E-waste EPR targets year by year: the schedule, the maths, certificate prices and what a shortfall costs

Schedule III of the 2022 rules sets the recycling target as a share, by weight, of the electrical and electronic equipment (EEE) you placed on the market in an earlier year, year Y minus X, where X is the product's average life^[1]. The rules came into force on 1 April 2023^[1].

Two schedules exist because many producers have not been selling long enough to have sales from one product-life ago.

• Schedule III applies once your sales history is at least as long as the product's average life. Target as above^[1].
• Schedule IV applies while your sales history is shorter. It was 15% of FY 2021-22 sales for 2023-24, 20% of FY 2022-23 sales for 2024-25, and from 2025-26 onwards it is 20% of the sales of the financial year two years earlier. You move to Schedule III once your sales years equal the average life^[1].
• Imported used EEE carries a 100% end-of-life obligation if it is not re-exported^[1].
• Solar panels and cells have no recycling target. Producers register, store the waste up to 2034-35 and file annual returns instead^[1]. CPCB treats their average life as 15 years^[4].

You are a producer if you sell imported EEE in India, whatever the sales channel^[1]. If you are unsure whether your products are covered, start at EPR e-waste.

Your target is set on the CPCB portal from three inputs: the sales data you file, the product's life period as laid down by CPCB, and the Schedule III or IV percentage. Where your data and a recycler's data differ, the lower figure counts^[5].

At registration, CPCB's SOP asks for financial-year sales by weight going back one average life, per CPCB's table on the portal. Its own example: if an item's average life is 5 years and you file in FY 2023-24, you give sales from FY 2018-19. A chartered accountant certifies the quantities^[6].

CPCB's per-product average-life table is shown inside the portal against each EEE code. We have not found it in a public CPCB document; the indicative values further down this page come from a consultancy's reproduction, partly marked draft. Check yours when you add items to your registration. Note that the rules list items by EEE code, and some popular products (earphones, chargers, power banks, smart watches) are not named as separate items^[1]. See EEE code.

The official table lives on the portal, but a compliance consultancy's reproduction of CPCB's table gives the values below. Part of it is labelled draft, so treat every figure as indicative and use the life your own portal account shows^[7]. The 'reference year' column is our arithmetic: 2026-27 minus the life in years.

Because the target is measured against sales from one product-life ago, a short life pulls the reference year close to today and a long life pushes it back^[1]. A fast-growing LED importer with a 3-year life is measured against recent, larger sales; a router importer with a 10-year life is measured against sales from a decade ago, which for a young business may be zero. That is exactly when Schedule IV takes over^[1].

When products that are not named in Schedule I sit under a generic code (earphones, power banks, smart watches, CCTV cameras)^[1], the code you pick also picks the average life. Choose the code that genuinely describes the product; the EEE code glossary and the product pages for CCTV cameras and Bluetooth earphones explain the usual mapping.

This is an illustration with made-up sales, using a 5-year average life only because CPCB's SOP uses that figure in its example. Use the life period shown for your own EEE code.

Facts assumed. An importer has sold laptops since 2018. Average life on the portal: 5 years (assumed). Laptops sold in FY 2021-22: 10,000 kg.

Target. For 2026-27, year Y-X is 2021-22, so the target is 70% of 10,000 kg = 7,000 kg^[1].

Floor cost of meeting it. Laptops fall in the IT and telecom category (ITEW), where CPCB's EC is Rs 112 per kg and the floor certificate price Rs 34 per kg^[3]. At the floor, 7,000 kg of certificates costs at least Rs 2,38,000. At the ceiling (100% of EC) it would be Rs 7,84,000^[2].

Cost of not meeting it. A full shortfall of 7,000 kg at the ITEW EC rate is Rs 7,84,000, and the obligation still carries forward^[1].

If the importer started in 2023 instead. It would be on Schedule IV: for 2026-27, 20% of FY 2024-25 sales by weight^[1].

Figures exclude GST and portal charges. Registration fees are on EPR registration costs.

Illustrative figures and our arithmetic.

Facts assumed. A company began importing Wi-Fi routers in FY 2023-24. It sold 3,000 kg that year and 8,000 kg in 2024-25. Reported average life: 10 years^[7]. Its sales history is far shorter than the product life, so Schedule IV applies^[1].

2025-26 target. 20% of sales two years earlier (2023-24): 0.20 x 3,000 kg = 600 kg.

2026-27 target. 20% of 2024-25 sales: 0.20 x 8,000 kg = 1,600 kg.

Certificate cost. Routers are IT and telecom equipment, so at the ITEW floor of Rs 34 per kg^[3], 1,600 kg costs at least Rs 54,400; at the Rs 112 ceiling, Rs 1,79,200^[2].

Registration fee. A target under 50 tonnes sits in the lowest CPCB fee slab, Rs 2,500^[8].

The same importer also needs MTCTE and WPC approvals for routers, which the router import guide covers.

Illustrative. Targets and prices are per EEE category, so a mixed catalogue needs separate sums.

You cannot meet e-waste EPR by collecting waste yourself. Producers fulfil it only by buying EPR certificates online from registered recyclers and filing them through the quarterly return, and liability stays with the producer even if a PRO helps^[1].

Buy quarterly, in proportion to the yearly target, because the rules require proportionate purchases each quarter and cap the total at current liability plus leftovers plus 5%^[1].

Separate from certificates, CPCB charges these portal fees^[1]:

The E-Waste (Management) Amendment Rules, 2024 (G.S.R. 164(E), 8 March 2024) added the price band and trading platform provisions^[2]. CPCB fixes the highest and lowest certificate prices at 100% and 30% of the environmental compensation for EPR shortfall, and trades on the portal must fall within that band^[2].

All figures in the table above come from CPCB's EC guidelines^[3]. The guidelines also give EC per unit of recovered metal, for example Rs 1,875 per kg of copper, with matching floor prices^[3].

The floor price is contested. According to news reports, Havells, Daikin, Voltas, Blue Star, Samsung, LG and Carrier have challenged the price band in the Delhi High Court, and in December 2025 the court gave Blue Star an interim stay on a CPCB price declaration. No final judgment had been reported^[9]. We found no e-waste rule amendment after 2024 on CPCB's rules page that changes the band. Until a court or MoEFCC changes it, plan on the band applying.

A shortfall triggers environmental compensation (EC) and the obligation does not go away.

• EC rate. Per kg of shortfall, at the category rate in the table above^[3].
• Carry forward and refund. Paying EC does not discharge EPR. The unmet quantity carries forward for up to three years; if you make it up, EC is refunded at 85% after one year, 60% after two and 30% after three, and nothing after that^[1].
• Other violations. For breaches other than a 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^[3].
• Unregistered sellers. EC can be levied on unregistered producers and on anyone who aids a violation^[1].
• Fake certificates. Forged certificates or false data can be prosecuted under section 15 of the Environment (Protection) Act^[1]. A 2024 second amendment reportedly made any contravention liable to a penalty under section 15^[10].

More on penalties: environmental compensation.

• Micro enterprises are outside the e-waste rules altogether^[1]. Most importers are not micro, so check your Udyam class before relying on it.
• Parts and spares are in scope: the rules cover components, consumables, parts and spares of Schedule I equipment^[1].
• Batteries and packaging inside your products are counted under the battery rules and plastic packaging rules, not here^[1].
• Refurbished stock. Refurbishing certificates defer EPR for the extended life; then 75% of the deferred quantity comes back into the recycling obligation^[1].
• Bulk buyers. A business using 1,000 or more units in a year is a bulk consumer and must hand its e-waste only to registered producers, refurbishers or recyclers^[1]; that can feed your take-back channel but does not reduce your certificate target.

1. Filing unit counts instead of weight. Targets are by weight^[1]. Use net product weight per model, certified by a chartered accountant as the SOP asks^[6].
2. Leaving new products off the registration. Adding EEE items costs Rs 10,000^[8]; selling unregistered items exposes you to EC as an unregistered producer^[1].
3. Buying everything in March. Certificates are scarcer at year-end and the rules want quarterly buying^[1].
4. Letting certificates expire. They last two years from the end of the year they were generated^[1].
5. Forgetting RoHS. Registration needs RoHS self-declarations^[8], and only RoHS-compliant products may be imported^[1].

If this is more than you want to run in-house, compare EPR consultants and read EPR for small importers.

CPCB's own figures to the National Green Tribunal show targets tightening and compliance slipping. Obligations allotted were 2,67,747 tonnes for FY 2023-24, of which 2,62,071 tonnes (97%) were met, and 3,46,505 tonnes for FY 2024-25, of which 2,98,393 tonnes (86%) were met^[4]. CPCB reported 381 registered recycling units in the same filing^[4].

For an importer this means two things. Certificate supply can be tight near year-end, and EC enforcement is now based on a full two years of portal data. Buy each quarter, as the rules require, instead of at the end of the year^[1].

Return deadlines can also be relaxed by government order by up to nine months under rule 9A^[2]. Filing dates are on EPR annual returns.

• 2026-27 is the last 70% year. The target rises to 80% from 2027-28^[1].
• FY 2025-26 returns were extended. Compliance trackers report a CPCB notice moving the quarterly and annual return deadline from 30 April 2026 to 30 September 2026^[13]. See EPR annual returns.
• Compliance fell to 86% of allotted obligations in FY 2024-25, from 97% the year before^[4], so expect closer scrutiny.
• The price band is in court. Reported challenges in the Delhi High Court, with an interim stay for one company in December 2025^[9].

Put return dates in the compliance calendar, estimate certificate spend with the compliance cost estimator, and see EPR registration costs. For marketplace sellers, Amazon seller compliance explains what platforms ask for. Not sure which code or schedule you are on? Ask for a free compliance check.