EPR annual and quarterly returns in India: every e-waste, battery and plastic filing, deadline and penalty

An electronics importer is often registered under three EPR schemes at once: e-waste for the device, battery for the cell inside, and plastic packaging for the box and wrapping^[1]. Each scheme has its own return, on its own CPCB portal, with its own deadline. The table lists every return in one place.

The registered producer files, and for imports that is usually the importer. Each scheme defines it slightly differently:

• E-waste. A producer includes anyone who offers imported electrical and electronic equipment for sale^[1]. If you import laptops or Bluetooth earphones and sell them, the returns are yours.
• Battery. Importers of batteries and battery-containing equipment are producers^[3]. CPCB's FAQ says the importer has the obligation when it sells under its own or the imported brand or supplies bulk consumers, but not when buyers resell under their own brand^[12].
• Plastic. An importer is anyone importing plastic packaging, or any commodity with plastic packaging, for commercial use^[6]. That is almost every importer of boxed goods.

Marketplace sellers who buy from an Indian importer usually do not file themselves, but platforms ask for the importer's registrations. See Amazon seller compliance, Flipkart seller compliance and compliance for distributors.

Producers under the E-Waste (Management) Rules, 2022 must file quarterly and annual returns on the CPCB portal^[1]. Each is due by the end of the month after the quarter or year it covers^[1]. The portal is eprewaste.cpcb.gov.in^[13].

What goes in. The quarterly return is how you submit the EPR certificates you bought from registered recyclers against your target^[1]. You must buy certificates proportionately each quarter^[1], so each quarterly return should show a share of the year's target. The rules do not let a PRO file away your liability; it stays with you even if a PRO does the work^[1].

Extensions. Rule 9A, added in March 2024, lets the Central Government relax the deadline for any return or report by up to nine further months, by order^[2]. For FY 2025-26, compliance trackers report a CPCB notice that moved the quarterly and annual return deadline from 30 April 2026 to 30 September 2026^[10]. We have not opened the notice itself, so treat the date as reported and confirm it on the portal.

Solar PV. Producers of solar PV modules, panels and cells have no recycling target, but must register, store the waste up to 2034-35 and file annual returns^[1].

Battery producers, which include importers of batteries and of equipment containing batteries^[3], file two forms each year.

Form 1(C). By 30 June each year, the quantity and weight of batteries you manufactured, assembled or imported in the preceding financial year (rule 4(7) as amended in 2023)^[3]. This is the data CPCB uses for your future targets.

Form 3 annual return. By 30 June of the next financial year, a return to CPCB and the State Pollution Control Board on waste batteries collected and recycled or refurbished, with details of the recyclers whose EPR certificates you bought^[4]. Pre-consumer waste batteries from manufacturing, assembly or import are reported here too^[3].

Extensions. Rule 14(6), inserted in 2023, lets the Central Government relax return deadlines by order by up to nine months^[3]. The Form 3 deadline has been extended for every year shown below. We have not found an extension for Form 1(C).

Producers, importers and brand owners (PIBOs) of plastic packaging file an annual return on plastic packaging waste collected and processed under EPR by 30 June of the next financial year. It includes certificate details for plastic sent for recycling or end-of-life disposal^[6]. Plastic waste processors file by 30 April^[6].

Importers of electronics in plastic packaging are PIBOs, and unlike producers and brand owners they have no exemption for micro and small enterprises^[6].

Fee with the return. PIBOs pay 25% of their application fee as an annual processing fee when they file the annual return^[7]. On the CPCB SOP's application fee slabs of Rs 10,000, Rs 20,000 and Rs 50,000^[7], that works out to Rs 2,500, Rs 5,000 or Rs 12,500.

Renewal depends on returns. Renewal of a PIBO registration needs all annual returns to be filed^[7].

Extensions. The 2024 amendment allowed FY 2022-23 returns to be filed until 31 March 2024^[6]. For FY 2025-26, TeamLease RegTech reports a MoEFCC order of 28 August 2026 extending the deadline to 31 December 2026 for PIBOs and 31 October 2026 for plastic waste processors^[11]. We have not seen the order itself, so file as early as the portal allows.

Enforcement is live. CPCB issued revised show-cause notices on 11 March 2026 to PIBOs for non-fulfilment of obligations and non-filing of annual returns for FY 2022-23^[16].

Every figure in a return has to trace back to a document. Keep this file for each financial year:

Each scheme has its own portal and login: e-waste at eprewaste.cpcb.gov.in^[13], battery at eprbattery.cpcb.gov.in^[20] and plastic at eprplastic.cpcb.gov.in^[21]. Screens change often; our CPCB EPR portal guide has the current layout.

These are the dates set in the rules for the current financial year, with no extensions assumed. Copy them into the compliance calendar.

Illustrative, our arithmetic. An importer of power banks has three registrations, because the device, the Li-ion cell and the packaging each fall under a different scheme^[1].

Its filing year. Four e-waste quarterly returns plus an e-waste annual return, battery Form 1(C) and Form 3, and one plastic annual return: seven filings across three portals, plus quarterly certificate purchases.

Fixed portal costs. The e-waste annual maintenance charge is Rs 5,000^[19]. Under 1,000 tonnes of plastic it pays a Rs 10,000 plastic application fee^[7], so the annual processing fee with the plastic return is Rs 2,500^[7].

If it misses all three annual returns once. Plastic EC of Rs 5,000 then Rs 10,000^[8], battery EC of Rs 20,000^[9] and e-waste EC of Rs 20,000 for a first non-shortfall violation^[22]: about Rs 55,000 in total, before any EC for unmet targets. Unmet targets are priced separately on the battery targets, e-waste targets and plastic targets pages.

For the full picture of what a power bank importer needs beyond EPR, see the power bank import guide and lithium-ion battery packs.

Plastic. CPCB's revised EC guidelines set out a step scale for not filing the annual return. A notice goes out five days after the deadline. EC of Rs 5,000 then applies for the next five days and Rs 10,000 for the following ten days. For a second default these are doubled (Rs 10,000 and Rs 20,000) and for a third quadrupled (Rs 20,000 and Rs 40,000)^[8]. CPCB levies EC on PIBOs operating in more than two states; SPCBs and PCCs levy it on PIBOs in one or two states^[23]. Since the 2025 amendment, anyone who fails to comply with the plastic rules is also liable to a penalty under section 15 of the Environment (Protection) Act^[24].

Battery. Not filing annual returns is listed as a non-compliance other than an EPR shortfall. EC is Rs 20,000 for a first default, Rs 40,000 for a second and Rs 80,000 for a third, rising 10% every year^[9]. Late payment of EC carries interest of 12% or 24% a year, and after three months the unit can be closed^[9].

E-waste. CPCB's e-waste EC guidelines set EC for violations other than an EPR shortfall at Rs 20,000, Rs 40,000 and Rs 80,000 for producers' first, second and third defaults^[22]. The fact we hold does not list late or missing returns by name, so check the guidelines for how CPCB treats a missed e-waste return. Because certificates are submitted through the quarterly return^[1], a missed return can also leave your target unmet on the record, and target shortfalls draw EC per kg^[22]. False sales data carries EC of Rs 20,000 plus Rs 93 per kg^[22].

Shortfalls carry forward. Paying EC does not cancel the obligation. Under the e-waste rules, EC is refunded at 85%, 60% or 30% if you make up the shortfall after one, two or three years^[1]; under the battery and plastic rules, at 75%, 60% or 40%^[4][23].

1. Waiting for an extension that never comes. Extensions are issued by order, often late, and are not guaranteed^[3]. Prepare to the rule date.
2. Filing e-waste only once a year. The quarterly return is how certificates count^[1], and purchases must be proportionate each quarter^[1].
3. Missing Form 1(C). It feeds next year's battery targets^[3]. An empty or late Form 1(C) leaves CPCB to work from incomplete data.
4. Mismatched numbers across schemes. If customs data shows 10,000 power banks but the battery return shows 6,000, expect questions. Customs has been asked to check battery and plastic EPR registrations at clearance^[25][16].
5. Leaving it to a consultant without access. Liability stays with the producer even where a PRO helps^[1]. Keep your own portal login and check filings yourself; compare providers on EPR consultants.
6. Forgetting registration renewal. E-waste registrations last five years and must be renewed 120 days ahead^[19]; plastic renewal needs all returns filed^[7]. The licence renewal date tool works out the window.

Yes, indirectly. A plastic registration is renewed only if every annual return has been filed^[7], and a fresh plastic registration lasts one year, so a first-year importer meets this test quickly. E-waste registrations last five years with renewal applied for 120 days before expiry^[19], and CPCB can revoke a registration for up to three years for false information or concealment^[1]. A battery registration is valid until cancelled^[3], but non-filing still draws EC^[9].

Without a live registration you cannot deal with registered recyclers or sellers: e-waste entities may not deal with unregistered ones^[1].

Customs checks registration rather than returns, but the two are linked. CPCB asked CBIC in December 2022 to have Customs verify battery EPR registration on consignments of batteries and battery-containing equipment^[25], and in June 2025 to verify plastic EPR registration for importers^[16]. A registration that has lapsed for want of returns can therefore hold a shipment. Our guide to why shipments get held at Indian ports and the customs clearance documents checklist cover what to keep ready.

• Battery FY 2025-26 moved to 30 November 2026 by MoEFCC OM of 27 August 2026^[5], after 30 September 2025 for the year before^[14].
• E-waste FY 2025-26 moved to 30 September 2026, as reported^[10].
• Plastic FY 2025-26 moved to 31 December 2026 for PIBOs, as reported^[11].
• Brand owners now report virgin and recycled plastic in rigid packaging in the annual return^[18].
• Show-cause notices went to PIBOs on 11 March 2026 for FY 2022-23^[16].

Every dated change across Indian import rules is on new rules for 2026. For costs, see EPR registration costs and the compliance cost estimator; small businesses should read EPR for small importers and the EPR registration checklist. If you are behind on returns, ask for a free compliance check.