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, 2026 of 31 March 2026 reshaped certificates, audits and shortfall handling, so a 2024 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 market driven, with no statutory floor or ceiling, unlike the banded e-waste and battery markets. 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 for a second consecutive year and 20,000 INR for a 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 2026 amendment responds with verification by Registered Environment Auditors and a formalised portal trading mechanism.
What the 2026 amendment changed
- The 2025-26 recycled content shortfall can be carried forward three years, clearing at least one third each year, a relief aimed at food-contact packaging where FSSAI restrictions limit recycled material.
- Importers cannot count recycled content in imported packaging; the route is buying equivalent certificates from surplus PIBOs.
- Chemical recycling to feedstock now counts as recycling, while energy recovery, co-processing and road construction sit under a redefined end-of-life disposal.
- Certificate verification moves to Registered Environment Auditors under the Environment Audit Rules, 2025.
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 a Registered Environment Auditor’s review.
- Use the carry-forward deliberately, clearing at least one third of any recycled content shortfall each year.
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. The 2026 amendment allows a three year carry forward of the 2025-26 shortfall and requires recycled material to conform to IS 14534:2023.
How much do plastic EPR certificates cost?
Plastic certificate prices are market driven on the CPCB portal, with no statutory floor or ceiling, unlike the banded e-waste and battery certificate markets. Prices move with category, year and supply, 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 for a second consecutive year and 20,000 INR for a 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.
