Summary
Details
- India
Applicable producers, importers and brand owners must:
Register.
Calculate EPR obligations.
Meet recycling targets.
Meet recycled-content targets.
Meet applicable reuse targets.
File returns.
Use registered processors and valid certificates.
Address end-of-life disposal where recycling is not possible.
Deep dive
- What’s Required
- 1. Register on the centralized EPR portal
- 2. Classify plastic packaging
- 3. Meet EPR targets
- 4. Meet minimum recycling levels
- 5. Use recycled plastic content
- 6. Reuse Category I packaging where applicable
- 7. Use approved end-of-life routes
- 8. Use EPR certificates
- 9. File annual returns
- Important Deadlines
- Current Status
- Penalties for Non-Compliance
- Examples of Known Violations / Failure Modes
- Resources
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What’s Required
1. Register on the centralized EPR portal
Regulated entities include:
Producers.
Importers.
Brand owners.
Plastic waste processors.
Later amendments also expanded registration to certain plastic raw-material manufacturers and importers.
2. Classify plastic packaging
EPR obligations are divided into categories.
Broadly:
Category I: Rigid plastic packaging.
Category II: Flexible plastic packaging.
Category III: Multilayered plastic packaging.
Category IV: Compostable plastic packaging.
The applicable targets vary by category.
3. Meet EPR targets
The framework progressively increased the share of obligated plastic packaging subject to EPR.
The EPR target reached 100% of the relevant eligible quantity from 2023-24, subject to the detailed calculation rules.
4. Meet minimum recycling levels
For 2026-27, official requirements include:
Plastic packaging category | Minimum recycling level |
|---|---|
Category I | 70% |
Category II | 50% |
Category III | 50% |
Category IV | 70% |
From 2027-28 onward, the corresponding requirements rise to:
Category I: 80%
Category II: 60%
Category III: 60%
Category IV: 80%
5. Use recycled plastic content
The Guidelines progressively introduce mandatory recycled-content requirements.
For example, official guidance illustrates a 10% recycled-plastic requirement for Category II packaging in 2025-26. Exact percentages depend on category and compliance year.
6. Reuse Category I packaging where applicable
Rigid plastic packaging can also be subject to minimum reuse obligations depending on container size and the relevant compliance year.
Reuse can reduce the quantity of fresh plastic packaging counted toward the EPR obligation under applicable formulas.
7. Use approved end-of-life routes
Plastic that cannot be recycled may be managed through approved routes such as:
Co-processing.
Waste-to-energy.
Waste-to-oil.
Road construction.
These routes are intended for material that cannot be recycled and must follow applicable CPCB or other technical guidance.
8. Use EPR certificates
Plastic waste processors generate verified recycling or processing data within the EPR system.
EPR certificates can be used by producers, importers and brand owners to demonstrate fulfillment of applicable obligations.
CPCB has also developed rules for electronic trading and settlement platforms for plastic packaging EPR certificates.
9. File annual returns
Producers, importers and brand owners must file annual returns concerning plastic packaging collected and processed toward their EPR obligations.
Failure to file can trigger environmental compensation under CPCB enforcement guidance.
Important Deadlines
February 16, 2022: EPR Guidelines formally incorporated into the Plastic Waste Management Rules.
2022-23: EPR target increased to 70% under the phased framework.
2023-24: EPR target reached 100% of relevant eligible quantity.
2024-25: Minimum category-specific recycling requirements began at higher statutory levels.
2025-26: Recycling and recycled-content requirements increased further.
2026-27: Category I and IV minimum recycling increases to 70%; Category II and III to 50%.
2027-28 onward: Recycling requirements rise again to 80% for Categories I and IV and 60% for Categories II and III.
Current Status
Active and legally binding.
The EPR framework remains integrated into India’s Plastic Waste Management Rules and continues to operate through CPCB’s centralized system.
CPCB has developed registration, reporting, certificate, and enforcement mechanisms supporting implementation.
Penalties for Non-Compliance
CPCB’s environmental compensation methodology provides for penalties where EPR obligations are not fulfilled.
For shortfalls in obligations such as recycling, reuse, or mandated recycled content:
First instance: ₹5,000 per tonne.
Second instance: ₹10,000 per tonne.
Third instance: ₹20,000 per tonne.
Outstanding EPR obligations continue even when compensation is paid.
Where the shortfall is corrected within three years, part of the environmental compensation may be returned under the applicable mechanism.
Examples of Known Violations / Failure Modes
Operating without EPR registration.
Underreporting plastic packaging quantities.
Incorrect packaging-category classification.
Failing minimum recycling targets.
Failing recycled-content obligations.
Missing reuse requirements.
Using invalid EPR certificates.
Purchasing credits unsupported by actual recycling.
Using unregistered recyclers.
Filing annual returns late.
Claiming recycling through unapproved end-of-life routes.
Double-counting processed waste.
Failing to reconcile packaging placed on the market with EPR data.
Treating environmental compensation as a substitute for compliance.
Resources
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