Plastic packaging EPR targets: collection, recycling, recycled content and reuse, with the 2026 amendment

Plastic packaging EPR has four separate obligations, each set category by category:

1. EPR target (collection). Take back a percentage of your eligible quantity of packaging: 25% in 2021-22, 70% in 2022-23 and 100% from 2023-24^[1].
2. Minimum recycling. A rising share of that target must be recycled rather than sent for end-of-life disposal^[1].
3. Recycled content. Your own packaging must contain a minimum share of recycled plastic^[2].
4. Reuse. Brand owners using rigid packaging must reuse a share of it^[2].

The obligations apply to producers, importers and brand owners (PIBOs). Importers of plastic packaging, of intermediate material and of the packaging on imported products are covered, while micro and small producers and brand owners are carved out^[4]. An electronics importer is an importer for this purpose because its products arrive in plastic packaging^[4]. Registration is explained on EPR plastic and PIBO.

Every target is set per category^[4]:

• Category I: rigid plastic packaging (trays, clamshells, bottles, rigid inserts).
• Category II: flexible single or multilayer packaging of different plastics, plastic sheets and covers, carry bags, sachets and pouches.
• Category III: multilayered packaging with at least one plastic and one non-plastic layer.
• Category IV: compostable plastic sheets, carry bags and commodities.
• Category V: biodegradable plastic, added in 2024.

A typical boxed gadget can carry three categories: a rigid tray (I), a poly bag and film (II) and perhaps a foil-laminate pouch (III). Weigh each separately.

Importers carry EPR for the plastic packaging of the products they import, not just loose packaging^[4]. The categories come from the rules^[4]; the mapping below is our reading of typical packs. Weigh your own.

The EPR target is a percentage of an eligible quantity, worked out per category and per role^[5].

Collection alone is not enough. The share that must be recycled, as opposed to end-of-life disposal, rises each year^[1].

The 2026 amendment redefined end-of-life disposal as energy recovery: co-processing in cement or steel, waste-to-energy, waste-to-oil and use in road construction. Turning plastic waste into feedstock chemicals or new plastic counts as recycling^[2]. Only certificates from registered plastic waste processors count, except self-declarations for road construction^[5].

Surplus certificates can be used only within the same category; a reuse surplus can count against reuse, recycling or end-of-life, a recycling surplus against recycling or end-of-life, but an end-of-life surplus cannot count against reuse or recycling^[1]. Certificates trade within a CPCB-fixed band of 30% to 100% of the EC^[4].

The March 2026 amendment restated the recycled-content tables for producers, importers and brand owners^[2]. The percentages are the same as in the 2022 guidelines^[1].

The Plastic Waste Management (Amendment) Rules, 2026 were notified as G.S.R. 237(E) on 31 March 2026 and took effect on publication, after a draft of 3 June 2025^[2]. For targets, the changes are:

• Exemptions. Recycled-content targets do not apply where a law, FSSAI, CDSCO or CIB rule, or a mandatory Indian Standard bars recycled plastic. You claim this in your annual return. CPCB is to publish audit guidelines, and for Category III the target applies only to the plastic layers^[2].
• Food-contact carry-forward. An unmet 2025-26 recycled-content target for food-contact packaging can be carried for up to three years from 2026-27, clearing at least a third each year^[2].
• Importers buy certificates. Recycled plastic inside imported material does not count. Importers meet recycled content by buying certificates from PIBOs that exceeded their own obligation, through a mechanism CPCB is to build^[2].
• Reuse table rewritten. Separate lines for drinking-water packs and other large rigid packs, plus a carry-forward of 2025-26 reuse shortfalls^[2].
• End-of-life redefined as energy recovery and road use^[2].
• Auditors. Registered Environment Auditors can now verify compliance^[2].

Reuse applies to brand owners using Category I rigid packaging^[2]. It replaced the earlier 2022 table^[1].

Illustrative figures only.

Facts assumed. An importer of Bluetooth speakers imported and sold products whose packaging included 3,000 kg of Category I rigid trays in FY 2024-25 and 3,400 kg in FY 2025-26, and 1,000 kg and 1,200 kg of Category II poly bags. No pre-consumer waste, nothing supplied to brand owners.

Eligible quantity (Q2). Category I: average of 3,000 and 3,400 = 3,200 kg. Category II: 1,100 kg^[1].

2026-27 EPR target. 100% of Q2: 3,200 kg (Category I) and 1,100 kg (Category II)^[1].

Minimum recycling. 70% of the Category I target (2,240 kg) and 50% of the Category II target (550 kg) must come from recycling certificates; the rest may be end-of-life^[1].

Recycled content. 40% of Category I and 10% of Category II imported packaging in 2026-27, met through certificates bought from PIBOs with a surplus^[2].

Shortfall exposure. If the importer bought nothing, EC at Rs 2,900 per tonne (Category I) and Rs 5,000 per tonne (Category II) would be about Rs 9,280 plus Rs 5,500 for a first default^[3]. Plastic EC per tonne is small next to e-waste or battery EC; the bigger risk is registration and customs checks.

Continuing the Bluetooth speaker importer above. Illustrative, our arithmetic.

Recycled content for 2026-27. The target is a share of the plastic used or imported in the year^[1]. Say it imports 3,600 kg of Category I trays and 1,300 kg of Category II bags in 2026-27. At 40% and 10%^[2], it needs 1,440 kg and 130 kg of recycled content.

How an importer meets it. Recycled plastic already in the imported packaging does not count; the importer buys certificates for an equal quantity from producers, importers or brand owners that exceeded their own recycled-content targets^[2].

EC exposure on the collection target. If it files certificates for only 2,700 kg of its 3,200 kg Category I target, the 500 kg (0.5 tonne) shortfall at Rs 2,900 per tonne is Rs 1,450 of EC; a 300 kg Category II shortfall at Rs 5,000 per tonne is Rs 1,500^[3]. A second default doubles and a third triples these^[3].

Why small EC is not the point. EC does not end the obligation: it carries forward for three years and is refunded only in part if met later^[1]. Missing the annual return is costlier in practice: Rs 5,000, then Rs 10,000, for a first default^[3], and CPCB has issued show-cause notices for non-fulfilment and non-filing^[6].

Most problems come from weak data, not from the formulas. Plastic EPR is heavily used by importers: of 62,175 PIBOs registered by 25 June 2026, 52,935 were importers^[6]. CPCB has also asked Customs to check proof of plastic EPR registration when clearing importers' consignments^[6].

PIBOs file annual returns on plastic packaging collected and processed under EPR by 30 June of the next financial year, with certificate details^[4]. Brand owners must also report total sales, virgin plastic and recycled content in rigid packaging in the annual return, as amended in 2026^[2]. Keep the supporting law or standard on file if you claim a recycled-content exemption, because you have to submit it with the return^[2]. Return dates for all three EPR regimes are on EPR annual returns.

Your targets live inside a PIBO registration, which until mid-2026 sat on the Centralized EPR Portal for Plastic Packaging at eprplastic.cpcb.gov.in^[7]. CPCB is reported to have shut that portal on 28 June 2026 and moved registrations and filing to the Common EPR Portal at epr.cpcb.gov.in^[8], which is also CPCB's single sign-on for all EPR portals^[9]. Importers selling in more than two states register with CPCB; one or two states, with the state board^[1]. Units in different states and different roles register separately^[1].

Plastic packaging must carry the name and registration number of the producer or brand owner, and the rule extends to importers of imported packaging^[11]. Since 1 July 2025 you can put this in a QR code or barcode on the pack, in the product brochure, or by printing a unique number issued under any law^[12]. Recycled packaging must be labelled with its recycled share and meet IS 14534:2023^[4].

These sit alongside the Legal Metrology declarations covered on LMPC label rules. Check a draft carton with the label checker and the product label checklist.

• EC rates. Rs 2,900 per tonne (Category I), Rs 5,000 (Category II) and Rs 7,900 (Categories III and IV), doubled for a second default and tripled for a third^[3].
• Who levies. CPCB for PIBOs in more than two states; the state board for the rest^[1].
• Carry forward and refund. Unmet obligations carry forward three years; EC is refunded at 75%, 60% or 40% if met within one, two or three years^[1]. EC goes into an escrow account used for managing uncollected waste^[5].
• Late return. EC of Rs 5,000 and then Rs 10,000 for a first default^[3].
• Penalty. Since 2025, any contravention is liable to a penalty under section 15 of the Environment (Protection) Act^[12].

CPCB issued revised show-cause notices in March 2026 for FY 2022-23 non-fulfilment and missed returns^[6], so old shortfalls are being pursued.

• Micro and small producers. Since 2024 their EPR is met by the raw-material manufacturer or importer that supplies them, though they still meet recycled content^[4]. This relief is for producers of packaging, not importers of finished goods.
• Packaging supplied to brand owners. It is deducted from the producer's eligible quantity (the C term) and picked up by the brand owner instead^[5].
• Raw-material importers. CPCB's April 2025 notice called raw-material manufacturers and importers to register too^[6].
• Food-contact packaging. A 2025-26 recycled-content shortfall can be carried forward up to three years from 2026-27, clearing at least one third each year^[2].
• Surpluses. Usable only in the same category, and an end-of-life surplus cannot count against recycling^[1].

1. Counting only loose packaging. The packaging of imported products counts^[4]. A container of gadgets brings trays, bags and film with it.
2. Lumping categories together. Targets, recycling shares and EC rates are per category^[3]. Weigh rigid, flexible and multilayer separately per SKU.
3. Buying end-of-life certificates for the recycling share. End-of-life no longer includes conversion to feedstock or new plastic, which now counts as recycling^[2]; but only recycling certificates satisfy the minimum recycling share^[1].
4. Registering in one state while selling nationally. Selling in more than two states means CPCB registration^[1].
5. Letting the registration lapse. Renewal needs every annual return filed^[10], and Customs may ask for proof of registration^[6].

For help, compare EPR consultants or read EPR for small importers.

The normal annual return date is 30 June^[4], but FY 2025-26 was extended.

The earlier amendment chain to 2025 is recorded in the gazette notes^[12].

Most electronics importers have three EPR registrations: plastic packaging, e-waste for the device and batteries for any cells inside. Each has its own portal, targets and certificates; EPR registration costs compares the fees and the CPCB EPR portal guide shows the screens. The EPR registration checklist lists documents for all three.

Brands that sell direct should read compliance for D2C brands; importers buying from China can start with the China import guide. Add the return dates to the compliance calendar, price certificates with the compliance cost estimator, or ask for a free compliance check.