EPR consultants in India: what they and PROs actually do for e-waste, battery and plastic, what it costs and how to vet them

An EPR consultant handles your registrations and filings on CPCB's portals: e-waste, battery and plastic packaging. In practice that means registering you as a producer or importer, entering sales data, filing quarterly or annual returns, and buying EPR certificates from registered recyclers or processors to meet your targets.

What a consultant cannot do is take over your legal obligation. The e-waste rules let producers use third parties such as producer responsibility organisations, collection centres and dealers, but say EPR lies entirely on the producer^[1]. The battery rules say the same: a producer may authorise another entity for collection or recycling, but the obligation stays with the producer^[12]. If your consultant files late or buys bad certificates, the environmental compensation notice comes to you.

This page is a guide, not a directory. It covers which EPR regimes hit importers, the difference between a consultant, a PRO and a recycler, the CPCB portals, fees, deadlines and penalties, the fake-certificate problem, what consultants charge and how to vet them. For product-by-product detail, see e-waste EPR, battery EPR and plastic EPR, and our product pages such as power banks, laptops and Bluetooth earphones.

Most electronics importers need two or three. Battery EPR applies whenever batteries or equipment containing batteries are imported; plastic EPR applies to the packaging; e-waste EPR applies to equipment listed in Schedule I.

A consultant does paperwork. A PRO organises collection. A recycler or processor actually generates the certificates that count.

• Producer Responsibility Organisation. The 2016 e-waste rules defined a PRO as a professional organisation authorised or financed by producers to collect and channel e-waste from their end-of-life products^[16]. The 2022 rules still allow producers to use PROs, but EPR stays with the producer^[1].
• Recycler. Under the 2022 e-waste rules, producers meet EPR only by buying EPR certificates online from registered recyclers and filing them through the quarterly return^[10]. CPCB reported 381 registered e-waste recyclers in August 2025^[17].
• Plastic waste processor. The plastic EPR guidelines do not use the term PRO at all; only certificates from registered plastic waste processors count^[18].
• Consultant. Not defined in any EPR rule. Their job is your portal login, data and filings.

Many firms sell all three roles in one invoice. That is legal, but ask which part is advice, which part is a certificate purchase, and from which registered recycler or processor the certificates come.

Most of the job is portal work, and CPCB has made it easier to do yourself than it used to be. CPCB says single sign-on for all its EPR portals is live at epr.cpcb.gov.in, with FAQs and user manuals on the common portal^[3].

On the battery portal, login is by role (producer, recycler or refurbisher), and producers sign up as importer or manufacturer^[3]. CPCB's battery FAQ says an importer enters its own brand names in Form 1(A), not the imported battery's brand^[19], and that there is no separate certificate beyond the Form 1(B) registration^[19]. KYC for battery registration is the company's PAN, CIN and GST^[14]; for plastic it is the company's PAN, GST and CIN plus the authorised person's Aadhaar and PAN^[13].

If your consultant leaves and you cannot log in, both the battery and e-waste portals have a 'Lost Credentials' route^[3]. Insist that the login is registered to your company's email and authorised person, not the consultant's. See our CPCB EPR portal guide.

Manufacturers, producers, refurbishers and recyclers must register on the CPCB portal and may not do business without it^[10]. The fee depends on your annual recycling target: under 50 MT Rs 2,500; 50 to under 100 MT Rs 7,500; 100 to under 1,000 MT Rs 1,50,000; 1,000 to under 5,000 MT Rs 10,00,000; above 5,000 MT Rs 15,00,000; and Rs 10,000 for producers whose sales have just started^[5]. There is a Rs 5,000 annual maintenance charge^[5] and Rs 10,000 for amendments such as adding EEE items^[5].

You must give sales by weight for a period equal to each product's average life, RoHS self-declarations and an awareness plan^[5]. CPCB tells you of shortcomings within 25 working days and you get 7 working days to reply^[5]. Registration lasts five years, with renewal due 120 days before expiry^[5].

Which products? Schedule I lists items by EEE code, for example laptops (ITEW3)^[10] and mobile phones (ITEW15)^[10]. It does not separately name earphones, chargers, power banks or smartwatches^[10]. A good consultant will tell you that coverage of those items is a judgment call, not a certainty. See e-waste EPR targets.

CPCB's FAQ says importers of batteries and of equipment containing batteries are producers and must register before importing^[14]. An importer has obligations when it sells under its own brand, supplies others who sell under its brand, supplies bulk consumers, or sells under the imported brand name^[14]. Even importing batteries for in-house use requires registration and annual returns, per CPCB^[19].

The fee is Rs 10,000 under Rs 5 crore turnover, Rs 20,000 for Rs 5 to 50 crore, and Rs 40,000 above Rs 50 crore^[6]. Registration is in Form 1(A); since 2023 the Form 1(B) certificate is valid until cancelled^[8]. CPCB must register within two weeks of a complete application, after which it is deemed done unless refused^[8].

There is also a labelling job your consultant should flag: batteries must be marked with the producer's EPR registration number^[8], and for imported batteries the number can go on the equipment or its packaging^[21]. See battery EPR targets.

Importers of plastic packaging, of intermediate material and of the plastic packaging on imported products are covered^[15]. A PIBO operating in one or two states registers with the state board through the central portal; one operating in more than two registers with CPCB^[13]. Units in different states and different sub-categories register separately^[13].

The application fee is Rs 10,000 under 1,000 TPA, Rs 20,000 for 1,000 to 10,000 TPA and Rs 50,000 above^[7], plus 25% of it every year with the annual return^[7]. Applications are processed within 15 days under the SOP, with deemed registration if not processed in time^[7]. A fresh registration lasts one year and a renewed one three years^[7].

Scale check: as of 25 June 2026, 62,175 PIBOs were registered, of whom 52,935 were importers^[22]. Importers are the bulk of this market, which is why consultants chase them. See plastic EPR targets.

Returns are where most consultant relationships succeed or fail, because they repeat every year.

You meet targets by buying certificates on the portal, not by paying the consultant to 'take care of it'. For e-waste, certificates come only from registered recyclers^[10], are valid for two years after the financial year they were generated in^[10], and you may buy only up to your liability plus a 5% margin^[10]. Battery certificates are valid for seven years^[9].

Prices are banded. CPCB fixes the highest and lowest exchange prices of e-waste certificates at 100% and 30% of the environmental compensation^[23], and the same band applies to battery^[25] and plastic certificates^[15]. For e-waste, the floor is Rs 34 a kg for IT equipment (ITEW) and Rs 22 a kg for consumer electronics (CEEW)^[26]. A consultant quoting a certificate price below the floor is either wrong or not trading on the portal. Some large producers have reportedly challenged the e-waste price band in the Delhi High Court^[27].

You pay environmental compensation, not the consultant. Paying it does not cancel the obligation.

Increasingly, yes. CPCB asked CBIC in December 2022 to have Customs verify CPCB registration when clearing batteries and equipment containing batteries^[30]. In June 2025 it asked CBIC to have Customs verify plastic EPR registration for importers' consignments^[22]. So a consultant who registers you after the goods ship is late. Add EPR certificates to your customs clearance documents.

Yes, mostly in plastic. The NGT registered a case on a July 2024 news report headlined '6 lakh fake pollution-trading certificates unearthed in three States', and in CPCB's July 2026 report in that case, the Gujarat board records closing one processor, levying Rs 5.74 crore of environmental damage compensation for fake recycling credit certificates, revoking its consents and debarring its plastic EPR registration for a year^[11].

The market is large. As of 25 June 2026, 3,079 plastic waste processors were registered, with 237.95 lakh tonnes of certificates generated since inception and 178.48 lakh tonnes transferred to PIBOs^[11]. CPCB also issued revised show-cause notices in March 2026 to PIBOs over FY 2022-23 obligations and returns^[22].

What this means for you: ask your consultant which registered processor or recycler each certificate comes from, check it on the portal, and do not accept certificates priced below the floor. A PIBO that gives false information is revoked for a year^[13].

There is no official rate. Published prices are low entry points that usually exclude government fees and certificate purchases.

• Professional Utilities advertises e-waste EPR for importers from Rs 9,999^[31] and battery EPR for importers from Rs 9,999^[32].
• Another Professional Utilities e-waste page lists a Rs 5,000 professional fee^[33].

Read the government figures on these pages critically. The e-waste importer page shows a turnover-based fee table (Rs 10,000 / 20,000 / 40,000)^[31], which matches CPCB's battery slabs^[6], not CPCB's e-waste fee, which goes by target tonnage from Rs 2,500^[5]. Both pages say CPCB issues registration within 30 days^[32], while the battery rules say two weeks, then deemed registration^[8]. A quote is only as good as its understanding of the rules.

Official timelines are short; real ones depend on your data being ready.

This order keeps the registration in your name and your obligations visible.

A brand imports TWS earphones worth under Rs 5 crore a year.

• Battery EPR: The earbuds and case contain lithium batteries, so the importer is a producer^[34]. Fee: Rs 10,000^[6].
• Plastic EPR: Packaging in plastic makes it an importer under the plastic rules^[15]. Under 1,000 TPA the fee is Rs 10,000^[7].
• E-waste: Earphones are not separately named in Schedule I^[10]; reportedly they may fall under CEEW13^[35]. The consultant should explain the choice in writing.

CPCB fees: Rs 20,000 for battery and plastic, plus Rs 2,500 for e-waste if registered under 50 MT^[5]. Add certificates and the consultant's fee on top.

A distributor imports laptops under the brand's name.

• E-waste: Laptops are ITEW3^[10]. ITEW EC is Rs 112 a kg, so certificates cannot trade below Rs 34 a kg^[26].
• Battery: Laptops contain lithium-ion batteries^[34]. Whether the distributor or the brand is the producer depends on whose brand the goods are sold under^[14].
• Plastic: Required for the packaging.

The consultant's first job is deciding who the producer is, not filing. Get that wrong and two companies register for the same goods, or none does.

A small trader importing LED bulbs assumes being an MSME exempts it. It does not for imports: micro and small enterprises are excluded as plastic packaging producers and brand owners, but importers are covered^[15]. Traders were added as MSMEs only for priority sector lending^[36]. LED lamps reportedly fall under e-waste code CEEW18^[35]. See EPR for small importers.

1. Whose login? The portal account must be in your company's name^[3].
2. Which fee table? Ask them to quote CPCB's e-waste fee by tonnage^[5]; a turnover table for e-waste is a red flag^[31].
3. Where do certificates come from? Registered recyclers or processors only^[18], within the price band^[23].
4. Who is liable? You are^[1]. Ask what the contract says if they miss a return.
5. Deadlines. They should know the 30 June dates and current extensions^[24].
6. Labelling. They should raise the battery EPR number on packs^[8].

Compare with BIS consultants, WPC consultants and LMPC consultants; one importer often needs all four.

Add CPCB fees, annual charges, certificate purchases and the consultant fee. Our compliance cost estimator and EPR registration costs page do this per product; the EPR registration checklist lists the documents. For the full fee table across approvals, see India compliance fees 2026.

Comploa is an independent reference site. CPCB and the state boards decide every registration; we cannot influence them. We offer a free compliance check through our contact page: tell us your products and we will tell you which EPR regimes apply, the CPCB fees and the deadlines, with sources. If you want filing help, we can introduce a partner; their fee and any certificate purchases are separate and agreed with them. See our services.

No official list of approved EPR consultants or PROs exists for battery or plastic EPR; Comploa found none. The '6 lakh fake certificates' figure is a newspaper headline that named the NGT case, not a CPCB finding quoted in its report^[11]. Published consultant prices are starting prices and may not reflect real quotes^[32]. Tell us through contact if you have better sources.