EPR for plastic packaging in India: registration, targets, certificates and annual returns

Extended Producer Responsibility (EPR) makes the companies that put packaging on the market responsible for what happens to it afterwards. For plastic packaging in India, that means registering, meeting yearly targets with certificates, and filing a return — with real money at stake for a shortfall. This guide covers who is obligated, the targets to 2028-29, how certificates and returns work, and the parallel rules for batteries and e-waste.

Which rules apply?

EPR for plastic packaging sits in the Plastic Waste Management Rules, 2016. The detailed Guidelines on Extended Producer Responsibility were added as Schedule II in February 2022 (G.S.R. 133(E))¹, and have been amended several times since — most significantly in March 2024 (G.S.R. 201(E))², January 2025 (G.S.R. 73(E))³ and March 2026 (G.S.R. 237(E))⁴. The Central Pollution Control Board (CPCB) runs a centralised online EPR portal for registration, certificates and returns¹.

Who must register?

• Producers of plastic packaging, importers of plastic packaging or of products packed in it, and brand owners — including e-commerce marketplaces and retail chains that sell under their own brand — together called PIBOs¹.
• Plastic waste processors: recyclers and others that process plastic waste and generate EPR certificates¹.
• Since the 2024 amendment, also manufacturers and importers of plastic raw material, and manufacturers of compostable and biodegradable plastics; micro and small enterprises are left out of the definitions of producer and brand owner².

Registration is on the CPCB portal before the business operates².

The five categories

Category V was added in 2024². The obligation is calculated by category. Since 2023-24 it covers 100% of the eligible quantity — broadly, the plastic packaging a PIBO put on the market¹.

What are the targets?

Three kinds of target apply, by category and year¹⁴:

Minimum recycling (share of the EPR obligation to be met through recycling):

Use of recycled plastic in packaging:

Reuse applies to brand owners' rigid (Category I) packaging, by container size. The 2026 amendment keeps the highest reuse targets (70% rising to 85%) for drinking-water containers of 4.9 litres or more, and sets lower targets for other large containers⁴.

The 2026 amendment also allows an exemption where another law bars recycled plastic in a use, counts only the plastic layers of Category III packaging, carries forward the 2025-26 shortfall in recycled content for food-contact packaging over the following three years, and counts feedstock recycling as recycling⁴.

How do EPR certificates work?

Registered plastic waste processors generate EPR certificates on the portal for the quantity they process, by category. PIBOs buy them to meet their targets; a surplus can be used against other obligations, carried forward or sold¹. Since 2024, certificates are exchanged on platforms authorised by CPCB, within a price band whose ceiling is 100% and floor 30% of the environmental compensation for that category².

Annual returns and deadlines

PIBOs file an annual return on the portal by 30 June of the following financial year¹. For FY 2025-26, the deadline was extended to 31 December 2026 for PIBOs and 31 October 2026 for plastic waste processors⁵.

Since 1 July 2025, the information required on packaging — including the registration number — can be given through a barcode or QR code printed on it³.

What happens on a shortfall?

A shortfall attracts environmental compensation, and the unmet target is carried forward. If the shortfall is made good within one, two or three years, 75%, 60% or 40% of the compensation is returned⁶. CPCB's August 2024 rates were reported as ₹2,900 per tonne for Category I, ₹5,000 for Category II and ₹7,900 for Categories III and IV, with higher rates for repeat shortfalls⁶.

Batteries and e-waste

Two parallel regimes follow the same pattern of registration, targets, certificates and returns:

• Batteries: under the Battery Waste Management Rules, 2022, producers of all battery types register with CPCB, meet collection and recovery targets — for portable and electric-vehicle batteries, 70% for 2024-25, 80% for 2025-26 and 90% from 2026-27 — and file annual returns by 30 June, with recycled-content obligations from 2027-28⁷.
• E-waste: under the E-Waste (Management) Rules, 2022, in force since April 2023, manufacturers and producers of covered electrical and electronic equipment register and meet recycling targets — 60% for 2023-24 and 2024-25, 70% for 2025-26 and 2026-27, and 80% from 2027-28 — using certificates generated by registered recyclers, within a price band set by CPCB⁸.

How EPR shows up in BRSR

Under Principle 2, BRSR asks whether EPR applies to the company's activities and, if so, whether its waste collection plan is in line with the EPR plan submitted to the pollution control boards⁹. The figures behind your EPR returns — packaging placed on the market by category, certificates purchased, recycled content used — are also the evidence for that answer, and for the waste indicators of BRSR Core.

How ESGTrack helps

ESGTrack works out the obligation for each EPR stream — plastic packaging, e-waste, batteries, waste tyres and used oil — with its arithmetic, from the same approved data as your BRSR; matches certificates from registered recyclers to obligations; and prepares the annual returns and the figures BRSR Principle 2 asks for. See compliance programmes and our guide to CSR under section 135, the other obligation that runs alongside BRSR.