Extended Producer Responsibility (EPR) for plastic packaging makes Producers, Importers and Brand Owners (PIBOs) financially responsible for the plastic they place on the Indian market. The regime runs under the Plastic Waste Management Rules, 2016, whose Schedule II EPR guidelines were inserted by the amendment of 16 February 2022, and operates through the centralised CPCB EPR portal.
The obligation year now running carries live duties on three fronts at once: category-wise recycling targets, the minimum recycled content mandate that took effect in 2025-26, and rigid packaging reuse targets. The PWM (Amendment) Rules, 2024 of 14 March 2024 reshaped categories, obligated entities and certificate trading, so a 2022 understanding of the regime no longer files a clean return.
Who is obligated and the five packaging categories
Every producer, importer and brand owner placing plastic packaging on the market, and every plastic waste processor, must register on the CPCB portal; an unregistered entity cannot lawfully operate. The obligation is computed per category:
| Category | What it covers |
|---|---|
| I | Rigid plastic packaging |
| II | Flexible packaging, single or multi-layer all-plastic: sheets, covers, carry bags, sachets, pouches |
| III | Multilayered packaging with at least one plastic and one non-plastic layer |
| IV | Compostable plastic packaging and carry bags |
| V | Biodegradable plastic packaging, separated from compostable by the March 2024 amendment, with its own BIS marking and mandatory CPCB certification |
The targets in force, 2025-26 to 2027-28
The collection obligation has stood at 100 percent of the eligible quantity since 2023-24. What phases up are the recycling and recycled content duties:
| Category | 2025-26 | 2026-27 | 2027-28 on |
|---|---|---|---|
| I Rigid | 60% | 70% | 80% |
| II Flexible | 40% | 50% | 60% |
| III Multilayered | 40% | 50% | 60% |
| IV Compostable | 60% | 70% | 80% |
| Category | 2025-26 | 2026-27 | 2027-28 | 2028-29 on |
|---|---|---|---|---|
| I Rigid | 30% | 40% | 50% | 60% |
| II Flexible | 10% | 10% | 20% | 20% |
| III Multilayered | 5% | 5% | 10% | 10% |
Rigid packaging also carries reuse targets from 2025-26, rising through 2028-29, and recycled plastic must conform to IS 14534:2023 with FSSAI marking where food contact applies.
Certificates, annual returns and environmental compensation
Registered recyclers and processors generate EPR certificates on the portal against verified quantities, and PIBOs source certificates of the matching category to discharge the obligation. Plastic certificate pricing is banded, not free-floating: Schedule II paragraphs 8.8 and 8.9, inserted on 14 March 2024, require CPCB to fix the highest and lowest certificate price at 100 percent and 30 percent of the environmental compensation leviable for non-fulfilment, and portal trades must settle inside that band. Annual returns fall due by 30 June after the obligation year.
A shortfall draws environmental compensation of 5,000 INR per tonne, 10,000 INR the second time and 20,000 INR the third, under the CPCB guidelines of 4 April 2024. Compensation does not extinguish the duty: the shortfall carries forward three years, and most of the payment refunds when the obligation is later met.
Trust in the certificate market is being rebuilt after CPCB audits in 2024 found several lakh fraudulent certificates and levied compensation of around 355 crore INR. The amendment of 14 March 2024 keeps certificates subject to verification by the Central Pollution Control Board or the State Pollution Control Board or Pollution Control Committee concerned, and directs CPCB to issue guidelines for authorising agencies to establish electronic platforms for trade in EPR certificates.
What changed, and when
- An unfulfilled obligation carries forward to the next year for a period of three years. Where a statutory requirement such as a food-contact rule makes the recycled content obligation impossible to meet, CPCB grants an exemption case by case, and the obligation is still discharged in quantitative terms by buying certificates of equivalent quantity from PIBOs who used recycled content in excess of their own obligation.
- Since 16 February 2022, importers cannot count recycled content in imported packaging; the route is buying equivalent certificates from surplus PIBOs.
- Since 6 July 2022, feedstock chemicals produced from plastic waste for further use in making plastic count under recycling, while energy generation, co-processing and waste to oil sit under end-of-life disposal.
- Certificates are subject to verification by the Central Pollution Control Board or the State Pollution Control Board or Pollution Control Committee concerned, and where the figures reported by the PIBO and the registered processor differ, the lower figure counts towards the obligation.
Separately, since 1 July 2025 the mandatory packaging information may be carried by barcode, QR code, product brochure or a unique number under the January 2025 amendment, and the single-use plastic ban of 1 July 2022 on 19 items, with the 120 micron carry bag floor, remains fully in force.
What PIBOs should do for a clean 2026-27 year
- Re-map the portfolio across the five categories, including the compostable against biodegradable split.
- Plan certificates early. Targets step up to 70 and 50 percent in 2026-27, and late-year certificate sourcing pays scarcity prices.
- Secure recycled content supply that meets IS 14534:2023, or structure the certificate route where imports are involved.
- File by 30 June with documentation that survives verification by the Central Pollution Control Board, or the State Pollution Control Board or Pollution Control Committee concerned.
- Use the carry-forward deliberately. Clearing the shortfall within one year of the environmental compensation being levied returns 75 percent of it, within two years 60 percent and within three years 40 percent, after which the whole amount is forfeited.
Plastic EPR questions, answered
Who must register for plastic packaging EPR in India?
Every producer, importer and brand owner placing plastic packaging on the Indian market, and every plastic waste processor, must register on the centralised CPCB EPR portal under the Plastic Waste Management Rules. Operating without registration is barred, and registration is also the gateway for filing annual returns and holding EPR certificates.
What are the plastic EPR recycling targets for 2025-26 and 2026-27?
As a share of the EPR obligation: rigid Category I and compostable Category IV carry 60 percent in 2025-26 and 70 percent in 2026-27, while flexible Category II and multilayered Category III carry 40 percent rising to 50 percent, all reaching 80 and 60 percent respectively from 2027-28.
Is recycled content mandatory in plastic packaging?
Yes, since 2025-26. Rigid Category I packaging needs 30 percent recycled plastic, rising to 60 percent by 2028-29; flexible Category II needs 10 percent rising to 20; multilayered Category III needs 5 percent rising to 10. Schedule II carries an unfulfilled obligation forward for three years, and the March 2024 amendment requires recycled plastic packaging to conform to IS 14534:2023.
How much do plastic EPR certificates cost?
Plastic certificate prices are banded on the CPCB portal, not free. Under Schedule II paragraphs 8.8 and 8.9, inserted by the PWM (Amendment) Rules, 2024 of 14 March 2024, CPCB fixes the highest and lowest certificate price at 100 percent and 30 percent respectively of the environmental compensation leviable for non-fulfilment, and the exchange price between registered entities through the portal must sit between the two. Prices still move with category, year and supply inside that band, which is why early sourcing against a computed obligation beats year-end scarcity buying.
What happens if the EPR target is missed?
Environmental compensation applies at 5,000 INR per tonne of shortfall, 10,000 INR the second time and 20,000 INR the third. The obligation itself carries forward three years, and 75 percent of the compensation refunds if the shortfall clears within a year, so compensation is a financing cost rather than a settlement.
Is the single-use plastic ban still in force?
Yes. The ban on 19 identified single-use plastic items has applied since 1 July 2022, plastic carry bags must be at least 120 micron, and no banned item has been de-notified. Enforcement has tightened alongside the EPR regime rather than relaxed.
GreenSutra handles CPCB registration, category mapping, certificate planning and audit ready returns across all six EPR streams through dedicated EPR registration and compliance solutions.
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Primary sources
Updated 29 July 2026 — Corrected against the Plastic Waste Management Rules and the amendments of 16 February 2022 (G.S.R. 133(E)), 6 July 2022 (G.S.R. 522(E)), 14 March 2024 (G.S.R. 201(E)) and 23 January 2025 (G.S.R. 73(E)), and CPCB’s environmental compensation guidelines of 4 April 2024. References to a 2026 amendment have been removed: no such notification exists, and the changes described were made in 2022 and 2024.
