EPR for plastic packaging in India: registration, targets and returns for importers, producers and brand owners

Yes, in most cases. Extended Producer Responsibility (EPR) for plastic packaging makes the businesses that put plastic packaging on the Indian market pay for collecting and processing it once it becomes waste. The rules sit in the Plastic Waste Management (PWM) Rules, 2016. The detailed EPR guidelines were added to those rules as Schedule II by G.S.R. 133(E) dated 16 February 2022, with immediate effect^[1].

The law calls the businesses that carry this duty producers, importers and brand owners, usually shortened to PIBOs. An importer is anyone who imports for commercial use any plastic packaging, any commodity with plastic packaging, carry bags, plastic sheets, or plastic raw material or intermediate material for making packaging^[2]. That definition is wide. A shipment of phone cases in polybags, earphones in blister packs or laptops wrapped in film all bring plastic packaging into India.

In practice, an importer has to do four things:

1. Register on CPCB's centralised EPR portal before doing business. Unregistered entities may not operate, and registered entities may not deal with unregistered ones^[2].
2. Work out the yearly target from the weight of plastic packaging it imported and sold^[1].
3. Meet the target with EPR certificates for plastic recycled or sent for end-of-life disposal, and report them^[2].
4. File the annual return by 30 June of the next financial year^[2].

Importers are by far the biggest group on the portal. As of 25 June 2026, 62,175 PIBOs were registered, and 52,935 of them were importers^[6].

If you also import electronics or batteries, plastic EPR is only one of three regimes. The e-waste rules expressly leave packaging plastics to the PWM Rules^[7], so a gadget can trigger e-waste EPR, battery EPR and plastic EPR at the same time.

Since the 2024 amendment, the EPR guidelines cover these entities^[2]:

• Producers of plastic packaging, other than micro and small enterprises.
• Importers of plastic packaging, of intermediate material such as films and preforms, and of the plastic packaging of imported products.
• Brand owners, including online marketplaces and retail chains, other than micro and small enterprises.
• Plastic waste processors (recyclers, co-processors and similar).
• Manufacturers and importers of plastic raw material.
• Manufacturers of compostable or biodegradable plastic items.

Note the asymmetry. The micro and small enterprise carve-out is written for producers and brand owners. Importers have no such exemption, so a small trading company that imports goods in plastic packaging is still covered^[2].

For micro and small producers, the 2024 amendment moved their EPR to the manufacturer or importer of the plastic raw material supplied to them. The one exception is the recycled-content target, which the small producer must still meet itself^[2]. CPCB followed this with a notice on 28 April 2025 calling for registration of raw material manufacturers and importers, micro and small producers, and sellers on the portal, and section 5 directions to raw-material manufacturers on 4 July 2025^[6].

Plastic EPR attaches to the packaging, not to the product. Any product that arrives in plastic packaging counts, because the importer definition covers "any commodity with plastic packaging"^[2]. For electronics importers this usually means the polybag, blister, tray, film and foam around the device. The device itself may need other approvals, such as BIS CRS and e-waste EPR.

Typical examples among the products we cover:

• Bluetooth earphones, smartwatches and power banks: blister or tray packaging plus inner polybags. Built-in batteries also bring battery EPR^[8].
• Mobile chargers and USB cables: polybags and twist ties.
• Laptops, tablets and mobile phones: protective films, foam and bags inside the carton.
• LED bulbs, CCTV cameras and Wi-Fi routers: rigid plastic inserts and film.

What matters for your target is the weight of each packaging category you place on the market, so record packaging weights per SKU from the first shipment.

More products in plastic packaging where the importer is an obligated 'Importer' under the guidelines^[9]: Bluetooth speakers^[9], keyboards and mice^[9], set-top boxes^[9], smart plugs^[9], extension boards^[9], UPS and inverters^[9], lithium-ion battery packs^[9], LED drivers^[9] and e-bike chargers^[9]. Not sure about your product? Try the approval checker or ask for a free compliance check.

Every target, certificate and fee calculation is split by packaging category. The 2022 guidelines created Categories I to IV, and the 2024 amendment (G.S.R. 201(E)) added Category V^[2]. Surplus certificates can be used only within the same category^[1], so getting the category right matters.

Every PIBO applies through the same centralised portal, but the registering authority depends on where you operate. If you operate in one or two states or Union Territories, you register with the State Pollution Control Board (SPCB) or Pollution Control Committee (PCC). If you operate in more than two, you register with CPCB^[1]. As of 25 June 2026, 35,611 of the 62,175 registered PIBOs were registered by CPCB^[6].

Two rules often surprise first-time applicants:

• One registration per sub-category. A business that is, say, both an importer and a brand owner registers separately for each role^[1].
• One registration per state. Units in different states register separately, giving one registration per sub-category per state^[1].

The same split decides who levies environmental compensation on you later: CPCB for PIBOs in more than two states, and the SPCB or PCC for PIBOs in one or two states and for plastic waste processors^[1]. The fee is shared 80:20 between CPCB and the SPCB or PCC, or the reverse, depending on who registers you^[3].

If your business is set up abroad, the portal still expects Indian identifiers (see documents below), so foreign brands usually register through their Indian importing entity. See foreign manufacturers.

The order below follows the EPR guidelines and CPCB's PIBO SOP of March 2022. For screens and common portal errors, see our CPCB EPR portal guide.

CPCB's EPR portals are now reached through a single sign-on at epr.cpcb.gov.in^[10]. Our EPR registration checklist lists everything to have ready before you start.

The guidelines list the identity documents: PAN, GST and CIN of the company, and the Aadhaar and PAN of the authorised person^[1]. Because CIN is a company identifier, a sole proprietor or partnership should check on the portal what it accepts in its place; we did not find an official statement on this.

Beyond KYC, the application turns on data rather than certificates. For an importer, the portal needs the figures behind the target formula^[1]:

• the average weight of plastic packaging, by category, imported and sold in the last two financial years;
• the average pre-consumer plastic packaging waste;
• the quantity supplied to brand owners in the previous financial year.

Keep bills of entry, packing lists and a weight sheet per SKU so you can back these numbers up. A PIBO found to have given false information or concealed facts has its registration revoked for one year and cannot re-register during that time^[1].

The official fees come from CPCB's SOP for PIBOs dated 15 March 2022. This is the latest fee schedule we found. We could not confirm whether CPCB has issued a newer SOP after the 2024 amendment, so check the fee shown on the portal before paying. The fee depends on how much plastic waste you generate each year, measured in tonnes per annum (TPA)^[3].

The government fee is usually the smallest part of the bill. The larger costs are:

• EPR certificates. You buy these from registered plastic waste processors to cover your target. Since 2024, CPCB must fix the highest and lowest certificate prices at 100% and 30% of the environmental compensation for non-fulfilment, and trades on the portal must fall within that band^[2]. Prices inside the band are set between buyers and processors; we did not find an official list of current traded prices.
• Extra registrations if you register in several states or several roles^[1].
• Consultant or PRO charges, which are not government fees and are not regulated.

Our EPR registration cost page puts plastic, e-waste and battery costs side by side.

The market is large and mostly legitimate, but fake recycling certificates have been caught and punished, so buy only from registered processors and keep the paper trail. CPCB told the National Green Tribunal that as on 25 June 2026, 4,153 plastic waste processors had applied on the EPR portal and 3,079 were registered, and that certificates for 237.95 lakh tonnes had been generated since inception, of which 178.48 lakh tonnes had been transferred to PIBOs^[11].

Only certificates from registered plastic waste processors count towards a PIBO's obligation; the guidelines do not use the term producer responsibility organisation^[12]. A PRO or consultant can arrange the purchase, but the EPR certificate must come from a registered processor.

What goes wrong. In the same July 2026 report, the Gujarat Pollution Control Board recorded that after CPCB found discrepancies at one processor, it levied environmental damage compensation of Rs 5.74 crore for fake recycling credit certificates, revoked the unit's consents and debarred its plastic EPR registration for a year^[11]. A PIBO that relied on such certificates may find its target unmet and face environmental compensation.

How to protect yourself. Check the processor's registration on the portal, buy within CPCB's price band^[2], insist that the transfer is made on the portal, and keep invoices that match the certificate quantity. Our EPR consultants page explains how to vet a provider, and EPR for small importers covers the low-volume case. Budget certificates alongside other approvals with the compliance cost estimator and the India compliance fees 2026 data.

An importer's eligible quantity is Q2 = (A + B) - C^[1], where:

• A is the average weight of plastic packaging, by category, imported and sold in the last two financial years;
• B is the average pre-consumer plastic packaging waste;
• C is the quantity supplied to brand owners in the previous financial year (they carry the EPR for it).

The EPR target for producers, importers and brand owners in Categories I to III was 25% of the eligible quantity in 2021-22, 70% in 2022-23, and 100% from 2023-24 onwards^[1]. So for FY 2026-27 the target is the full eligible quantity.

Inside that target, a minimum share must come from recycling rather than end-of-life disposal (such as co-processing). On top of it, there are separate obligations for recycled content and, for brand owners, reuse. The tables below set these out.

Separately from collection and recycling, PIBOs must use a minimum share of recycled plastic, measured as a percentage of the plastic they used or imported in the year^[1]. For an importer, recycled plastic already inside the imported packaging does not count towards this obligation; importers meet it by buying certificates from PIBOs that have a surplus^[1].

Brand owners that use Category I rigid packaging also have reuse targets: for packs of 0.9 to 4.9 litres or kg, 10% in 2025-26, 15% in 2026-27, 20% in 2027-28 and 25% from 2028-29; for packs of 4.9 litres or kg or more, 70%, 75%, 80% and 85% over the same years^[1].

Surplus certificates move only one way down the hierarchy. A surplus under reuse can count against reuse, recycling or end-of-life; a surplus under recycling against recycling or end-of-life; but end-of-life cannot count against reuse or recycling, and nothing crosses categories^[1].

Update for 2026. The March 2026 amendment split the larger-pack reuse band: 70/75/80/85% now applies to drinking-water packs of 4.9 litres or kg and more, and other packs of that size have targets of 10/10/15/15%^[13]. See the 2026 amendment section below.

PIBOs must file the annual return on plastic packaging waste collected and processed under EPR by 30 June of the next financial year, with the certificate details for plastic recycled or sent for end-of-life disposal^[2]. Plastic waste processors file by 30 April^[2]. The annual processing fee, 25% of your application fee, is paid at the same time^[3].

Deadlines have been moved before: the 2024 amendment allowed returns for FY 2022-23 until 31 March 2024^[2]. We could not confirm whether any extension order applies to the FY 2024-25 or FY 2025-26 plastic returns, so treat 30 June as the deadline unless you see an order on the portal.

Late filing is expensive. Under CPCB's revised environmental compensation guidelines, a PIBO that misses the deadline gets a notice 5 days after it, then EC of Rs 5,000 for the next 5 days and Rs 10,000 for the following 10 days; these double and quadruple for second and third defaults^[5]. CPCB is also chasing old years: on 11 March 2026 it issued revised show-cause notices to PIBOs for unmet obligations and unfiled returns for FY 2022-23^[6].

More detail on filing is on our EPR annual returns page.

Under CPCB's PIBO SOP of March 2022, a fresh registration is valid for one year and a renewed registration for three years. Renewal must be applied for four months before expiry, and you need all annual returns filed to renew^[3]. The renewal fee equals the registration fee^[3].

These validity rules come from the March 2022 SOP, the latest we found. We did not find a later SOP revision, and we could not confirm whether the 2024 amendment changed them. Check the expiry date shown on your registration certificate on the portal and plan the renewal from that date.

Work out your renewal filing date with the licence renewal date calculator and keep the 30 June return on your compliance calendar.

Rule 11(1)(a), as substituted in July 2022, requires plastic packaging to show the name and registration number of the producer or brand owner, and the thickness for carry bags and plastic packaging. New clause (d) applies this to importers of imported plastic packaging, whether imported alone or with products^[14].

There is a conflict in the text. The same substituted clause (a) carries a proviso exempting "plastic packaging used for imported goods", while clause (d) requires importers to comply. The proviso also exempts packages covered by rule 26 of the Legal Metrology (Packaged Commodities) Rules and cases where printing is not technically feasible, with CPCB approval^[14]. We have not found a CPCB clarification that resolves this. Until there is one, the cautious course for an importer is to carry the name and EPR registration number on the packaging (or use one of the 2025 options below), rather than rely on the proviso.

Since 2024 there are also content labels: recycled plastic packaging must say "recycled having [x%] of recycled plastic" and conform to IS 14534:2023; compostable plastic must say "compostable only under industrial composting" (IS/ISO 17088:2021); and biodegradable plastic must state the days and environment in which it biodegrades^[2].

Your packaging will usually also need Legal Metrology declarations; those are a separate law.

Check your pack artwork against both laws with our label checker.

No. It is an option, not a mandate. Many websites describe the January 2025 amendment as a new requirement to print a QR code. That is not what it says.

G.S.R. 73(E), dated 23 January 2025, says that from 1 July 2025 a PIBO may provide the rule 11(1) information in one of these ways instead of printing it in full^[4]:

• a barcode or QR code printed on the plastic packaging;
• the product information brochure; or
• a unique number issued under any law, printed on the packaging.

The duty that remains is the underlying rule 11(1) information (name and registration number, and thickness where it applies). The QR code, barcode, brochure and unique number are alternative ways to carry it. If you choose one of them, you must tell CPCB which method you use, and CPCB publishes a quarterly list of PIBOs that have done so^[4].

Battery rules have a similar but separate QR or barcode option for the battery EPR number, introduced by S.O. 958(E) in February 2025^[15]; see battery EPR.

The PWM Rules have been amended many times since 2016. The chain below is taken from the note in the January 2025 gazette^[4]. The latest amendment we have verified is G.S.R. 237(E) of 31 March 2026^[13], covered in the next section. We also have not read the full text of the two 2023 amendments, so the table describes them only by number and date.

The Plastic Waste Management (Amendment) Rules, 2026, notified as G.S.R. 237(E) on 31 March 2026 and in force on publication, kept the recycled-content percentages but added carve-outs, carry-forwards and new verification routes^[13]. They followed a draft published on 3 June 2025.

Recycled-content targets. The 2026 text keeps Category I at 30/40/50/60%, Category II at 10/10/20/20% and Category III at 5/5/10/10% from 2025-26 to 2028-29 onwards. The targets do not apply where a law, an FSSAI, CDSCO or CIB rule, or a mandatory Indian Standard bars recycled plastic, which must be claimed in the annual return, and the Category III target now applies only to the plastic layers^[13]. Importers still cannot count recycled plastic already in imported packaging; they buy certificates from entities that over-achieved, through a mechanism CPCB is to build on the portal^[13].

Food-contact packaging. An unmet 2025-26 recycled-content target for food-contact packaging can be carried forward for up to three years from 2026-27, clearing at least a third each year^[13]. Food importers should read this with our FSSAI import guide.

Reuse targets restated. For brand owners' Category I rigid packaging, reuse targets are now 10/15/20/25% for 0.9 to under 4.9 litres or kg, 70/75/80/85% for drinking-water packs of 4.9 litres or kg and more, and 10/10/15/15% for other packs of that size, with a three-year carry-forward for a 2025-26 shortfall^[13]. That replaces the single 70-85% band for all large packs in the earlier text.

What counts as recycling. End-of-life disposal now means energy recovery, including co-processing in cement or steel, waste-to-energy, waste-to-oil and road construction; turning plastic waste into feedstock chemicals or new plastic counts as recycling^[13].

Verification and reporting. A Registered Environment Auditor under the Environment Audit Rules, 2025 can now verify compliance alongside a designated agency^[13], and brand owners must report total sales and virgin and recycled plastic in rigid packaging in their annual return^[13].

The year-by-year numbers are worked through on our plastic EPR targets page, and every 2026 change across regulators is on new rules for 2026.

Plastic EPR is enforced mainly through environmental compensation (EC), a civil charge levied by CPCB or the SPCB/PCC^[1]. CPCB's revised EC guidelines (August 2024) set these rates for a shortfall against the EPR target^[5]:

• Category I: Rs 2,900 per tonne;
• Category II: Rs 5,000 per tonne;
• Categories III and IV: Rs 7,900 per tonne.

The rate is doubled for a second default and tripled for a third. The guidelines say EC is to be reviewed every six months and kept about 15-20% above prevailing EPR credit prices, and the same rates apply to unregistered PIBOs on plastic used since inception or notification^[5]. In other words, staying unregistered does not avoid the cost; it adds back years.

Paying EC does not end the obligation. Unmet obligations carry forward for three years, and EC is refunded at 75% if the shortfall is met within one year, 60% within two years and 40% within three; after that it is forfeited^[1].

Other consequences:

• Annual return EC: Rs 5,000 and then Rs 10,000 for a first default, as described above^[5].
• Revocation: one year for false information or concealment^[1].
• Statutory penalty: the 2025 amendment inserted rule 19, making anyone who fails to comply with or contravenes the PWM Rules liable to a penalty under section 15 of the Environment (Protection) Act^[4].

All three regimes are run by CPCB on separate portals, and one imported electronic product can trigger all three^[7]. The main differences for an importer: