% of the application fee | [4] |
| E-waste EPR | Power banks are not named in Schedule I; coverage unclear | Confirm with CPCB first | [8] |
- 1Register battery EPR first
Battery EPR must be in place before the first import, so it goes first.
- 2Register plastic EPR with CPCB
Operating in more than two states means CPCB, not a state board, handles the registration.
- 3Ask CPCB about e-waste
Get a written view on whether power banks fall under a Schedule I entry before deciding on e-waste registration.
- 4Diarise the returns
Battery Form 1(C) and Form 3, and the plastic annual return, are due by 30 June each year.
Worked example: a laptop importer that needs all three registrations
A distributor with Rs 20 crore turnover starts importing laptops in plastic-wrapped cartons and sells in eight states. Laptops are Schedule I code ITEW3[8] and contain lithium-ion batteries[19], so all three regimes apply.
- Battery EPR: Rs 20,000 for the Rs 5-50 crore turnover band[2].
- Plastic EPR with CPCB (more than two states[12]): Rs 10,000 under 1,000 TPA[4], then 25% of that, Rs 2,500, each year with the return[4].
- E-waste EPR: Rs 10,000 as a producer whose sales have just started[5], plus the Rs 5,000 annual maintenance charge[5].
Registration and first-year charges come to Rs 20,000 + Rs 10,000 + Rs 2,500 + Rs 10,000 + Rs 5,000 = Rs 47,500 before GST. The bigger cost is later: as a new seller, its e-waste targets follow Schedule IV[8], met only by buying certificates from registered recyclers[8]. A shortfall on IT equipment carries EC of Rs 112 per kg[25]. The laptops page covers BIS and the reported import authorisation, and EPR registration costs compares fee bands.
Common EPR registration mistakes
- Registering for e-waste and assuming the battery is covered. It is not; waste batteries are outside the e-waste rules[8].
- Importing first, registering later. For batteries CPCB expects registration before import[1].
- Leaving the EPR number off the product. Battery EPR numbers had to be marked by 31 March 2025[3].
- Forgetting renewal. A fresh plastic registration lasts only one year[4].
- Treating environmental compensation as a fee. Paying EC does not discharge the EPR obligation; it carries forward[8].
Non-filing has a cost: for battery-rule breaches other than a target shortfall, EC is Rs 20,000 for a first default[24].
What should you do when an EPR check fails?
Fix the registration first, then the paperwork that depends on it. These are the usual failures and their fixes.
| Failed check | Fix | Read more |
|---|---|---|
| Goods arriving with no battery registration | File Form 1(A) at once; CPCB must decide within two weeks[3] | Battery EPR |
| Registered with the wrong plastic authority | Re-register with CPCB if you operate in more than two states[12] | CPCB EPR portal |
| CPCB flags shortcomings on e-waste | Reply within 7 working days[5] | E-waste EPR |
| Return deadline missed | File at once; check for a central extension, as for battery returns FY 2025-26[7] | EPR annual returns |
| Target shortfall | Buy certificates within the purchase cap[8][11] | E-waste targets |
| PRO did not deliver | The liability stays with you[26] | Producer responsibility organisation |
| Unsure whether a product is covered | Get a written view before registering under a guessed code | Free compliance check |
Which tools and pages help with EPR registration?
The approval checker and HS code approval finder flag which EPR regimes a product triggers. The compliance cost estimator adds EPR fees to BIS and WPC costs. Targets are explained on battery targets, plastic targets and e-waste targets. If you prefer to outsource, see EPR consultants. The rest of a first import is in the first electronics import checklist.
Frequently asked questions
Do I need battery EPR if I only import earphones with a small built-in battery?
How much does battery EPR registration cost?
The application fee depends on turnover: Rs 10,000 under Rs 5 crore, Rs 20,000 for Rs 5-50 crore and Rs 40,000 above Rs 50 crore[2].
Who do I register with for plastic EPR, CPCB or the state board?
How long is each EPR registration valid?
Will Customs ask for my EPR registration?
What documents does e-waste EPR registration need?
Sales of EEE by weight for each year of the product's average life, RoHS self-declarations with EN 50581 documentation, and an awareness plan[5].
Is a micro enterprise exempt from EPR?
What happens if CPCB does not process my application?
Does registering for e-waste EPR cover the battery inside my product?
No. Waste batteries are excluded from the e-waste rules and governed by the Battery Waste Management Rules[8], so you need a separate battery registration.
What is the penalty for not filing a plastic EPR annual return?
CPCB sends a notice 5 days after the deadline, then levies environmental compensation of Rs 5,000 for the next 5 days and Rs 10,000 for the following 10 days[23].
How long are EPR certificates valid?
Can a producer responsibility organisation take over my EPR liability?
No. Rule 13(1) of the 2022 e-waste rules lets producers use PROs, collection centres and dealers, but says EPR lies entirely on the producer[26]. Keep the certificates and returns in your own name.
Sources 26 documents, 23 official
Each number in the text links to the document below. Labels show the type of source; see our editorial policy.
- Official portal CPCB FAQs (General) under Battery Waste Management Rules, 2022
- Official portal CPCB SOP for Registration of Producers through the Online Portal under BWM Rules, 2022
- Gazette Battery Waste Management (Amendment) Rules, 2023 - S.O. 4669(E) · 25 October 2023
- Official portal CPCB SOP for Registration of Producer, Importer & Brand Owners through Plastic EPR Portal (15 Mar 2022) · 15 March 2022
- Official circular CPCB SOP for grant of registration to Producers under E-Waste (Management) Rules, 2022 (April 2023; copy hosted by Pollution Control Board Assam) · 1 April 2023
- Official circular CPCB letter dated 23 Dec 2022 to CBIC on clearing battery import consignments · 23 December 2022
- Official circular MoEFCC Office Memorandum dated 27 Aug 2026 - extension of annual return timeline under BWM Rules, 2022 · 27 August 2026
- Gazette E-Waste (Management) Rules, 2022 - G.S.R. 801(E), Gazette of India (CPCB copy) · 2 November 2022
- Gazette G.S.R. 133(E): Plastic Waste Management (Amendment) Rules 2022 - Guidelines on EPR for Plastic Packaging (copy hosted by TNPCB) · 16 February 2022
- Gazette Plastic Waste Management (Amendment) Rules, 2024 - G.S.R. 201(E) (gazette copy hosted by TNPCB) · 14 March 2024
- Gazette Battery Waste Management Rules, 2022 - S.O. 3984(E), Gazette of India · 22 August 2022
- Gazette Plastic Waste Management (Amendment) Rules, 2022 - G.S.R. 133(E) inserting Schedule II EPR Guidelines · 16 February 2022
- Gazette E-Waste (Management) Rules, 2022 (G.S.R. 801(E)) incl. Schedule I · 2 November 2022Not yet confirmed officially
- Gazette E-Waste (Management) Amendment Rules, 2023 - G.S.R. 61(E) · 30 January 2023
- Official circular CPCB Notice dated 28 May 2024 on MoEFCC OM of 17 May 2024 (recycled material and labelling) · 28 May 2024
- Official circular JNCH Public Notice No. 85/2018 (23.05.2018) · 23 May 2018
- Reported Enviliance: India's Plastic Packaging EPR Online Portal Migrates to EPR Common Portal · 28 June 2026Not yet confirmed officially
- Official portal CPCB E-Waste Management System portal (home page)
- Gazette Battery Waste Management Rules, 2022 (S.O. 3984(E)) · 22 August 2022Not yet confirmed officially
- Official portal DGFT Handbook of Procedures (FTP 2023), Chapter 2 - General Provisions Regarding Imports and Exports (file HBP_07_2026_Chapter_02)
- Gazette Battery Waste Management Amendment Rules, 2025 - S.O. 958(E) · 24 February 2025
- Court order CPCB compliance report to NGT in O.A. 993/2024 with O.A. 926/2024 (dated 06.07.2026) · 6 July 2026
- Official circular CPCB Revised Guidelines for Assessment of Environment Compensation for Violation of PWM Rules, 2016 (August 2024)
- Official circular CPCB Notice (10 Sep 2024) enclosing Guidelines for Environment Compensation under BWM Rules, 2022 (August 2024) and MoEFCC concurrence of 9 Sep 2024 · 10 September 2024
- Official circular CPCB Guidelines for Environment Compensation (EC) under E-Waste (Management) Rules, 2022 (August 2024; copy hosted by TNPCB)
- Gazette E-Waste (Management) Rules, 2022 (G.S.R. 801(E)) · 2 November 2022