EPR for plastic packaging, explained
Under the Plastic Waste Management Rules, 2016, producers, importers and brand owners (PIBOs) of plastic packaging must collect and process as much plastic packaging waste as they place on the market. This page sums up the Guidelines on Extended Producer Responsibility (Schedule II) as amended up to 31 March 2026.
Who is obligated
- Producers of plastic packaging, other than micro and small enterprises; micro and small producers register, and the plastic raw material makers or importers who supply them take on their target (paragraphs 4 and 7.8).
- Importers of plastic packaging, of intermediate material such as films and preforms, and of products in plastic packaging (paragraph 4(b)).
- Brand owners, including online marketplaces and retail chains, other than micro and small enterprises (paragraph 4(c)).
- Plastic waste processors: recyclers and end of life disposal units. They register too, and issue the certificates.
Steps
- Register on CPCB's Common EPR Portal (epr.cpcb.gov.in): with the State Pollution Control Board if you operate in one or two states, with CPCB if in more (paragraph 6.1).
- Work out your EPR target by category from your last two years' figures.
- Get EPR certificates from registered plastic waste processors for the waste collected and recycled or sent to end of life disposal, at least the minimum recycling share.
- Use recycled plastic in your packaging and, as a brand owner, reuse rigid packaging, as the tables require.
- File the annual return on the portal with the certificates, recycled content and reuse figures.
Questions
How is the EPR target calculated?
For each category, take the average plastic packaging you sold (or imported, or as a brand owner bought new) in the last two financial years, add the average pre-consumer plastic packaging waste of those years, and as a producer or importer subtract what you supplied to brand owners in the previous year. Since 2023-24 the target is 100 % of that quantity (paragraph 7).
When is the annual return due?
By 30 June after the financial year (paragraph 10.6), and the Central Government may allow up to nine months more (paragraph 12.9). For 2025-26 the date is 31 December 2026 for producers, importers and brand owners and 31 October 2026 for plastic waste processors (MoEFCC Office Memorandum of 28 August 2026).
What is an EPR certificate?
A record a registered plastic waste processor generates on the portal for plastic packaging waste it recycled or sent to end of life disposal, by category. Producers, importers and brand owners use certificates to show their target was met; a surplus can be carried forward, set off against an earlier shortfall or sold within the same category (paragraph 8).
What do EPR certificates cost?
The price is agreed between registered entities on the portal, between a lowest and a highest price that CPCB fixes at 30 % and 100 % of the environmental compensation for not meeting the obligation (paragraphs 8.8 and 8.9).
What happens if the target is not met?
Environmental compensation is levied under CPCB's guidelines, and the unmet part is carried forward to the next year. If the shortfall is made good within three years, part of the compensation is returned: 75 % within one year, 60 % within two and 40 % within three (paragraph 9.5).
Are exporters and small businesses exempt?
CPCB's FAQ says export-oriented units are exempt from EPR obligations, and micro and small brand owners have no EPR obligation. Micro and small producers must still register; their target is met by their raw material suppliers.
Does multilayered packaging count at full weight?
For the EPR target, yes: a MoEFCC Office Memorandum of 3 February 2023, quoted in CPCB's FAQ, says the complete weight of multilayered packaging counts. The recycled content obligation of Category III is on the plastic layers only (G.S.R. 237(E)).
Sources: Plastic Waste Management Rules, 2016, Schedule II, as amended by G.S.R. 133(E) of 16 February 2022, G.S.R. 201(E) of 14 March 2024 and G.S.R. 237(E) of 31 March 2026; CPCB's FAQ and portal notices, read on 30 October 2026. This is not legal advice.