If your business sells, imports or makes anything in plastic packaging, you may have an obligation under the extended producer responsibility rules for plastic packaging, even if you have never heard of them. The Plastic Waste Management Rules, 2016 and the EPR guidelines added in 2022 require producers, importers and brand owners, known as PIBOs, to register on the Central Pollution Control Board's portal and meet yearly obligations for the packaging they place on the market. The rules were tightened in March 2026.
This guide explains, in plain words, who counts as a producer, importer or brand owner, how to tell which roles apply to your business, how e-commerce and small businesses are treated, and what happens if you do not register. For registration, targets and certificates, see plastic EPR registration.
हिंदी में सारांश
अगर आपका व्यवसाय प्लास्टिक पैकेजिंग में कुछ बेचता, आयात करता या बनाता है, तो प्लास्टिक कचरा प्रबंधन नियम, 2016 और 2022 के EPR दिशानिर्देशों के तहत आपकी ज़िम्मेदारी हो सकती है। प्रोड्यूसर (पैकेजिंग बनाने वाले), इम्पोर्टर (पैकेजिंग या पैक्ड सामान आयात करने वाले) और ब्रांड ओनर (अपने ब्रांड से प्लास्टिक पैक्ड सामान बेचने वाले) को CPCB पोर्टल पर रजिस्ट्रेशन कराना होता है। कई व्यवसायों की एक से ज़्यादा भूमिकाएँ होती हैं। मार्च 2026 में नियम और सख्त हुए।
The roles at a glance
Producer
Makes plastic packaging or intermediate material, including for others.
Importer
Imports plastic packaging, packed goods, or plastic sheets and films for packaging.
Brand owner
Sells goods under its brand in plastic packaging, including online.
More than one role
A business can be a brand owner and an importer at the same time.
Processor
Recyclers and other processors register to generate certificates.
Not registered?
Notices, directions to stop and environmental compensation.
Producers
A producer, for these rules, is a person engaged in manufacturing plastic packaging, or in manufacturing intermediate material such as films or laminates used to make packaging, including contract manufacturing of packaging for a brand. Film makers, laminators, bottle and container makers, and converters who print and form packaging are typically producers. A company that makes its own packaging in-house for its products may be both a producer and a brand owner. Producers register and report the packaging they supply to the market, distinguishing what goes to registered brand owners from what goes to unregistered entities.
Importers
An importer is a person who imports plastic packaging, products in plastic packaging, or plastic sheets and similar material for packaging. This catches many businesses: an electronics importer whose products arrive in plastic wrap, a food importer bringing goods in plastic bags, a retailer importing packaged consumer goods. Under the 2026 amendment, recycled content in imported packaging does not count towards the importer's recycled content obligation, which makes the import role more costly to comply with. Importers should register before placing goods on the market and report imported packaging by category.
Brand owners
A brand owner is a person who sells a commodity under a registered brand label or trademark in plastic packaging, whether in shops or online. FMCG companies, food and beverage brands, personal care brands, pharmaceutical companies, and direct-to-consumer brands selling through marketplaces are typical brand owners. The obligation follows the packaging around your product, whether you made it or bought it. Even if your packaging supplier is registered as a producer, you have your own obligation as a brand owner.
How to work out your roles
List your packaging
Every plastic item that reaches the market with your goods.
Trace its source
Made in-house, bought locally or imported.
Identify your roles
Producer, importer, brand owner, or more than one.
Check the categories
Rigid, flexible, multilayered or compostable.
Register each role
On the CPCB portal before placing packaging on the market.
Plan compliance
Certificates, returns and the 2026 recycled content targets.
Common businesses and their usual roles
| Business | Usual roles |
|---|---|
| FMCG brand buying printed laminates | Brand owner |
| Brand importing ingredients in plastic bags | Brand owner and importer |
| Film or laminate manufacturer | Producer |
| Electronics importer | Importer, often also brand owner |
| D2C brand on marketplaces | Brand owner |
| Retail chain with private labels | Brand owner, often importer |
| Contract packer for brands | Producer |
E-commerce and small businesses
E-commerce entities that use plastic packaging for shipping, and sellers on marketplaces who sell under their own brands, have obligations under the rules. Marketplaces may ask sellers for EPR registration details. Small businesses often assume they are too small to matter. The rules and guidelines have provided some relief for micro and small enterprises in certain respects, but many small brand owners and importers remain obligated. Check the current rules for any thresholds or simplified procedures before assuming you are exempt.
The CPCB has issued notices to unregistered businesses identified through marketplace data, customs records and complaints. Registering voluntarily, and buying certificates for past obligations where required, is usually far less costly than waiting for a notice. See CPCB EPR matters.
A D2C brand that discovered its obligation
Here's a made-up example. A Delhi skincare brand selling online assumed its contract manufacturer handled plastic EPR. A marketplace asked for its EPR registration.
We explained that as a brand owner it had its own obligation, and that it was also an importer because some of its bottles were imported. It registered in both roles, bought certificates, and updated its supplier contracts to share data on packaging weights.
Packaging categories
Once you know your roles, the next step is to sort your packaging into the four categories used by the EPR guidelines. Category I is rigid plastic packaging, such as bottles, jars, tubs, crates and caps. Category II is flexible packaging of a single layer or multiple layers of different types of plastic, such as pouches, wraps, carry bags and films. Category III is multilayered packaging with at least one layer of plastic and at least one layer of non-plastic material, such as laminates with aluminium foil or paper. Category IV covers plastic sheets and similar material used for packaging, as well as carry bags made of compostable plastics.
The category matters because targets for recycling, recycled content and reuse differ between categories, and the 2026 amendment raised recycled content targets in steps: Category I from 30 per cent in 2025-26 to 60 per cent in 2028-29, Category II from 10 to 20 per cent, and Category III from 5 to 10 per cent. A brand that misclassifies a multilayer pouch as rigid packaging, or the reverse, will calculate the wrong obligation. When in doubt, ask your packaging supplier for the material specification of each layer.
What happens if you do not register
Placing plastic packaging on the market without registration is a violation that the CPCB can act against. The usual sequence is a notice asking the business to register and explain, followed by directions and environmental compensation calculated on the packaging quantities placed on the market without meeting obligations. Marketplaces increasingly require EPR registration numbers before listing products, so an unregistered brand may also lose sales channels. Banks, investors and large buyers conducting due diligence often ask for EPR registration and returns.
For a business that discovers it should have registered earlier, the best course is usually to register at once, estimate the packaging placed on the market in earlier years, and take advice on how to deal with past obligations. A voluntary, documented approach is treated more favourably than a registration made only after a notice. See environmental compensation demand.
Information you need before registering
| Information | Where it usually comes from |
|---|---|
| Packaging items and weights | Packaging suppliers' specifications, internal BOMs |
| Categories of each item | Material specification of each layer |
| Quantities placed on the market | Sales data multiplied by packaging weight per unit |
| Imported packaging and packed goods | Import records and supplier documents |
| Brand names and trademarks | Trademark registrations and product lists |
| Company documents | Incorporation, GST, PAN, CIN and authorised signatory |
Before you file
- Have you identified every role: producer, importer, brand owner?
- Have you included packaging on imported goods?
- Have you counted secondary and tertiary packaging, such as shrink wrap and cartons with plastic?
- Have you classified each item into the right category?
- Do your suppliers' quantities match yours, so nothing is double counted?
- Do you know who in your company will file returns each year?
Frequently Asked Questions
Who needs plastic EPR registration?
Producers, importers and brand owners of plastic packaging, and plastic waste processors.
What is a PIBO?
A producer, importer or brand owner under the rules.
Is my packaging supplier's registration enough?
No, brand owners have their own obligation.
Do importers of packed goods need to register?
Yes, as importers.
Do e-commerce sellers need registration?
Brand owners selling online do, and e-commerce entities using plastic packaging have obligations.
Are small businesses exempt?
Not generally; check the current rules for any relief.
Can I have more than one role?
Yes, and each must be registered.
What changed in 2026?
Higher recycled content targets, auditors, and importers' recycled content not counting.
What if I never registered?
Register now; you may need to cover past obligations.
Where do I register?
On the CPCB centralised EPR portal for plastic packaging.
Not Sure If You Need Plastic EPR?
Tell us about your products and packaging. We will identify your roles.
This page gives general information about environmental law as it stood when it was last reviewed. It is not legal advice on your case and does not promise any result. Environmental rules, EPR targets, GRAP measures and board procedures change often, so check the current position for your unit or project before acting.
Have a question about your own case?
A guide can only go so far. Send us the notice, the order or a few photos, and we'll tell you where you stand, which authority or NGT bench deals with it and when the next step is due, in plain words.
