PLASTIC EPR GUIDE
Plastic Packaging EPR in India
Plastic packaging EPR is the Indian rule that makes the business which places plastic packaging on the market responsible for collecting back and recycling the waste that packaging becomes. It runs under Schedule II of the Plastic Waste Management Rules, 2016, is administered by the Central Pollution Control Board on a central online portal, and binds producers, importers and brand owners. This guide sets out the five Schedule II categories, who needs to register, how registration works on the CPCB Common EPR single sign-on, the compliance calendar and key dates, the recycling and recycled-content targets, the exemptions, and how environmental compensation applies.
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Plastic packaging EPR at a glance
Plastic packaging EPR is administered by the Central Pollution Control Board under Schedule II of the Plastic Waste Management Rules, 2016, as amended to 2026, and measured through registration and tradable EPR certificates.
What plastic packaging EPR is
Extended Producer Responsibility for plastic packaging holds the business that places plastic packaging on the Indian market responsible for the waste it becomes, on the polluter-pays principle.
Plastic packaging EPR is a statutory obligation under Schedule II of the Plastic Waste Management Rules, 2016. In it, EPR stands for Extended Producer Responsibility, and it makes the party that places plastic packaging on the Indian market responsible for collecting back and recycling a defined quantity of the resulting waste each year. It shifts the cost and the accountability of end-of-life management onto the business that benefits from the packaging, under the polluter-pays principle set by the Environment (Protection) Act, 1986.
The Central Pollution Control Board (CPCB) administers the regime on a central online portal. An obligation is expressed as a quantity of plastic waste and discharged with EPR certificates generated by registered plastic recyclers and end-of-life processors on that portal, so a compliant year is one where the obligated business holds certificates of the matching category against its target and has filed its returns.
The obligation binds Producers, Importers and Brand Owners, together abbreviated PIBOs. A producer manufactures plastic packaging, an importer brings plastic 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 next sections set out exactly who is caught, the five categories the packaging is sorted into, and how registration is done.
The commercial side, where a consultant registers a business, computes its category-wise targets, sources the certificates and files the returns, sits on the plastic packaging EPR service. This guide holds the how-it-works detail for plastic packaging.
Who needs plastic packaging EPR
The obligation falls on producers, importers and brand owners of plastic packaging, with no turnover or tonnage threshold except a limited exemption for the smallest brand owners.
Producers. A business that manufactures plastic packaging, plastic sheets or carry bags is a producer and registers on the plastic EPR portal.
Importers, including of raw material. The importer definition was widened by G.S.R. 201(E), in force 14 March 2024, to cover not only finished plastic packaging but also importers of plastic raw material such as resin, pellets and intermediate material like films and preforms. Since CBIC Instruction 21/2025-Customs of 2 July 2025, Customs verifies a plastic-raw-material importer EPR registration before clearing the consignment, so registration precedes import for these businesses.
Brand Owners. A business that sells any commodity in plastic packaging under its own brand is a brand owner, whether or not it makes the item or the packaging. This reaches online marketplaces and retail chains as well as manufacturers, because the plastic packaging carries the obligation.
A business is bound if it does any of the following in India:
- manufactures plastic packaging, sheets or carry bags;
- imports plastic packaging, goods in plastic packaging, or plastic raw material such as resin, pellets or preforms;
- sells goods in plastic packaging under its own brand.
There is no turnover or tonnage floor for producers and importers; they register regardless of size. The one carve-out is for micro and small brand owners, set out under exemptions below. A brand that owes plastic packaging EPR often also owes e-waste or battery EPR on the same products, which the full EPR guide covers across all six CPCB streams.
The five plastic packaging categories (Schedule II)
Schedule II sorts plastic packaging into five categories, and every target runs by category, so identifying the category for each product is the first step in any plastic EPR calculation.
The consolidated Plastic Waste Management Rules define five plastic packaging categories. The 2026 amendment (gazette G.S.R. 237(E), 31 March 2026) split the earlier compostable category in two, adding Category V for biodegradable plastics, so the current framework has five categories, not four.
| Category | What it covers | Recycled-content obligation |
|---|---|---|
| Category I | Rigid plastic packaging: PET and HDPE or PP bottles and jars, containers, tubs, jerry cans, drums and thick-wall packaging that holds its shape. | Applies |
| Category II | Flexible plastic packaging of a single layer or of multiple layers of plastic, plus plastic sheets, covers, carry bags, sachets and pouches. Conventional non-compostable carry bags sit here, not in Category IV. | Applies |
| Category III | Multilayered packaging with at least one layer of plastic and at least one layer of a material other than plastic, such as aluminium foil or paper laminated with plastic. | Applies, on the plastic layers only |
| Category IV | Compostable plastic packaging, sheets, carry bags and commodities made of compostable plastics carrying a valid CPCB compostable certification. | Not applicable |
| Category V | Biodegradable plastic packaging, sheets, carry bags and commodities made of biodegradable plastics. Added by the 2026 amendment, separating it from compostable Category IV. | Not applicable |
The test that separates Category II from Category III is the presence of a non-plastic layer: a pack whose layers are all plastic is Category II, while a pack combining a plastic layer with a foil or paper layer is Category III. The compostable and biodegradable qualifier is load-bearing for Categories IV and V: a conventional plastic carry bag is Category II, and only a certified compostable or biodegradable bag falls in Category IV or V. Getting the category right is what makes the computed target the correct one.
How to register on the CPCB portal
Plastic packaging EPR registration runs on the CPCB Common EPR single sign-on: one corporate login at epr.cpcb.gov.in issues a master CEPR ID, and the plastic module at eprplastic.cpcb.gov.in carries the producer, importer or brand owner application. The single sign-on and CEPR ID model is confirmed; whether migration to the CEPR ID is mandatory before the plastic module opens, and the precise order of the steps, are confirmed against the live portal.
- Create the SSO account and CEPR IDThe CPCB Common EPR single sign-on at epr.cpcb.gov.in issues a master CEPR ID against a corporate email and a signatory mobile one-time password.
- Open the plastic module and applyInside the plastic module at eprplastic.cpcb.gov.in the entity files its application as producer, importer or brand owner, declaring the categories handled and the quantity introduced. The registering authority is the State Pollution Control Board or Pollution Control Committee for operations in one or two States or Union Territories and the CPCB for more than two, though every applicant applies on the same central portal.
- Complete KYC and consentsThe application assembles PAN, GST for each State or Union Territory, the Company Identification Number for companies or the Importer Exporter Code for importers, and the consents to establish and operate for any manufacturing site. Importers of plastic raw material must hold the registration before customs clearance.
- Compute targets and source certificatesThe category-wise and year-wise targets are computed from the quantity placed on the market and discharged by sourcing matching EPR certificates from registered recyclers on the portal. The application fee scales with the annual plastic-waste generation in tonnes per annum; the renewal fee equals the registration fee and the annual processing fee is 25 per cent of the application fee.
- File returns and keep the recordThe annual return is filed for the prior financial year, the records are retained for a CPCB or State board audit, and the registration is renewed on the portal ahead of expiry.
Registration flow verified to the SSO/CEPR-ID model; awaiting owner confirmation of the exact current client SOP.
Compliance timeline and key dates
Two calendars govern plastic packaging EPR: a set of recurring filing dates that returns every year, and the phased rollout of the rulebook itself. Both are set out here as durable rules rather than a single current-year deadline, because the CPCB issues administrative extensions.
Part A. The recurring compliance calendar
The same filing dates return every financial year. These are the base statutory dates set in Schedule II.
| Obligation | Recurring date |
|---|---|
| PIBO annual EPR return | 30 June, for the prior financial year |
| Plastic waste processor return | 30 April |
| Registration renewal | Apply at least 120 days before expiry. The registration is valid for one year, then renewed for three years; the renewal fee equals the registration fee. |
| Through the year | Procure and reconcile EPR certificates of the matching category and maintain the records. |
Part B. The regulatory rollout
- 2016The Plastic Waste Management Rules are notified (G.S.R. 320(E), 18 March 2016).
- 16 Feb 2022The EPR Guidelines are inserted as Schedule II, setting the category-wise targets and the tradable EPR certificate mechanism.
- 14 Mar 2024The importer definition is widened by G.S.R. 201(E) to cover importers of plastic raw material such as resin, pellets and intermediate material.
- 2 Jul 2025CBIC Instruction 21/2025-Customs directs Customs to verify a plastic-raw-material importer EPR registration before clearing the consignment.
- 31 Mar 2026The Plastic Waste Management (Amendment) Rules 2026 (G.S.R. 237(E)) add Category V for biodegradable plastics, escalate the reuse obligations on brand owners, and add a food-contact recycled-content carry-forward.
- FY2025-26 to 2028-29The minimum recycled-content obligation phases in and rises year on year for Categories I, II and III.
- PendingA registered environment auditor verification route is provided in the 2026 rules and becomes operational once the CPCB issues its implementing guidelines.
The recurring dates in Part A are the base statutory dates. The CPCB has repeatedly issued administrative extensions of the 30 June annual-return date, so the operative deadline for any given year is confirmed against the current CPCB portal notice rather than assumed. As at this review, the CPCB implementing guidelines for the environment-auditor verification route were still awaited, so that route is treated as pending.
Your plastic EPR targets
A plastic EPR target is the share of the packaging placed on the market that must be recycled or, on the input side, filled with recycled content. It is set by category and financial year and rises over time, never a single blended figure.
The obligation is a quantity. The eligible quantity is computed as Q = (A + B) minus C for a producer or importer and Q = A + B for a brand owner, where A and B are trailing two-financial-year averages of the plastic packaging placed on the market and the pre-consumer plastic waste, and C is the quantity supplied to a brand owner in the prior financial year, subtracted so the same tonnage is not counted twice.
The overall EPR target rose from 25 per cent in 2021-22 to 70 per cent in 2022-23 and 100 per cent from 2023-24 onward, so a PIBO is now obligated for the full eligible quantity each year, split by the category-wise targets below.
Category-wise recycling targets
The recycling target is the share of the EPR obligation that must be recycled rather than only sent to an end-of-life route. It rises ten percentage points a year.
| Category | 2024-25 | 2025-26 | 2026-27 | 2027-28+ |
|---|---|---|---|---|
| Category I (rigid) | 50% | 60% | 70% | 80% |
| Category II (flexible) | 30% | 40% | 50% | 60% |
| Category III (multilayered) | 30% | 40% | 50% | 60% |
| Category IV (compostable) | 50% | 60% | 70% | 80% |
The gazetted recycling-target table lists Categories I to IV. Whatever is not recycled is discharged through the specified end-of-life routes, such as waste-to-energy, co-processing or, for Category IV, industrial composting.
Minimum recycled-content targets
Separately, a minimum share of the plastic introduced must itself be recycled plastic, effective from the financial year 2025-26.
| Category | 2025-26 | 2026-27 | 2027-28 | 2028-29+ |
|---|---|---|---|---|
| Category I (rigid) | 30% | 40% | 50% | 60% |
| Category II (flexible) | 10% | 10% | 20% | 20% |
| Category III (multilayered) | 5% | 5% | 10% | 10% |
| Categories IV and V | Not applicable | |||
For Category III the recycled-content obligation is limited to the weight of the plastic layers only. Importers cannot physically add recycled content, so their only discharge route is buying EPR certificates. Food-contact recycled plastic packaging must conform to IS 14534:2023 and carry FSSAI marking. The 2026 amendment also placed escalating reuse obligations on brand owners for rigid Category I packaging, rising year on year from 2025-26.
How to estimate a plastic EPR liability
A plastic EPR liability follows from the tonnage placed on the market, sorted by category, multiplied by the category-wise target, and met by procuring EPR certificates.
Estimating a plastic EPR liability starts from the tonnage of packaging placed on the market, sorted into the five categories, because every target runs by category. Each category tonnage is multiplied by its year-wise recycling target to give the quantity of matching EPR certificates to procure, and, for Categories I, II and III, the recycled-content obligation is computed on the input side against the plastic introduced that year.
The cost is the market price of those certificates plus the compliance work, and it is the certificate market, not a fixed rate, that sets the number. A short scoping turns a product catalogue and prior-year volumes into a category-by-category picture of the certificates and returns that will be due.
Exemptions
The exemptions are narrow. Only the smallest brand owners and export-oriented units are exempt from the obligation, and being compostable or biodegradable does not remove a product from the framework.
Micro and small brand owners, measured on the Ministry of MSME criteria, are exempt from plastic packaging EPR obligations, and export-oriented units are also exempt. The exemption is limited to brand owners; it does not extend to producers or importers, who register regardless of size. There is no separate turnover or tonnage threshold beyond this carve-out.
Compostable and biodegradable packaging, Categories IV and V, carries no minimum recycled-content obligation, but the material still sits inside the EPR framework and the packaging is not exempt from registration on that basis alone.
Because the exemption turns on the precise entity type and the MSME classification, the safe course is to confirm the classification before assuming an exemption applies.
Penalties: environmental compensation
Non-compliance is enforced through environmental compensation, a per-tonne levy on the polluter-pays principle that escalates for repeat shortfalls and does not cancel the underlying obligation.
Environmental compensation is the financial levy the CPCB imposes for falling short of an EPR target or a filing obligation. Its statutory basis is Section 15 of the Environment (Protection) Act, 1986, as amended by the Jan Vishwas (Amendment of Provisions) Act, 2023.
The compensation is levied per tonne of unmet obligation and escalates for consecutive-year shortfalls. The CPCB sets and revises the per-tonne amounts through its environmental-compensation guidelines and keeps them above the prevailing market price of an EPR certificate, so the operative rate is read from the current CPCB guideline rather than assumed here.
Paying compensation does not extinguish the obligation. The unfulfilled EPR is carried forward for three years, and the compensation is refunded in part, 75 per cent, 60 per cent or 40 per cent, if the obligation is met within one, two or three years; after three years the compensation is forfeited in full. Late or non-filing of returns can also trigger compensation and suspension of the portal registration.
Plastic packaging EPR questions, answered
Common questions on what plastic EPR is, the five categories, who must register, registration, the return dates, importers and non-compliance, answered for businesses working out their obligation.
What is EPR for plastic packaging?
EPR for plastic packaging is Extended Producer Responsibility under Schedule II of the Plastic Waste Management Rules, 2016. It makes the producer, importer or brand owner that places plastic packaging on the Indian market responsible for collecting back and recycling a defined quantity of the resulting waste each year, administered by the Central Pollution Control Board on a central online portal and discharged through tradable EPR certificates.
How many categories of plastic packaging are there under EPR?
There are five. Category I is rigid plastic packaging, Category II is flexible plastic packaging including sheets, covers, carry bags and pouches, Category III is multilayered packaging combining a plastic layer with a non-plastic layer such as foil or paper, Category IV is compostable plastic packaging, and Category V is biodegradable plastic packaging, which the 2026 amendment added by splitting it out from compostable. Every target runs by category, so identifying the category for each product comes first.
Which category do plastic carry bags fall under?
It depends on the material. A conventional, non-compostable plastic carry bag is Category II, the flexible category, not Category IV. A certified compostable carry bag is Category IV and a biodegradable carry bag is Category V. The compostable or biodegradable qualifier is what moves a bag out of Category II.
Who needs plastic packaging EPR registration?
Producers, importers and brand owners of plastic packaging, together abbreviated PIBOs. A producer manufactures the packaging, an importer brings plastic 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. Producers and importers register regardless of size; only micro and small brand owners and export-oriented units are exempt.
Do cosmetic, FMCG and D2C brands need plastic EPR?
Yes, where they sell goods in plastic packaging. There is no separate cosmetics, FMCG or e-commerce regime; the plastic packaging carries the obligation, so a cosmetics, food or direct-to-consumer brand that places goods in plastic packaging on the Indian market is a brand owner under the plastic packaging rules and registers on the plastic EPR portal, unless it qualifies as a micro or small enterprise brand owner.
How is plastic EPR registration done?
Registration runs on the CPCB Common EPR single sign-on. A corporate login at epr.cpcb.gov.in issues a master CEPR ID, and the plastic module at eprplastic.cpcb.gov.in carries the producer, importer or brand owner application, with KYC documents, the applicable consents and the tonnage-based fee. The single sign-on and CEPR ID model is confirmed; the precise order of the steps is confirmed against the live portal.
When is the plastic EPR annual return due?
The base statutory date for the PIBO annual EPR return is 30 June, for the prior financial year, and plastic waste processors file by 30 April. The CPCB has repeatedly issued administrative extensions of the 30 June date, so the operative deadline for any given year is confirmed against the current CPCB portal notice rather than assumed.
Do importers of plastic raw material need EPR registration?
Yes. The importer definition was widened with effect from 14 March 2024 to cover importers of plastic raw material such as resin, pellets and intermediate material. Since a CBIC customs instruction of 2 July 2025, Customs verifies the importer EPR registration before clearing plastic-raw-material consignments, so registration must be in place before import.
What happens on non-compliance with plastic EPR?
The CPCB levies environmental compensation, a per-tonne financial levy on the polluter-pays principle that escalates for consecutive-year shortfalls, under Section 15 of the Environment (Protection) Act, 1986 as amended by the Jan Vishwas Act, 2023. Paying it does not cancel the obligation: the shortfall is carried forward for three years, part of the compensation is refunded if the obligation is met within one to three years, and late filing can suspend the portal registration.
How long is a plastic EPR registration valid?
The registration is valid for one year and is then renewed for three years. The renewal application is filed at least 120 days before expiry, and the renewal fee equals the registration fee. Filing the returns and holding a live registration are what keep the obligation in good standing.
Primary sources
The rules cited in this guide come from the Central Pollution Control Board and the Government of India notifications.
Scope a plastic EPR registration
This guide sets out how plastic packaging EPR works; a short scoping applies it to a specific catalogue. A few structured questions about the packaging placed on the market and the role in each category turn into a clear picture of the registration, the targets and the certificates that apply. The EPR solutions page sets out the full engagement.
Reviewed 23 July 2026