EPR for Plastic Packaging: Mandatory Rules & Procedure

Extended Producer Responsibility (EPR) is a key environmental strategy where producers, importers, and brand owners (collectively known as PIBOs) take full responsibility for the environmental impacts of their products, especially plastic packaging, throughout the product lifecycle. In India, EPR is legally mandated under the Plastic Waste Management (PWM) Rules, ensuring that companies that introduce plastic into the market are also accountable for its end-of-life disposal.

EPR for plastic packaging essentially requires companies to collect, recycle, and process the plastic waste they generate. This effort promotes a circular economy by encouraging responsible production and sustainable waste management practices.

Plastic Packaging Categories under EPR

Plastics under the rules of PWM is classified into two categories:

• Category I: Rigid plastic packaging materials.
• Category II: Flexible plastic packaging, including single-layer or multi-layer plastic (comprising different types of plastic), plastic sheets, covers made from plastic sheets, carry bags, and plastic sachets or pouches.
• Category III: Multi-layered plastic packaging, consisting of at least one layer of plastic combined with at least one non-plastic material.
• Category IV: Plastic sheets and similar materials used for packaging, along with carry bags made from compostable plastics.

Entities Required to Register Under EPR Guidelines

Under the latest amendments to the PWM Rules, the following entities are mandatorily required to register for EPR through the Central Pollution Control Board (CPCB) portal:

• Producers of plastic packaging materials
• Importers of plastic goods or packaging 
• Brand Owners who introduce products with plastic packaging
• Sellers or Importers of Raw Material 
• Manufacturers of Raw Material 
• Plastic Waste Processors (PWPs) engaged in:

          (a). Recycling

          (b). Waste-to-energy

          (c). Waste-to-oil

          (d). Industrial composting

• Micro, Small, and Medium Enterprises (MSME) are categorized as producers

Additionally, online marketplaces, supermarkets, and retail chains also fall under the EPR framework when they deal with plastic packaging.

Special Provision for Multi-State Operators

Entities operating in more than two states must register with the CPCB, while those functioning in only one or two states should register with their respective State Pollution Control Boards (SPCBs) or Pollution Control Committees (PCCs).

Exemptions Under EPR for Plastic Packaging

While the EPR framework applies widely, there are specific exemptions granted to certain categories:

• Brand Owners in Micro & Small Scale Categories are exempted from registering under the EPR regulations. 
• If such entities engage with large producers, the responsibility may shift to the latter under joint accountability clauses.

This clause supports smaller businesses while maintaining the regulatory intent of environmental protection.

Legal Basis and Amendments in EPR Policy

On February 16, 2022, the Ministry of Environment, Forest, and Climate Change (MoEFCC) notified a critical amendment to the PWM Rules. As per this amendment, Schedule II outlines detailed EPR guidelines, which must be strictly followed by:

• PIBOs
• Plastic Waste Processors (PWPs)

These amendments streamlined the compliance process and laid the groundwork for a centralized EPR portal, enabling businesses to track and fulfill their obligations digitally.

CPCB EPR Portal: Centralized Online Registration

The Government of India introduced a centralized online portal, developed by the CPCB, for managing EPR registrations.

• Official Portal: https://eprplastic.cpcb.gov.in 
• Access Requirements: PAN, GST, CIN, and authorized signatory details. 
• Jurisdiction: Central registration for multi-state operators, SPCB/PCC registration for one/two-state operators

This portal ensures that all processes—from registration to certification and compliance—are monitored and recorded in one place.

Step-by-Step Procedure for EPR Registration

Registering for EPR is a five-step digital process:

Step 1: Online Registration: The applicant must register their business by creating a profile on the CPCB portal, uploading basic company details.

Step 2: Submission of Documents: Upload all required documents (explained below), product details, and plastic packaging categories.

Step 3: Scrutiny by CPCB: The submitted application is scrutinized for accuracy and completeness. If any discrepancies are found, the applicant will be notified for correction.

Step 4: Approval or Rejection: CPCB either approves the application or rejects it with a stated reason. Rejected applicants can reapply after making necessary changes.

Step 5: Waste Management Implementation: Post-approval, the company must implement its EPR waste management plan, engage with PWPs, and submit annual reports through the portal.

Required Documents for EPR Registration

The following documents must be submitted in PDF format (max 5MB each):

1. Company PAN, GST & CIN
2. PAN and Aadhaar of the Authorized Signatory
3. Previous Registration Certificate (for renewals)
4. Details of Products and Quantities Produced
5. Representative Image of Plastic Packaging
6. District Industries Centre Certificate (if applicable)
7. Consent to Operate under Part B for further verification

It is advised to verify the clarity and size of each document before uploading to avoid rejection.

Application Fees for PIBOs and PWPs

For PIBOs (based on Plastic Waste Generation per Annum): 

For PWPs: 

Annual Processing Fee: 25% of the original application fee must be paid yearly for continued registration.

Role of Local Bodies and Compliance Authorities

Local urban and rural bodies are responsible for setting up Plastic Waste Management (PWM) systems. They must collaborate with PIBOs and Brand Owners to collect and manage plastic waste effectively. CPCB and SPCBs enforce compliance, maintain data, and ensure that waste is processed through authorized PWPs.

How to Implement the EPR Waste Management Plan

Once the CPCB grants approval, the real work begins—implementing the EPR Plan. This involves:

• Partnering with Plastic Waste Processors (PWPs): Only registered PWPs can process plastic waste under the EPR system. 
• Tracking Waste Quantities: Companies must monitor how much plastic they generate, recycle, or dispose of. 
• Annual Compliance Reports: Businesses are obligated to file reports detailing:

• Recordkeeping: Maintain proof of agreements with PWPs, and keep copies of all PWP certificates obtained.

It is important that the waste management system aligns with the targets assigned by CPCB based on your product volume and packaging type.

Understanding EPR Target Fulfillment via PWP Certificates

To prove compliance with assigned EPR targets, PIBOs and SIMPs must use PWP certificates. Here's how the system works:

• PWPs issue certificates for the volume of plastic waste processed (recycled, composted, incinerated, etc.). 
• PIBOs purchase or acquire these certificates from PWPs. 
• These certificates are then uploaded to the CPCB portal as evidence to offset their plastic waste obligations. 
• Certificates are subject to audit and must match the quantity declared in the EPR plan.

Note:

Certificates cannot be reused or duplicated and are traceable through the CPCB’s digital records to prevent fraud.

Penalties and Environmental Compensation for Non-Compliance

Entities that fail to register or do not meet their EPR obligations face strict penalties:

• Environmental Compensation (EC): Financial penalties imposed based on the quantity of non-compliant plastic. 
• Legal and Administrative Action: CPCB may cancel registrations, impose bans, or escalate to legal authorities. 
• Public Blacklisting: Non-compliant companies may be listed on government portals, damaging reputation and market trust.

Hence, timely registration and diligent reporting are not just legal obligations but critical for business continuity.

Challenges Faced by PIBOs in EPR Compliance

Despite a well-defined framework, many PIBOs face hurdles, especially Micro and Small Enterprises:

• Digital Barriers: Lack of technical knowledge to use the CPCB portal efficiently. 
• Cost Constraints: High registration and waste processing fees are a burden for smaller companies. 
• Lack of Awareness: Unclear understanding of documentation and procedural requirements. 
• PWP Availability: Limited access to certified waste processors in certain regions.

To tackle this, several states have initiated training programs, and CPCB has released user manuals and video tutorials on its website.

Benefits of EPR Compliance

EPR compliance isn’t just a regulatory requirement—it brings several long-term benefits:

• Environmental Protection: Reduces landfill waste and pollution by promoting recycling. 
• CSR Enhancement: Improves brand reputation and supports sustainable business practices. 
• Regulatory Ease: Prevents legal issues and fines by ensuring proactive adherence. 
• Market Advantage: Many large buyers prefer dealing with EPR-compliant suppliers, creating new business opportunities.

Companies that adopt a sustainable approach early are better positioned for future environmental mandates and consumer trust.

Tips for Smooth Registration on the CPCB Portal

To avoid application rejection or delays, follow these pro tips:

• Pre-check Documents: Ensure PDF files are below 5MB and all information is clear and consistent. 
• Use Updated Browser: The portal works best with modern browsers like Chrome or Edge. 
• Avoid Incomplete Submissions: Submit all mandatory fields and avoid “TBD” or “NA” placeholders. 
• Stay Informed: Regularly check CPCB notifications and updates on the portal.

Conclusion

With the 2025 regulatory environment getting stricter, compliance with EPR for Plastic Packaging is no longer optional—it’s mandatory. The government has established a transparent and structured process accessible to businesses of all sizes. Whether you are a multinational or a small brand, taking responsibility for your plastic waste not only meets legal requirements but also reflects your commitment to a sustainable future.

Now is the time to register, comply, and lead by example in reducing plastic waste in India. Let EPR not just be a regulation—but a revolution in responsible packaging.

FAQs on EPR for Plastic Packaging

1. Who is required to obtain EPR registration?

Ans. All Producers, Importers, Brand Owners (PIBOs) and Plastic Waste Processors (PWPs) are required to register under EPR guidelines, except micro and small brand owners.

2. What is the validity period of EPR registration?

Ans. Registration is typically valid for one year, after which it must be renewed annually with updated data and 25% of the initial application fee.

3. Can a company operate without EPR registration?

Ans. No. Operating without registration is illegal and subject to penalties, including fines, cancellation of license, and legal prosecution.

4. What happens if my application is rejected?

Ans. You will receive the reason for rejection. You can modify and resubmit the corrected application through the CPCB portal.

5. How are EPR targets calculated?

Ans. CPCB assigns targets based on:

• Type and volume of plastic packaging used 
• Previous year’s production and market data

6. Are there any support services available for applicants?

Ans. Yes. CPCB provides:

• User Manuals 
• Video Tutorials 
• Email and helpline support