EPR Is Live. If Your Business Uses Plastic Packaging, You Are Already Required to Comply.
India generates approximately 35 lakh metric tonnes of plastic waste annually.
Of that, approximately 30% is formally collected and recycled. The remaining 70% — roughly 24.5 lakh metric tonnes — ends up in landfills, rivers, coastal waterways, and the open environment. India is one of the world’s largest contributors to plastic pollution in ocean systems.
The Ministry of Environment, Forest and Climate Change (MoEFCC) introduced the Plastic Waste Management (Amendment) Rules, 2022, to change this. At the heart of those rules is a principle called Extended Producer Responsibility (EPR): the businesses that put plastic into the market are responsible for ensuring it is collected and processed.
If your business uses plastic packaging — to pack a product, to ship a product, to present a product to a retailer or consumer — the EPR rules apply to you. Registration on the CPCB portal was mandatory from the commencement of the 2022 rules. Collection targets are now enforceable.
The CPCB has already begun enforcement. State Pollution Control Boards are incorporating EPR compliance into consent renewal assessments. Large listed companies are beginning to require EPR certificates from their MSME suppliers as part of BRSR value chain compliance documentation.
If you haven’t registered, you are in violation. This guide tells you everything you need to know to fix that.
What EPR Is — The Legal Framework
Extended Producer Responsibility is a policy principle that shifts the responsibility for end-of-life management of products from governments (through municipal waste collection) back to the businesses that create those products. The producer — the company that manufactured the packaging or the product that comes in packaging — is responsible for ensuring that the material is recovered and processed after use.
India’s EPR framework for plastic waste is established in the Plastic Waste Management (PWM) Rules, 2016, as comprehensively amended in January 2022. The key provisions:
Covered materials (categories defined in the Rules):
- Category I: Rigid plastic packaging
- Category II: Flexible plastic packaging (films, pouches, bags, wrappers)
- Category III: Multi-layer plastic packaging (laminated films, sachets, tetra-paks)
- Category IV: Plastic sheets / carry bags not covered elsewhere
- Extended to cover EPR obligations for producers of plastic commodities (not just packaging) from 2024
Who is obligated (PIBOs):
- Producers: Manufacturers of plastic packaging materials
- Importers: Importers of products packaged in plastic
- Brand Owners: Companies whose brands appear on plastic-packaged products
The key point: if your company’s name appears on the packaging of a product sold in India, you are a brand owner under EPR. If you manufacture plastic packaging for others, you are a producer. If you import goods in plastic packaging, you are an importer. All three categories must register.
The EPR obligation: Registered PIBOs must collect a defined percentage of the plastic packaging weight they put into commerce in any given financial year, and ensure that collected plastic is processed (recycled, co-processed in cement kilns, or converted to energy in approved facilities).
Collection targets (percentage of plastic put on market that must be collected/processed):
| Category | FY2021-22 | FY2022-23 | FY2023-24 | FY2024-25 | FY2025-26 | FY2026-27 onwards |
|---|---|---|---|---|---|---|
| Category I (Rigid) | 35% | 50% | 60% | 70% | 80% | 100% |
| Category II (Flexible) | 35% | 45% | 55% | 65% | 75% | 100% |
| Category III (MLPs) | 35% | 50% | 60% | 70% | 80% | 100% |
By FY2026-27, PIBOs must ensure 100% collection and processing of the plastic packaging they put into commerce. This is an ambitious target that will require significant investment in collection and processing infrastructure across India.
How EPR Compliance Works: The Credit Mechanism
The EPR framework uses a market mechanism — EPR credits — to allow PIBOs to meet their collection targets without operating their own collection infrastructure.
The EPR credit system works as follows:
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Waste processors and recyclers — entities that formally collect and process plastic waste — register on the CPCB EPR portal and receive EPR certificates (credits) for each tonne of plastic they collect and verifiably process.
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PIBOs must acquire EPR credits matching their collection obligations. They can do this by:
- Establishing their own collection and processing systems (and certifying this to CPCB)
- Purchasing EPR credits from registered waste processors on the CPCB portal
- Engaging a Producer Responsibility Organisation (PRO) — an aggregator that pools EPR obligations across multiple PIBOs and manages compliance collectively
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At the end of each financial year, PIBOs submit their compliance report to CPCB showing the EPR credits acquired against the obligation for the year.
The market for EPR credits:
EPR credit prices vary by plastic category, material quality, and regional availability of collection infrastructure. Typical ranges in FY2025-26:
- Rigid plastics (PET, HDPE): ₹5,000–12,000 per tonne
- Flexible films (PE films): ₹8,000–18,000 per tonne
- Multilayer packaging (laminated films): ₹12,000–25,000 per tonne (higher due to processing complexity)
The higher prices for flexible and multilayer categories reflect the greater difficulty of collecting and processing these materials. They are also the categories that most consumer goods brands use most heavily — meaning the EPR obligation cost is concentrated in the packaging types that most need to change.
The PRO route:
Most small and medium PIBOs use a Producer Responsibility Organisation to manage their EPR compliance. A PRO:
- Aggregates EPR obligations from multiple brand owners
- Manages collection partnerships with waste collectors, informal waste workers, and recyclers
- Provides PIBOs with EPR certificates matching their obligation
- Handles all CPCB portal filings and annual reports
Engaging a PRO is typically the most cost-efficient approach for MSMEs. PRO fees are bundled with the cost of EPR credits. CPCB maintains a list of registered PROs — currently over 100 nationally.
The Enforcement Timeline
Phase 1 (2022–2023): Registration priority
The initial enforcement focus was on driving registration. CPCB issued notices to large PIBOs (major FMCG brands, packaging manufacturers, importers) for non-registration. The registration database grew from near-zero to 60,000+ registered entities.
Phase 2 (2024): Compliance notices
CPCB began issuing compliance notices to registered PIBOs that had not filed annual compliance reports or had filed reports showing significant gaps in collection targets. Over 500 notice letters went to large brand owners in 2024.
Phase 3 (2025): Environmental Compensation orders
The first Environmental Compensation (EC) orders were issued in 2025 under the Public Liability Insurance Act and the Environment Protection Act, requiring non-compliant PIBOs to pay financial penalties. The EC order amounts are calculated based on the gap between declared obligation and demonstrated compliance, multiplied by the prescribed per-tonne penalty rate.
Phase 4 (2026 onwards): Consent integration
State Pollution Control Boards have begun incorporating EPR registration and compliance status into the consent-to-operate renewal process for manufacturing units. A factory that manufactures plastic packaging, processes food in plastic packaging, or otherwise qualifies as a PIBO may face delays in consent renewal if it cannot produce current EPR registration and compliance documentation.
Who Specifically Must Register
Any company that manufactures plastic packaging — whether for its own products or for sale to others. Plastic film extruders, rigid container manufacturers, flexible packaging converters, and injection moulding units producing caps, closures, and containers — all are producers under EPR.
Any company that imports products in plastic packaging — whether the packaging is part of the product (a blister-packed imported electronic component) or the shipping packaging. Importers must register even if they are not the brand owner.
Any brand owner whose product is sold in plastic packaging — whether or not they manufacture the packaging themselves. A company that contracts a packaging manufacturer to produce pouches for its food product is a brand owner under EPR. The key test: whose brand name appears on the package?
Size is not an exemption. The 2022 rules do not provide turnover-based exemptions for MSMEs in most categories. All PIBOs above a micro-scale are obligated. CPCB has acknowledged the compliance challenge for very small producers and is developing simplified compliance pathways, but registration is mandatory.
The Revenue Opportunity: EPR Credits as a Business Model
The EPR mandate creates obligations for those who put plastic on the market. It simultaneously creates a revenue opportunity for those who collect and process it.
Who can generate EPR credits:
- Formal waste recyclers and co-processors (cement kilns, pyrolysis plants) registered as Recyclers/Pre-processors on the CPCB EPR portal
- Urban local bodies and waste management entities that can document collection and transfer to registered processors
- Producer Responsibility Organisations that aggregate collection infrastructure
- Informal waste collector enterprises that formalise and register their operations
The credit economics:
At current credit prices (₹5,000–25,000/tonne depending on category), a recycler processing 100 tonnes of flexible packaging per month can generate ₹50–100 lakh per month in EPR credit revenue. For informal waste collectors who formalise into registered PRO supply chains, EPR credit revenue supplements their existing scrap sale income.
The market size:
CPCB’s analysis of registered PIBO obligations suggests that by FY2026-27, the EPR credit demand will exceed 35 lakh tonnes annually. At average credit prices of ₹10,000/tonne, that is a ₹35,000 crore annual market. This is new economic value created from material that was previously dumped.
The business model gap:
India’s formal plastic waste processing capacity is currently far below this demand. The gap between obligated demand for EPR credits and available supply is one of the most significant infrastructure investment opportunities in the Indian circular economy.
Entrepreneurs who establish formal plastic waste collection, sorting, and processing operations — with CPCB registration and the ability to generate certified EPR credits — are building businesses with guaranteed institutional demand from PIBOs seeking compliance.
Step-by-Step: How to Register and Comply
Step 1: Determine Your PIBO Classification
Review your business against the three categories (Producer, Importer, Brand Owner). A company can be in more than one category — a manufacturer who also sells its own branded product is both a Producer and a Brand Owner.
Calculate your approximate annual plastic packaging volume — the total weight of plastic packaging your business puts into commerce in a financial year. This will determine the scale of your EPR obligation.
Step 2: Register on the CPCB EPR Portal
Visit eprnew.cpcb.gov.in. The registration process requires:
- Company name, registered address, GST number
- MSME Udyam registration number (if applicable)
- PAN of company/proprietor
- Details of plastic packaging used, by category (weight per year)
- Bank account details for regulatory correspondence
Registration is online and typically completes within 7–10 working days.
Step 3: Calculate Your Annual Obligation
Based on your declared plastic packaging quantity and the applicable collection target percentages for the current financial year, CPCB calculates your EPR obligation (in tonnes, by plastic category).
Step 4: Engage a PRO or Develop a Collection Plan
For most MSMEs, engaging a CPCB-registered PRO is the most practical compliance route. The PRO manages collection, processing, and certification on your behalf, providing you with EPR certificates to submit in your annual compliance report.
Contact 2–3 registered PROs in your region for quotes. PRO fees typically range from ₹3,000–8,000 per tonne of EPR obligation, depending on the plastic category and PRO’s operational model. Compare total cost (EPR credit cost + PRO management fee) against your obligation tonnage.
Step 5: File Annual Compliance Report
By the prescribed date (currently 30 June for the preceding financial year), submit your annual EPR compliance report to CPCB through the portal, attaching EPR certificates equivalent to your collection obligation.
The 4-Level Action Plan
Personal (this week): Determine whether your business meets the PIBO definition. If you manufacture plastic packaging, sell branded products in plastic packaging, or import goods in plastic packaging — you almost certainly do. If the answer is yes, add EPR registration to this week’s action list.
Professional (this month): Register on eprnew.cpcb.gov.in. This takes 2–3 hours of internal effort. Once registered, calculate your FY2025-26 EPR obligation. Contact a registered PRO to understand your compliance cost. Budget for it in your operating expenses.
For BRSR-linked clients: once registered, your EPR certificate number becomes part of your sustainability credentials package. Share it proactively with clients who request ESG information.
Company-level (this quarter): If your business generates plastic waste in the manufacturing process (as a producer of packaging), explore whether registering as an EPR credit generator (recycler/pre-processor) could create a revenue stream from your own waste.
Review your packaging design. Where plastic packaging can be reduced, simplified, or replaced with a more recyclable material, these changes reduce your EPR obligation while simultaneously improving your BRSR environmental metrics. Packaging redesign is a circular economy investment with both cost and regulatory returns.
Policy-level: Push CPCB and MoEFCC to streamline the EPR portal registration process (currently clunky) and establish EPR credit price floor pricing to prevent race-to-the-bottom credit markets that undermine the economics of formal recycling. Advocate for mandatory EPR compliance verification as part of GST return filings for businesses above defined plastic use thresholds — this would dramatically increase registration and compliance rates without additional enforcement infrastructure.
The Bottom Line
EPR for plastic packaging is not a future obligation. It is a current legal requirement.
If you use plastic packaging and have not registered on the CPCB EPR portal, you are in violation today. The enforcement that began with large brand owners is moving systematically toward smaller businesses.
The compliance cost — at current PRO rates and EPR credit prices — is manageable. For most MSMEs, it is ₹1–5 lakh per year, depending on plastic volumes used. This is the cost of responsible business in a world that can no longer absorb unlimited plastic pollution.
And for those building collection and processing infrastructure, the EPR credit market is a multi-thousand-crore revenue opportunity that is structurally guaranteed by regulation.
The circular economy of plastic in India is being built right now. Compliance is the floor. Opportunity is the ceiling.
Resources
- CPCB EPR Portal: eprnew.cpcb.gov.in
- MoEFCC Plastic Waste Management Rules (2022): moef.gov.in
- CPCB Registered PRO List: eprnew.cpcb.gov.in (PRO directory)
- CPCB Registered Recycler List: eprnew.cpcb.gov.in (Recycler directory)
- Environment Protection Act penalties: egazette.nic.in
Amit Saha is the founder of Pro India. If your company needs help with EPR registration, finding a PRO in your region, or understanding compliance obligations, write to info@proindia.net.
