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Plastic EPR Compliance

Guidelines for Annual Compliances for CPCB Plastic EPR Registration. How to submit Government fee, upload invoices & buy recycler credits for plastic EPR

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Plastic EPR Compliance

Plastic EPR Annual Compliance

  • In the modern times, EPR Registration is mandatory in India which means that no entity be it a  producer or importer, can carry out any kind of business without registering itself. The Registration is required for Indian importers & manufacturers of products for Plastic waste management.
  • EPR Authorization is issued by the Central Pollution Control Board (CPCB) under MoEF&CC, Government of India. Plastic EPR registration enables the disposal of plastic items and proper collection after use by ensuring responsible manufacturing methods, and it extends beyond that to encourage waste reduction and environmental impact in general. 
  • To apply online on the CPCB Plastic EPR portal, the applicant need to submit the company doucments, along with the Sale/import/ purchase data. The Plastic EPR Registration is valid for lifetime and only the annual compliances are to be submitted every year.
  • As a significant first, the guidelines and rules allow for the purchase and sale of surplus Plastic recycling credits thus setting up a market mechanism for plastic waste management. The Plastic EPR rules will give a rise to the formalization and further development of the plastic waste management industry. 
  • On 18th March 2016, the Ministry of Environment, Forest and climate change (MoEF&CC) published the Plastic Waste Management Rules (PWM), 2016. According to these Rules, plastic waste generators must take steps to reduce plastic waste generation, avoid littering plastic waste, ensure segregated waste storage at the source and send over segregated trash to local bodies or organisations permitted by the local bodies. Local governments, village panchayats, waste generators, retailers and street sellers are all required to manage plastic waste under the guidelines. 

According to the PWM Rules, the Producers, importers and brand owners (PIBOs) who import/manufacture/sell/package the products into the market have to get Plastic EPR Registrationfor the management of plastic packaging waste.

1.  Producers

  • The producers are the business entities engaged in the manufacturing of plastic items through injection moulding, blow moulding or any other business activity. 

2.  Importers

  • The importers in PIBO are the individuals/business entities engaged in importing the items which are packaged in the plastic packaging

3.  Brand Owners

  • Brand Owners are the entities which are not directly engaged in manufactuirng or import of plastic items but are using plastics to package the items manufactured by them. 

4.  Recyclers

The recyclers are the business entites which are recycing the waste plastics into plastic granules, fibres etc which can again be used to produce plastic items. 

Objectives of Plastic EPR Registration

The objectives of Plastic EPR Registrationare as following:

  • Optimize waste supply chain and management
  • Improve modalities for waste management
  • Ensure cost-cutting in waste management
  • Improve waste segregation and disposal
  • Improve coordination with affiliated units
  • Provide a credible image for the international market
  • Improved Market Reputation and goodwill
     

Benefits of Plastic EPR Annual Compliances

1.  Brand Reputation & Market Edge
Modern consumers and investors are increasingly "green-conscious." Transparency in waste management is a powerful marketing tool.
  • Consumer Loyalty: A verified EPR profile allows you to market your products as sustainable, appealing to the growing demographic of eco-conscious buyers.
  • ESG Scoring: For larger corporations, EPR compliance is a critical metric for Environmental, Social, and Governance (ESG) reporting, making the company more attractive to institutional investors.
2.  Cost Optimization in Long Term
  • Encourages reduction in plastic usage and packaging redesign 
  • Promotes use of recyclable and eco-friendly materials 
  • Reduces future compliance and environmental costs
3.  Social and governance benefits
  • Formalises the waste ecosystem, helping integrate informal workers into safer, more transparent value chains supported by verified EPR credits.
  • Shifts financial responsibility for plastic waste from municipalities and taxpayers to producers, which is viewed as more equitable policy and encourages better product design.
4.  Transparency & Accountability
  • Digital tracking through CPCB portal 
  • Better reporting and audit readiness 
  • Builds accountability in the supply chain

How to submit Plastic EPR Annual Compliances

The plastic EPR compliance process in India has three broad phases: registration on CPCB’s EPR portal, yearly target fulfilment (through actual recycling/credits), and annual return filing with documentation.
  • Fill the EPR application: enter historical plastic usage (by category and state), upload required documents, and submit for CPCB/SPCB scrutiny; approvals typically take around 15–30 days if documents are correct.
  • Determine Your Category: Identify if you are a Producer (P), Importer (I), or Brand Owner (BO). Incorrect categorization is the leading cause of application rejection.
  • Submit the EPR Action Plan: This is a formal declaration of how you intend to collect and process the equivalent amount of plastic waste you generate.
  • Pay Registration Fees: Fees are typically tiered based on the volume of plastic waste handled annually.
  • Quarterly/Half-Yearly Returns: You must log your sales and procurement of EPR credits on the portal to show you are on track to meet your targets.
  • Annual Return Filing: The final reconciliation for the financial year must be filed (usually by June 30th).
  • External Audits: Large-scale PIBOs (Producers, Importers, Brand Owners) are now subject to digital audits where the CPCB cross-verifies your GST data with your declared plastic volumes to prevent "under-reporting."
Audit & Compliance Verification
  • CPCB may conduct audits or inspections 
  • Ensure transparency and accuracy in reporting 
Target Fulfillment & Operations
Once registered, the CPCB assigns you an Annual Recycling Target.
  • Fulfill via Credits: Most companies do not recycle the waste themselves. Instead, they buy EPR Certificates from CPCB-authorized recyclers.
  • Recycled Content Mandates: As of the 2025–26 fiscal year, certain packaging (like rigid plastics) must contain a minimum percentage of recycled plastic (typically starting at 30%).

Document Required for Plastic EPR Annual Compliances

  • Sales invoices /  bills
  • Purchase/Import Invoices / bills
  • Plastic product Details

What you get?

  • CPCB Plastic EPR Annual Compliance report
  • Transfer of required credits for CAT 1, CAT 2, CAT 3, CAT 4

Common Questions

Frequently Asked Questions

According to the PWM Rules, the Producers, importers and brand owners (PIBOs) which manufacture or import their plastic products/packaging in the Indian consumer market have Extended Producers Responsibility (EPR) for the management of plastic waste generated by the plastic packaging of their products. 

To get a Plastic EPR Registration, the applicant is required to visit the CPCB Plastic EPR portal. After generation of login id & password, the applicant need to upload the company/ firm documents, along with the sale/purchase data / invoices of the last two financial years. After the scrutiny of doucments by the CPCB, plastic EPR Registrationis uploaded on the CPCB portal. 

The annual compliances for Plastic EPR Certificate are as following:

First step for annual compliance submission is to upload the documentary evidence / invoices for the plastic purchased / sold by any PIBO.

If any recycling credits are alloted to the PIBO, then the applicant is required to buy these plastic recycling credits from a CPCB registered Plastic Waste Processor (PWP)

After the recycling credits purchase, the applicant is required to submit Govt fee of Rs.2,500 or as per the quantity of recycling targets. 

 

 

The Producers, Importers and Brand Owners (PIBOs) are required to apply online on the CPCB Plastic EPR Portal. Whether the PIBOs operate in one or multiple States, the application for Plastic EPR Registration is to be made to the Central Pollution Control Board (CPCB). Also, the quantity of the plastics purchased or sold, along with the Sale/Purchase invoices, is to be uploaded to the CPCB Portal All the required documents are to be submitted along with the Government fee. In case, the applicant submits the SPCB CTO as producer/brand owner, then the CPCB sends this CTO to State Pollution Control Board for verification. After this, the Plastic EPR certifciate is issued. 

 

The documents required for Plastic EPR Registration as Importer are as follows:

  1. GST Registration
  2. Aadhar card + PAN card of Authorized Person
  3. Pic of Products
  4. IEC 
  5. MSME Registration
  6. State wise procurement data for last two years

The Government fee for submission of Plastic EPR Annual compliances is Rs.2500, which may go up depending on the quantity of Plastic EPR Recycling target. The annual compliances for plastic EPR are to to be submitted to the online portal of the Central Pollution Control Board.  

The Govt. fee for PIBOs for annual compliances submission is as following

S.no  PW generation slab (TPA) Govt. fee (Rs.)
1. <1000 2500
2. 1000 < 10,000 5000
3. >10000 12,500

Govt fee for annual compliance submission for PWPs is as following:

S.no Production Capacity Slab (TPA) Govt fee. (Rs.)
1. <200 1250
2. 200 < 2000 5000
3. >2000 12500

 

 

 

The documents required for Plastic EPR  Registration as a producer are as following:

  • GST
  • Pan card of Unit
  • CIN
  • Aadhar card and pan card of Authorized Person
  • SPCB CTO
  • Total Area (Sq ft.) - 
  • Picture with GEO tagging of - 
  •     Raw Material Area
  •     Production Area    
  •     Dispatch Area
  • Video of Processing Area
  • Name of Machinery & Details of Machinery- 
  • Production Hrs 
  • Picture of Machine
  • Sales and purchase bill of last two years

The documents required for Plastic EPR as brand owner are as follows:

  • CIN Registration(For Private limited company)
  • GST Registration
  • Aadhar card + PAN Card of Authorized Person
  • Picture of Products
  • SPCB CTO consent
  • State wise sales data and procurement data for last two years

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