EPR Compliance Guide

Extended Producer Responsibility (EPR) is a statutory obligation that holds the party which places a covered product on the Indian market responsible for collecting and recycling the waste that product becomes. It shifts the cost and the accountability of end-of-life management from the public system onto the producer, so a business that benefits from selling a product also carries its waste.

Each regime defines its own obligated entities. The party that must register is defined differently in each set of rules, so the exact definition depends on the stream. Under the plastic packaging rules the obligation falls on Producers, Importers and Brand Owners, together abbreviated PIBOs: a producer manufactures the plastic packaging, an importer brings packaging or plastic raw material such as resin and pellets into India, and a brand owner sells goods in plastic packaging under its own brand. The e-waste, battery, tyre, used-oil and vehicle regimes each carry their own definitions of who registers, set out in the next section. The common thread is that whoever first places a covered stream on the market carries the obligation, but the words that define that party differ by regime, so reading the definition for the specific stream is the first task.

The obligation applies regardless of size. There is no turnover threshold and no minimum tonnage below which a covered producer, importer or brand owner is exempt. A business that places any covered stream on the Indian market is bound, and the practical question is which of the six regimes applies and in what role.

The commercial side of EPR, where a consultant registers a business, computes its targets, sources the certificates and files the returns, sits on the EPR solutions page. This guide holds the how-it-works detail.

The six portals share one mechanic, registration before placing on the market, EPR certificates sourced against the recycling achieved, and returns filed on the portal, but each is governed by its own rule and measures the obligation differently.

The three core regimes, plastic packaging, e-waste and batteries, each sit under the Environment (Protection) Act, 1986. Waste tyre and used-oil EPR sit under the Hazardous and Other Wastes Rules, and end-of-life vehicle EPR under its own 2025 rules. A business that places more than one covered stream on the market completes one registration for each applicable portal.

Who is the obligated entity in each regime

The registering party is defined differently in each set of rules, and the same business can be a producer under one regime and an importer under another, so the definition is read stream by stream rather than assumed from one label.

An EPR target is computed from three inputs: the quantity of the covered material placed on the market, the category that material falls into, and the financial year, since the required percentage steps up over time. The obligation is discharged by sourcing EPR certificates generated by registered recyclers against the recycling achieved.

Plastic packaging runs two distinct tracks at once. A recycling target applies on the output side, measured as a percentage of the EPR obligation, and, under the 2026 amendment, a minimum recycled-content mandate applies on the input side. E-waste runs a single recycling target measured against waste generation, and batteries pair a collection target with a minimum material recovery by battery type. The exact year-wise percentages for each stream sit in the tables on the EPR solutions page and in the plastic EPR explainer.

The plastic packaging categories

Plastic packaging is classified into five categories, and the target runs by category. Knowing the category is the first step in computing a plastic EPR obligation.

Categories IV and V are distinct: compostable plastic breaks down under industrial composting conditions, while biodegradable plastic is defined separately under the rules. Getting the category right for each product is what makes the computed target the correct one.

Cosmetics, food and other consumer brands. A business that sells goods in plastic packaging is a brand owner under the plastic packaging rules and registers on the plastic EPR portal. There is no separate cosmetics regime; the packaging is what carries the obligation, so a cosmetics or FMCG brand meets plastic packaging EPR like any other brand owner.

Small businesses and MSMEs. The three core regimes apply to every covered producer, importer and brand owner regardless of size. There is no turnover or tonnage threshold that exempts a small business, so an MSME that places covered packaging, equipment or batteries on the market registers in the same way a large one does. The exemptions question at the Experts Corner sets out the limited cases.

E-waste and solar. Any manufacturer, producer, refurbisher or recycler of the 106 electrical and electronic equipment items in Schedule I of the E-Waste Rules 2022 registers on the e-waste portal. Solar photo-voltaic modules, panels and cells are inside Schedule I but carry a storage obligation until the financial year 2034-35 in place of a recycling target.

Batteries. A business that manufactures, sells under its own brand, or imports batteries or equipment containing batteries is a producer under the Battery Waste Management Rules 2022 and registers in Form 1(A). This covers every chemistry and every use, from portable to automotive, industrial and electric-vehicle batteries.

Non-ferrous metals and other streams. EPR-style obligations continue to widen. The dedicated non-ferrous metals explainer covers that stream in full, and draft rules for packaging made from paper, glass and metal remain draft rather than in force.

An EPR certificate is the instrument that discharges the target. A registered recycler, refurbisher or, for vehicles, a Registered Vehicle Scrapping Facility processes the collected waste and generates certificates on the portal against the quantity achieved. The obligated producer, importer or brand owner then sources those certificates on the same portal and offsets them against its year-wise target. The certificates exist only on the CPCB portals, so an obligation is discharged through registered channels and the recycler relationships matter as much as the registration itself.

Validity. Battery EPR registration in Form 1(A) is valid for five years. Plastic packaging and e-waste registrations run on their respective CPCB portals and are maintained and renewed to the portal requirements, so the current validity is confirmed against the portal rather than assumed from a fixed period.

Returns. Quarterly and annual returns are filed on the CPCB portal and the records retained for audit. The rules require the returns and set environmental compensation for shortfalls, and the CPCB has revised the filing timelines by notice, so the working practice is to file to the current portal schedule rather than a fixed calendar date. The specific rupee figures and enforcement actions for a given year are set out in the plastic and e-waste explainers.