Plastic EPR in India
What does plastic EPR mean for businesses in India?
Plastic EPR in India: what it requires of businesses (as of November 2026)
If your business puts plastic packaging on the Indian market, you must register on CPCB's online EPR portal. You must not trade with anyone who is not registered. Each year you have to show, through certificates from registered recyclers and processors, that you collected and processed 100% of your "eligible quantity" of packaging. You also face rising targets for recycling, recycled content and (for rigid packaging) reuse. Missing a target costs you Environmental Compensation, and paying it does not cancel the obligation.
Approach: The datasets only hold the superseded 2011 plastic rules and CPCB's EPR portal directory. So I read the current Plastic Waste Management Rules, 2016 and their amendments (2022, 2024, January 2025 and March 2026) as published by MoEFCC and CPCB, plus CPCB's April 2024 Environmental Compensation guidelines.
Legal basis
- EPR comes from Rule 9 of the Plastic Waste Management Rules, 2016. The detailed obligations are in Schedule II, "Guidelines on Extended Producer Responsibility for Plastic Packaging", which G.S.R. 133(E) of 16 February 2022 inserted. Schedule II applies to both pre-consumer and post-consumer packaging waste (G.S.R. 133(E), pp. 21-23).
- Since G.S.R. 201(E) of 14 March 2024, Rule 9 reads: producers, importers and brand owners (PIBOs) who introduce plastic packaging "shall be responsible for collection". Fulfilling EPR counts as meeting that duty (G.S.R. 201(E), p. 27).
Who is obligated (Schedule II para 4, as substituted in 2024)
- Producers of plastic packaging, other than micro and small enterprises. Since 2024 a "producer" also includes makers of intermediate material (films, preforms) and contract manufacturers who pack products for brand owners.
- Importers of plastic packaging, intermediate material and the packaging on imported products. Importers of plastic raw material (resin, pellets) also count as importers.
- Brand owners, including online marketplaces and supermarket or retail chains, other than micro and small enterprises.
- Plastic waste processors, manufacturers and importers of plastic raw material, and manufacturers of compostable or biodegradable plastic items.
- Micro and small producers must still register. Their collection target is met by the raw-material supplier that sold to them, but they must meet their own recycled-content target.
All of this is in G.S.R. 201(E), pp. 26, 29-30.
Packaging categories
| Category | What it covers |
|---|---|
| I | Rigid plastic packaging |
| II | Flexible single-layer or multilayer plastic packaging, sheets, carry bags, sachets and pouches |
| III | Multilayered packaging (at least one plastic layer plus at least one non-plastic layer) |
| IV | Compostable plastic sheets, carry bags and commodities |
| V | Biodegradable plastic sheets, carry bags and commodities (added in 2024) |
Sources: G.S.R. 133(E), pp. 22-23; G.S.R. 201(E), pp. 29-30.
Registration (Schedule II para 6)
- Who registers you depends on your footprint:
- Operating in one or two states: the State Pollution Control Board or Pollution Control Committee, through CPCB's portal.
- Operating in more than two states: CPCB.
- Registered entities "shall not carry any business without registration" and "shall not deal with any entity not registered".
- You need a separate registration for each role you play (producer, importer, brand owner) and for each state.
- You must provide PAN, GST, CIN and Aadhaar details.
- If you give false information, your registration is revoked for one year.
Sources: G.S.R. 133(E), p. 23; CPCB portal: https://eprplastic.cpcb.gov.in/#/plastic/home [1].
Targets
Collection target. Since 2023-24 the target is 100% of the eligible quantity, set category by category. It was 25% in 2021-22 and 70% in 2022-23. The eligible quantity is calculated differently for each role:
- Producers: average packaging sold over the last two financial years, plus pre-consumer waste, minus quantities supplied to brand owners.
- Brand owners: average virgin packaging purchased and introduced to the market over the last two years, plus pre-consumer waste.
(G.S.R. 133(E), pp. 24-26.)
Minimum share of the target that must be recycled (end-of-life disposal does not count):
| Category | 2024-25 | 2025-26 | 2026-27 | 2027-28 onwards |
|---|---|---|---|---|
| I | 50% | 60% | 70% | 80% |
| II | 30% | 40% | 50% | 60% |
| III | 30% | 40% | 50% | 60% |
| IV | 50% | 60% | 70% | 80% |
Only plastic that cannot be recycled may go to end-of-life uses: co-processing, waste-to-energy, waste-to-oil or road construction. Since 2026, converting plastic into feedstock chemicals or new plastic counts as recycling (G.S.R. 237(E), p. 10).
Mandatory recycled content (as restated in March 2026):
| Category | 2025-26 | 2026-27 | 2027-28 | 2028-29 onwards |
|---|---|---|---|---|
| I | 30% | 40% | 50% | 60% |
| II | 10% | 10% | 20% | 20% |
| III | 5% | 5% | 10% | 10% |
- The targets do not apply where a law, an FSSAI, CDSCO or Central Insecticide Board rule, or a mandatory Indian Standard forbids recycled content. To claim this exemption you must cite the provision in your annual return.
- For Category III, the target applies only to the weight of the plastic layers.
- For food-contact packaging, any 2025-26 shortfall may be carried forward over three years from 2026-27, with at least one-third made up each year.
- Recycled plastic already in imported material does not count. Importers must buy certificates instead.
(G.S.R. 237(E), pp. 12-15.)
Reuse targets for brand owners using Category I rigid packaging:
| Pack size | 2025-26 | 2026-27 | 2027-28 | 2028-29 onwards |
|---|---|---|---|---|
| 0.9 L/kg or more but under 4.9 L/kg | 10% | 15% | 20% | 25% |
| 4.9 L/kg or more, drinking water | 70% | 75% | 80% | 85% |
| 4.9 L/kg or more, other products | 10% | 10% | 15% | 15% |
Reuse is exempt where regulation prohibits it, and 2025-26 shortfalls carry forward on the same one-third-per-year basis (G.S.R. 237(E), p. 14).
Certificates, returns and audit
- Only certificates from registered processors count toward your obligation. Where your figures and the processor's differ, the lower figure is used.
- PIBOs file annual returns by 30 June of the following financial year. Processors file by 30 April.
- Surplus certificates can offset earlier shortfalls, be carried forward or be sold, but only within the same category.
- CPCB fixes a price band for certificates: the ceiling is 100% and the floor 30% of the Environmental Compensation rate.
- CPCB publishes each year, by 30 September, a list of PIBOs that missed their targets.
- Since 2026, Registered Environment Auditors may carry out compliance audits.
Sources: G.S.R. 133(E), pp. 28-32; G.S.R. 201(E), pp. 30-31; G.S.R. 237(E), p. 16.
What non-compliance costs
- CPCB's April 2024 guidelines set Environmental Compensation for an EPR shortfall at Rs 5,000 per tonne. A second offence costs Rs 10,000 per tonne and a third Rs 20,000 per tonne.
- If you make up the shortfall later, part of the compensation is refunded: 75% within one year, 60% within two years, 40% within three years. After three years it is forfeited.
- Late annual returns are charged Rs 5,000, then Rs 10,000, in escalating steps.
- Rates are to be reviewed every six months and kept about 15-20% above market prices for EPR credits.
(CPCB EC guidelines, pp. 26-28.)
Since January 2025, new Rule 19 also makes anyone who breaches the Rules "liable to a penalty" under section 15 of the Environment (Protection) Act (G.S.R. 73(E), p. 3).
Labelling
- Rule 11(1): packaging must show the producer's or brand owner's name and registration number (as quoted in CPCB's EC guidelines, pp. 21-22). Breaches are fined Rs 2,000, Rs 5,000 and Rs 10,000 for successive violations, and registration can be cancelled.
- From 1 July 2025 this information may instead be given through a barcode or QR code, a product brochure or a statutory unique number. You must inform CPCB if you use this option (G.S.R. 73(E), pp. 2-3).
- Recycled-content packaging must conform to IS 14534:2023, carry the recycled-content mark, and meet FSSAI labelling requirements for food contact (G.S.R. 237(E), p. 10).
Limits of this review
- I read MoEFCC's and CPCB's copies of the Gazette notices because the e-Gazette server could not be reached.
- I did not read the July 2022, April 2023 and October 2023 amendments (G.S.R. 522(E), 318(E) and 807(E)), apart from where later texts quote them.
- The Environmental Compensation figures come from CPCB's April 2024 guidelines. I did not find a later revision.
I can go into any one role (for example importer only) or the registration steps on the portal if that would help.
Who needs to register for plastic packaging EPR?
Under Schedule II of India's Plastic Waste Management Rules, 2016, six kinds of entity shall register on CPCB's centralised EPR portal: producers (now including micro and small producers), importers, brand owners, plastic waste processors, manufacturers and importers of plastic raw material, and manufacturers of compostable or biodegradable plastic items. Unregistered entities may not do business, and registered entities may not deal with anyone who is unregistered.
Approach: The only plastic rules in the datasets are the superseded 2011 rules [2]. I therefore read the official Gazette texts of the February 2022 amendment (G.S.R. 133(E), which inserted Schedule II) and the March 2024 amendment (G.S.R. 201(E), which replaced the registration list).
Who must register on the CPCB portal (Schedule II para 6.1(a), as substituted in 2024)
| # | Entity | Notes |
|---|---|---|
| (i) | Producer (P) | Explicitly "including micro and small enterprises" as defined in the MSMED Act, 2006 |
| (ii) | Importer (I) | |
| (iii) | Brand owner (BO) | |
| (iv) | Plastic waste processor | Recycling, waste to energy, waste to oil, industrial composting |
| (v) | Manufacturers and importers of plastic raw material | |
| (vi) | Manufacturers of compostable or biodegradable plastic items |
Source: G.S.R. 201(E), 14 March 2024, p. 30. Para 10.1 adds that producers, importers, brand owners, manufacturers and compostable/biodegradable manufacturers "shall have to register through the online centralized portal" (p. 31).
How the 2024 definitions widen the list
Since 2024 (G.S.R. 201(E), pp. 25-26):
- Producer also covers makers of intermediate material, such as films and preforms, and contract manufacturers that pack products for brand owners.
- Importer covers anyone importing for commercial use any of the following: plastic packaging, goods in plastic packaging, carry bags or sheets, plastic raw material (resin or pellets), or intermediate material.
Registration and EPR targets are not the same thing
Registering does not always mean carrying the full EPR target yourself:
- Micro and small producers must register. However, their EPR is fulfilled by the raw-material manufacturer or importer that supplied them, and they remain responsible for their own recycled-content target (para 7.8, p. 30).
- Micro and small brand owners are left out of the list of obligated entities in para 4(c). Para 6.1(a) also lists "Brand owner" without the micro-and-small wording it uses for producers (pp. 29-30).
Separate registrations with the State Pollution Control Board (Rule 13)
These are in addition to the portal registration:
- Manufacturers and importers of plastic raw material "shall make an application" to the State Pollution Control Board (SPCB) or Pollution Control Committee in Form III (Rule 13(4)).
- They may sell only to registered producers or sellers, and must show the buyer's registration number on the invoice (Rule 13(4A)).
- Sellers of plastic raw material or intermediate material to producers must also apply to the SPCB or Pollution Control Committee for registration (Rule 13(4B)).
- If registration has not been granted within 30 days of a complete application, the applicant is deemed registered (Rule 13(8)).
Source: G.S.R. 201(E), pp. 28-29.
Registration conditions (Schedule II paras 6.1(b)-6.6, from 2022)
- Who registers you: for producers, importers and brand owners operating in one or two states, and for processors, registration is done by the SPCB or Pollution Control Committee through the CPCB portal.
- New businesses: an entity that starts placing products on the market in a year takes on EPR targets from the next year.
- No business without registration, and no dealings with unregistered entities.
- One registration per role and per state: you need a separate registration for each sub-category you fall into and for each state where you have units. Several units in one state need only one registration for that sub-category.
- Documents: you must provide PAN, GST and CIN for the company, and the Aadhaar and PAN of the authorised representative.
- Penalty for false information: registration is revoked for one year, after a hearing, and you cannot re-register during that period.
Source: G.S.R. 133(E), 16 February 2022, p. 23.
I can go through the portal registration steps for a specific role, such as an importer.
Which targets apply to plastic packaging?
Four kinds of target apply to plastic packaging in India under Schedule II of the Plastic Waste Management Rules, 2016:
- a collection (EPR) target of 100% of your "eligible quantity" each year since 2023-24;
- a minimum share of that target that must be recycled, which rises each year;
- mandatory recycled content for Categories I to III;
- reuse targets for brand owners using Category I rigid packaging.
For the current financial year (2026-27), that means 100% collection, 70% or 50% recycling depending on category, 40%, 10% or 5% recycled content, and reuse of 15%, 75% or 10% depending on pack size and use.
Approach: The datasets I can search don't hold the Indian Rules themselves, only CPCB's EPR portal directory. So I read the official Gazette texts: G.S.R. 133(E) of February 2022, G.S.R. 201(E) of March 2024 and G.S.R. 237(E) of 31 March 2026.
1. Collection target
The target is a percentage of the eligible quantity, set separately for each category:
| Year | Target |
|---|---|
| 2021-22 | 25% |
| 2022-23 | 70% |
| 2023-24 onwards | 100% |
How the eligible quantity is worked out depends on your role:
- Producers (Q1) and importers (Q2): average packaging sold or imported over the last two financial years, plus average pre-consumer waste, minus the quantity supplied to brand owners.
- Brand owners (Q3): average virgin packaging bought and put on the market over the last two years, plus pre-consumer waste.
Source: G.S.R. 133(E), pp. 24-26.
2. Minimum share of the collection target that must be recycled
End-of-life disposal does not count towards these figures.
| Category | 2024-25 | 2025-26 | 2026-27 | 2027-28 onwards |
|---|---|---|---|---|
| I (rigid) | 50% | 60% | 70% | 80% |
| II (flexible) | 30% | 40% | 50% | 60% |
| III (multilayered) | 30% | 40% | 50% | 60% |
| IV (compostable) | 50% | 60% | 70% | 80% |
- For Category IV, "recycling" means industrial composting (G.S.R. 133(E), pp. 24-27).
- Only plastic that cannot be recycled may go to end-of-life uses such as road construction, waste-to-energy, waste-to-oil or co-processing (pp. 24-27).
- Since March 2026, turning plastic waste into feedstock chemicals or new plastic counts as recycling (G.S.R. 237(E), p. 10).
- Raw-material manufacturers and importers carry the collection target for packaging made by the micro and small producers they supply. They have the same recycling percentages for Categories I to III (G.S.R. 201(E), p. 30).
- Biodegradable plastics (Category V): manufacturers meet their EPR by obtaining certificates generated by local authorities, equal to the biodegradable plastic those authorities collect and biodegrade (G.S.R. 201(E), p. 31). I found no recycling-percentage table for Category V in the texts I read.
3. Mandatory recycled content
These percentages were restated in 2026 and apply to producers, importers and brand owners alike:
| Category | 2025-26 | 2026-27 | 2027-28 | 2028-29 onwards |
|---|---|---|---|---|
| I | 30% | 40% | 50% | 60% |
| II | 10% | 10% | 20% | 20% |
| III | 5% | 5% | 10% | 10% |
Conditions (G.S.R. 237(E), pp. 12-16):
- Exemption where recycled content is not allowed. The targets "shall not be applicable" where a law, rule or mandatory Indian Standard does not permit recycled content, including rules from FSSAI, CDSCO or the Central Insecticide Board. To claim this, you "shall submit" the provision in your annual return. Under the 2022 text, CPCB granted exemptions case by case and you had to buy certificates instead (G.S.R. 133(E), pp. 25, 28).
- Category III: the target applies only to the weight of the plastic layers.
- Food-contact carry-forward: a 2025-26 shortfall on food-contact packaging may be carried forward for up to three years from 2026-27, with at least one-third made up each year.
- Importers: recycled plastic already in imported material does not count. Importers must buy certificates from entities that exceeded their own obligation.
- Micro and small producers must meet their own recycled-content target, even though their collection target is passed to their raw-material supplier (G.S.R. 201(E), p. 30).
4. Reuse targets for brand owners using Category I rigid packaging
Each target is a percentage of the Category I rigid packaging in products sold that year:
| Pack size and use | 2025-26 | 2026-27 | 2027-28 | 2028-29 onwards |
|---|---|---|---|---|
| A: 0.9 L/kg or more but under 4.9 L/kg | 10% | 15% | 20% | 25% |
| B: 4.9 L/kg or more, drinking water | 70% | 75% | 80% | 85% |
| C: 4.9 L/kg or more, other products | 10% | 10% | 15% | 15% |
Source: G.S.R. 237(E), p. 14.
- 2026 change: before 2026, the 70-85% figures applied to all rigid packs of 4.9 L/kg or more (G.S.R. 133(E), p. 27). The 2026 amendment limited those figures to drinking water and set lower figures for other products.
- Exemption: the reuse targets do not apply where regulation prohibits reuse. To claim this, the brand owner must cite the provision in its annual return.
- Carry-forward: a 2025-26 shortfall may be carried forward on the same one-third-per-year basis.
- Reporting: brand owners report total sales, virgin content and recycled content of their rigid packaging (G.S.R. 237(E), pp. 14-15).
- No reuse target below 0.9 L/kg: the table sets no target for rigid packs under 0.9 L/kg.
Points that apply to all targets
- Review: the reuse, recycling and recycled-content obligations "shall be reviewed every five years" (G.S.R. 133(E), para 7.6, p. 28).
- Surplus certificates: surplus can only be used within the same category. Within that category, a reuse surplus can count against reuse, recycling or end-of-life targets, and a recycling surplus against recycling or end-of-life. An end-of-life surplus cannot count against reuse or recycling (para 8.2, p. 28).
- Biodegradable packaging exemption removed: the 2022 exemption from EPR targets for packaging certified 100% biodegradable (former para 7.8) was deleted in 2024 (G.S.R. 201(E), p. 30).
I can work through the eligible-quantity and target calculation for one role and category if you share your volumes.