E-waste EPR for importers and producers in India: who must register, Schedule I codes, targets, certificates and penalties

Extended Producer Responsibility (EPR) for e-waste makes the company that puts electronics on the Indian market pay for recycling them at the end of their life. The law is the E-Waste (Management) Rules, 2022, notified by MoEFCC as G.S.R. 801(E) on 2 November 2022, which replaced the 2016 rules^[1]. The new rules have applied since 1 April 2023^[1].

For an importer, five points cover most of what you need to know:

• Importing to sell makes you a producer. The definition covers anyone who offers to sell imported EEE and its components, consumables, parts and spares, whatever the sales channel, including e-retail^[1].
• You must register before you trade. Producers must register on the CPCB portal, cannot carry on business without registration, and registered businesses may not deal with unregistered ones^[1]. The official portal is eprewaste.cpcb.gov.in^[2].
• You get a yearly recycling target. For 2026-27 it is 70% of the EEE you placed on the market in an earlier reference year, rising to 80% from 2027-28^[1].
• You meet the target by buying certificates. The only way to fulfil EPR is to buy EPR certificates online from registered recyclers and submit them in your quarterly return^[1].
• Shortfalls cost money. CPCB levies environmental compensation (EC) per kg of unmet target, for example Rs 112 per kg for the ITEW group, which holds phones and laptops^[4].

E-waste EPR is only one of three EPR schemes an electronics importer usually meets. The battery inside the device falls under the Battery Waste Management Rules, and the plastic packaging falls under the plastic packaging EPR rules^[1]. Each scheme has its own registration^[5][6], and its own targets and returns, compared below.

2026-27 is the last year at the 70% target before it rises to 80% from 2027-28^[1], the certificate floor price is still being fought in court, and CPCB's own figures show producers falling short. Plan certificate purchases now for the jump.

Producers missed more in 2024-25. CPCB told the NGT that producers met 97% of their 2,67,747 MT obligation for FY 2023-24 but only 86% of 3,46,505 MT for FY 2024-25^[7]. The shortfall is where environmental compensation bites.

The price band is in court. Reports say several large appliance makers have challenged the certificate price band in the Delhi High Court, and that one won an interim stay in December 2025; no final judgment had been reported^[8]. Until a court rules otherwise, the band applies to everyone else.

Returns. The FY 2025-26 return deadline was reportedly extended to 30 September 2026^[9].

Worked example. A producer that placed 100 MT of a product on the market in the reference year needs certificates for 70 MT in 2026-27; if its reference-year sales for 2027-28 are also 100 MT, the need rises to 80 MT^[1]. That is 10 MT more certificates to source in one year. See new rules for 2026 for other changes.

Rule 3(1)(t) defines a producer as any person who, whatever selling technique it uses (dealer, retailer or e-retailer)^[1]:

1. manufactures and sells EEE under its own brand;
2. sells under its own brand EEE made by other manufacturers;
3. offers to sell imported EEE and their components, consumables, parts or spares; or
4. imports used EEE.

The third limb is the one that catches importers. You do not need your own brand to be a producer: offering imported electronics for sale is enough^[1]. The fourth limb catches importers of used equipment, who carry a 100% EPR obligation for the imported material at end of life if it is not re-exported^[1].

The rules apply to manufacturers, producers, refurbishers, dismantlers and recyclers of the EEE listed in Schedule I, including its components, consumables, parts and spares^[1]. They do not apply to:

• waste batteries, which are covered by the Battery Waste Management Rules, 2022;
• packaging plastics, which are covered by the Plastic Waste Management Rules, 2016;
• micro enterprises under the MSMED Act; and
• radioactive wastes^[1].

The micro-enterprise exclusion covers micro enterprises only, not small or medium enterprises^[1]. If your business is a small enterprise that imports electronics, the rules apply to you.

Which role are you?

The table below applies the rule 3 definition to common importer situations. Where the answer depends on facts the rules do not settle, it says so.

Schedule I is the list of electrical and electronic equipment (EEE) the rules cover. Each item has an EEE code made of a category prefix and a number. There are seven categories: ITEW, CEEW, LSEEW, EETW, TLSEW, MDW and LIW^[1]. The code matters because the environmental compensation rate, and with it the floor price of certificates, is set by the category of the product^[4].

The table lists the Schedule I entries that matter most for importers of consumer electronics. The wording in the second column is the wording of the Gazette entry. Three codes (ITEW17, CEEW13 and CEEW18) were matched to their entries by their order in the published table, so check them against the Gazette page before you file^[1].

Several of the most imported gadgets do not appear in Schedule I as separate items. The rules do not name headphones or earphones, chargers or adapters, power banks, smart watches or wearables, CCTV cameras, keyboards or mice, or Bluetooth speakers^[1]. Whether they are covered depends on generic entries, such as PC input and output devices (ITEW2), other sound reproduction equipment (CEEW13), video cameras (CEEW9) or other lighting (CEEW18), and on the fact that the scope extends to components, consumables, parts and spares^[1].

We do not assign an EEE code to these products, because no official source we have found does. We have not been able to verify how CPCB classifies them on the portal^[1]. If you import any of them, ask CPCB or check the item list on the portal when you apply, and keep a record of the answer.

Most household appliances are named in Schedule I, so importers of kitchen and home appliances are e-waste producers just like phone importers. The table lists codes for appliances and other products our readers ask about; the gadget codes are in the tables above.

Two cautions. First, the code decides the product's average life and so its target reference year^[10]. Second, where Schedule I does not name a product, such as induction cooktops or water purifiers, do not pick the nearest code yourself; ask CPCB and keep the answer. Many of these appliances also fall under the household appliances QCO, which needs a BIS ISI licence, and some under the BEE star label.

The producer applies, in its own name. Registration is a condition of doing business, so the importer of record that sells the goods in India should hold it before the goods are offered for sale^[1].

A foreign brand that sells through an Indian importer should check which entity meets the producer definition. The importer that offers imported EEE for sale is caught by rule 3(1)(t) whether or not the brand is its own^[1].

You can hire a producer responsibility organisation (PRO) or a consultant to handle certificate buying and filings. The liability does not move to them: the rules keep EPR liability with the producer even when a PRO is used^[1].

Registration is also needed by manufacturers, refurbishers and recyclers^[1]. This matters to you as a producer because you may buy certificates only from registered recyclers^[1], and you may not deal with unregistered entities^[1].

The official CPCB e-waste EPR portal is the E-Waste Management System at eprewaste.cpcb.gov.in^[2].

Use only the cpcb.gov.in address. CPCB's April 2023 producer SOP names an older address for the portal. When we checked that older domain in October 2026 it was serving an ad-supported blog with no CPCB branding, so we do not link to it and you should not enter company or payment details there^[2].

The steps below follow the rules and CPCB's producer SOP. Screen names on the portal can change, so treat these as the order of work rather than a click-by-click guide.

Our CPCB EPR portal guide and EPR registration checklist go through the screens and the papers.

CPCB's producer SOP asks for the following with the application^[3]:

• Sales data of EEE placed on the market, financial year by financial year, by weight, for a period equal to the average life of the EEE.
• RoHS self-declaration that your products comply with the hazardous-substance limits.
• EN 50581 declaration that the technical documentation is available.
• Awareness plan under rule 6(3).

Keep the underlying records. The sales data drives your targets for years, and CPCB treats false sales data as a separate violation with its own compensation of Rs 20,000 plus Rs 93 per kg of false sales data^[4]. Supplying false information can also lead to revocation of registration for up to three years^[1].

The RoHS limits behind the declaration are 0.1% by weight in homogeneous materials for lead, mercury, hexavalent chromium, PBB and PBDE, and 0.01% for cadmium^[1]. Since the 2023 amendment, the RoHS conformance declaration is provided as and when CPCB asks for it, instead of being printed in the product's user documentation^[14].

Rule 4(6) lets CPCB charge a registration fee and annual maintenance charges based on the capacity of e-waste generated, recycled or handled, as laid down by CPCB with Steering Committee approval^[1]. CPCB's producer SOP sets the fee by the size of your annual e-waste recycling target^[3].

These are government fees only. They do not include the cost of EPR certificates, which is usually the larger cost, or any PRO or consultant charges.

Some consultant websites quote turnover-based slabs of Rs 10,000, Rs 20,000 and Rs 40,000 for e-waste. Those figures are the slabs CPCB uses for battery EPR registration^[15]; we have found no official source that applies them to e-waste^[3].

Processing. If your application is incomplete, CPCB tells you what is missing within 25 working days, and you have 7 working days to reply^[3]. The SOP does not promise a grant date, so plan for queries and do not book sales on the assumption of a fixed approval time.

Validity. A producer's e-waste EPR registration is valid for five years from the date of issue^[3].

Renewal. Apply for renewal on the portal 120 days before the registration expires^[3]. The renewal fee follows the same target-based slabs as the first grant^[3].

Changes during validity. Adding new EEE items or revising targets is an amendment, with a Rs 10,000 processing fee^[3]. On our reading, add new products before you start selling them, since no producer may carry on business without registration^[1].

Revocation. CPCB can revoke a registration for up to three years if you gave false information or concealed facts, on top of environmental compensation^[1].

Your yearly target is a percentage of the weight of EEE you placed on the market in an earlier year. Under Schedule III, the reference year is Y-X, where Y is the target year and X is the product's average life^[1]. A product with a longer average life therefore has an older reference year.

Producers whose sales history is shorter than the product's average life follow Schedule IV instead, which uses recent sales^[1]. Once your years of sales match the average life in CPCB's guidelines, Schedule III applies^[1].

Our e-waste targets guide works through the reference years product by product.

The arithmetic is simple once you have the right reference year. The figures below are invented to show the method; they are not official numbers.

Example 1: established importer (Schedule III). Suppose you have sold laptops (ITEW3) in India for longer than their average life^[1]. For 2026-27 your target is 70% of the laptops, by weight, that you placed on the market in year Y-X^[1]. If that reference year's laptop sales weighed 10,000 kg, your 2026-27 target is 7,000 kg. In 2027-28 the percentage rises to 80%^[1], so the same 10,000 kg base would give 8,000 kg.

Example 2: newer importer (Schedule IV). Suppose you started importing Wi-Fi routers (ITEW22) two years ago^[1], which is less than their average life. From 2025-26 onwards your target is 20% of the sales of the financial year two years earlier^[1]. If your FY 2024-25 router sales weighed 2,000 kg, your 2026-27 target is 400 kg.

Example 3: used equipment. If you import used EEE and do not re-export it, your obligation is 100% of the imported material at end of life^[1].

Then turn the target into certificates. You may buy up to your current-year liability, plus any leftover liability from earlier years, plus 5% of the current-year liability, and you must buy proportionately each quarter^[1]. In practice that means spreading purchases through the year rather than buying everything in the last quarter.

Solar is different. Recycling targets do not apply to waste solar PV modules, panels or cells. Their producers register, store the waste up to 2034-35 and file annual returns instead^[1].

An EPR certificate is the record a registered recycler generates on the portal for e-waste it has processed. You fulfil your EPR only by buying these certificates online from registered recyclers and submitting them through your quarterly return^[1].

Key rules for certificates:

• Denominations. Certificates come in 100, 200, 500 and 1,000 kg denominations (or as CPCB lays down), each with a unique number encoding the year, end-product code and recycler code^[1].
• Validity. A certificate is valid for two years from the end of the financial year in which it was generated^[1].
• Purchase cap. You can buy up to your current-year liability, plus leftover liability from earlier years, plus 5% of the current-year liability^[1].
• Quarterly buying. You must buy proportionately each quarter^[1].
• Refurbishing certificates. Refurbishing certificates defer your EPR for the extended life of the product. After that, 75% of the deferred quantity is added back to your recycling obligation^[1].
• Liability stays with you. Using a PRO does not transfer the liability^[1].

The 2024 amendment, G.S.R. 164(E) of 8 March 2024, added two trading rules^[16]. CPCB fixes the highest and lowest exchange prices for certificates at 100% and 30% of the environmental compensation for not meeting EPR, and portal trades must fall within that band^[16]. The Central Government may also set up one or more platforms for exchanging or transferring certificates^[16].

Because the price band is set at 30% to 100% of environmental compensation^[16], the EC rates in CPCB's e-waste EC guidelines also fix the minimum (floor) and maximum prices of certificates. The floor is 0.3 times the EC for each category^[4].

The approval status and dates of these guidelines conflict across sources. The copy we read, hosted by the Tamil Nadu Pollution Control Board, is dated August 2024 and does not state when MoEFCC approved it. Secondary sources mention a September 2024 notice and say final guidelines were issued in August 2025. We have not found an official notice that settles the date^[4]. Treat the rates below as CPCB's published figures, and check the portal for the rates it applies today.

Producers have challenged the floor price in court. Industry has challenged the floor price in the Delhi High Court. This is reported; we have not verified the case or its outcome^[4].

The same guidelines also set EC by recovered end product. EC is Rs 2,575 per gram of gold, Rs 1,875 per kg of copper, Rs 456 per kg of aluminium and Rs 101 per kg of iron. The floor certificate prices are Rs 772 per gram of gold, Rs 562 per kg of copper, Rs 136 per kg of aluminium and Rs 30 per kg of iron^[4]. These figures are built from a collection and transport cost of Rs 25 per kg plus processing cost^[4].

For a producer, the per-category table above is the one to watch, because it sets the price range for the certificates you buy and the compensation you pay if you fall short.

Producers must file quarterly and annual returns on the portal^[1]. Each return is due by the end of the month after the quarter or year it covers^[1]. The quarterly return is also how you submit the EPR certificates you have bought^[1].

Rule 9A, inserted by the 2024 amendment, lets the Central Government relax the deadline for any return or report, by order, by up to nine further months^[16]. We have not seen a rule 9A order for e-waste returns ourselves. Compliance trackers report that a CPCB notice extended the FY 2025-26 quarterly and annual return deadline on the portal from 30 April 2026 to 30 September 2026^[9]; check the portal before relying on it, and plan to the deadline in the rules otherwise. Diary each date in the compliance calendar.

See EPR annual returns for every e-waste, battery and plastic return in one table.

You may import or place EEE on the market only if it meets the rule 16 hazardous-substance limits. New EEE and its components must not exceed 0.1% by weight in homogeneous materials for lead, mercury, hexavalent chromium, PBB and PBDE, or 0.01% for cadmium^[1]. Components and spares for EEE placed on the market before 1 May 2014 may be exempted^[1].

Since the 2023 amendment (G.S.R. 61(E), 30 January 2023, effective 1 April 2023), the RoHS conformance declaration is provided when CPCB asks for it, rather than in the product's user documentation^[14]. The same amendment added RoHS exemptions for cadmium and lead in solar PV and lead in medical devices^[14]. The Second Amendment Rules, 2023 (G.S.R. 534(E), 24 July 2023) phased in RoHS for medical devices and laboratory instruments through new Schedules II A to II C^[17].

Keep test reports or supplier declarations that support your RoHS self-declaration. You signed it at registration^[3], and CPCB can ask for the declaration at any time^[14].

Other duties. You must run the awareness programme in your plan^[1]. If you hold e-waste yourself, for example returns or damaged stock, you may store it for up to 180 days, which CPCB can extend to 365 days for process development^[1].

The main penalty is environmental compensation (EC), levied by CPCB. There are two kinds.

EC for missing your target. If you do not meet your EPR obligation, EC is charged per kg of shortfall at the rate for the product's category, for example Rs 112 per kg for ITEW and Rs 74 per kg for CEEW^[4]. Paying EC does not end the obligation. Unmet EPR carries forward for up to three years. If you make up the shortfall later, EC is refunded at 85% after one year, 60% after two years and 30% after three years, with no refund after that^[1].

EC for other violations. For violations other than an EPR shortfall, producers face EC of Rs 20,000 for a first default, Rs 40,000 for a second and Rs 80,000 for a third^[4]. False sales data costs Rs 20,000 plus Rs 93 per kg of false sales data^[4].

Unregistered businesses are not exempt. EC can also be levied on unregistered producers, manufacturers, refurbishers and recyclers, and on anyone who aids or abets a violation^[1].

Revocation. CPCB may revoke registration for up to three years for false information or concealment, in addition to EC^[1].

Prosecution. Supplying false information to get EPR certificates, using forged certificates, wilfully breaching directions or not cooperating with an audit may be prosecuted under section 15 of the Environment (Protection) Act, in addition to EC^[1].

A reported 2024 change. MoEFCC is reported to have notified the E-Waste (Management) Second Amendment Rules, 2024 (G.S.R. 699(E), 12 November 2024), which substituted rule 23 so that anyone who fails to comply with or contravenes the rules is liable to a penalty under section 15 of the EP Act^[18]. We have not found this amendment in the Gazette, so treat it as reported until it is confirmed.

CPCB's e-waste division answers portal queries, and producer responsibility organisations and consultants can run the work for you, though the legal duty stays with you. Rule 13(1) lets producers use PROs, collection centres and dealers, but EPR lies entirely on the producer^[10].

• CPCB. The e-waste portal lists [email protected] and a contact number, 43102317^[19].
• Consultants and PROs. One consultant's site lists the Rs 2,500 and Rs 10,000 government fees plus a Rs 5,000 professional fee, as reported on its website^[20]. Compare offers in our EPR consultants guide and read what a producer responsibility organisation does.
• Costs. Our EPR registration cost guide, the compliance cost estimator and the 2026 compliance fee table put certificate and registration costs side by side.
• Small sellers. Read EPR for small importers and our guides for Amazon sellers and Flipkart sellers.
• Is my product covered? Try the HS code approval finder or the approval checker, or ask for a free compliance check.

An importer of a typical rechargeable gadget, such as a phone or laptop, usually needs all three. The device is EEE, the cell inside is a battery under separate rules, and the box and wrapping are plastic packaging^[1]. The three schemes look alike but differ in the details.

A first-time importer of mobile phones. Phones are listed as cellular telephones, ITEW15^[1]. Selling them makes you a producer^[1], so register before the first sale^[1]. If you have no sales history yet, the Rs 10,000 fee for producers whose sales have just started applies^[3], and your targets follow Schedule IV until your sales history matches the product's average life^[1]. The phone's battery also makes you a battery producer^[5].

A marketplace seller importing earphones and power banks. Schedule I does not name either product^[1], so get CPCB's view on coverage and the code before you file, rather than picking one yourself. Both contain batteries, so you are a battery producer whatever the e-waste answer^[5].

A foreign brand selling through an Indian distributor. The Indian entity that imports and offers the goods for sale is a producer under rule 3(1)(t)^[1]. Agree in writing who registers, who buys certificates and who files returns. The producer carries the liability, even if a PRO does the work^[1].