If your business places plastic packaging on the Indian market, whether you make it, import it or sell products packed in it under your brand, you probably have obligations under the Plastic Waste Management Rules, 2016. The rules, and the EPR guidelines added to them in 2022, require producers, importers and brand owners, known together as PIBOs, to register on the Central Pollution Control Board's centralised portal, report the plastic packaging they introduce each year, and meet targets for collection, recycling, reuse and use of recycled plastic. They do this mainly by buying EPR certificates generated by registered plastic waste processors.
The rules were tightened again by the Plastic Waste Management (Amendment) Rules, 2026, notified on 31 March 2026. They set rising targets for recycled content in packaging, require registered environment auditors to verify compliance, allow certain shortfalls to be carried forward for a limited period, and make clear that recycled content brought in by importers does not count towards the targets. This page explains who must register, how the obligation is calculated, how certificates work, the 2026 changes, and what to do if you receive a notice for non-compliance.
हिंदी में सारांश
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Is this your situation?
- You manufacture plastic packaging material or films
- You import goods in plastic packaging or import packaging material
- You sell products under your brand in plastic packaging, online or offline
- You run an e-commerce business that ships in plastic
- You received a CPCB notice for non-registration or unmet targets
- You are unsure which category your packaging falls in
- You are a plastic recycler or processor seeking registration
Plastic EPR at a glance
Who is a PIBO
Producers of plastic packaging, importers of packaging or packed goods, and brand owners who sell goods in plastic packaging.
Four categories
Rigid packaging (Category I), flexible packaging (II), multilayered packaging with a non-plastic layer (III), and compostable plastic (IV).
Registration
On the CPCB centralised EPR portal, with details of packaging quantities and categories.
Targets
Collection and recycling obligations, plus recycled content and reuse targets that rise year by year.
EPR certificates
Generated by registered plastic waste processors and transferred to PIBOs to meet targets.
Annual return
Filed on the portal, with the 2026 rules requiring verification by registered environment auditors.
Who counts as a producer, importer or brand owner
The definitions are broad. A producer, in this context, is someone who manufactures plastic packaging or makes intermediate material used to make packaging, and also someone who contract manufactures packaging for a brand. An importer is anyone who imports plastic packaging, products in plastic packaging, or plastic sheets and films used for packaging. A brand owner is anyone who sells a product under a registered brand label or trademark in plastic packaging, including through online platforms.
Many businesses fall into more than one role. A food company that buys printed laminates from a converter, imports some ingredients in plastic bags, and sells its products under its brand is a brand owner and an importer. Each role must be registered and reported correctly, and the same packaging should not be counted twice by the producer and the brand owner. Getting the role right at the start avoids most later disputes about the obligation.
The 2026 amendment
The Plastic Waste Management (Amendment) Rules, 2026 (GSR 237(E), dated 31 March 2026) made several practical changes. Mandatory recycled content in packaging now rises in steps: for rigid Category I packaging from 30 per cent in 2025-26 to 60 per cent in 2028-29; for flexible Category II packaging from 10 to 20 per cent; and for multilayered Category III packaging from 5 to 10 per cent, subject to food-contact rules. Reuse targets apply to certain rigid packaging. A shortfall in some obligations may be carried forward for up to three years, but not indefinitely.
The amendment also says that recycled content in imported packaging does not count towards an importer's recycled content obligation, which has caught some importers off guard. It introduces registered environment auditors to verify the accuracy of PIBO and processor reporting, and recognises energy recovery as one of the end-of-life routes for certain plastic waste, within limits. PIBOs should revisit their compliance plans in the light of these changes.
How to register and comply
Map your packaging
List all plastic packaging you introduce, by category, weight and source: domestic, imported or self-made.
Identify your roles
Decide whether you are a producer, importer, brand owner or more than one, and register each role.
Register on the CPCB portal
Submit company details, GST and CIN, packaging data and the action plan. Pay the fee.
Calculate the obligation
Use the quantities and the targets for each category and year.
Buy EPR certificates
Arrange certificates from registered plastic waste processors, through contracts and the portal.
File the annual return
Report quantities and certificates by the due date, with auditor verification under the 2026 rules.
EPR certificates and fake certificate risk
EPR certificates are generated on the portal when a registered processor recycles or otherwise processes plastic waste. PIBOs buy these certificates to meet their obligations. Because certificates have value, there have been cases of certificates generated without actual processing, and the CPCB has suspended processors and cancelled certificates after audits. If a certificate you relied on is cancelled, your obligation is treated as unmet.
Protect yourself by dealing only with processors whose registration and capacity are verified, by asking for evidence of actual processing, by avoiding prices far below the market, and by including warranties and indemnities in your contracts. Under the 2026 rules, auditor verification is expected to reduce this problem, but due diligence remains your responsibility.
Time and typical cost
Our fees are agreed in writing at the start, stage by stage. They are not linked to the outcome.
| Stage | Usual time | What it involves |
|---|---|---|
| Packaging mapping | 1 to 3 weeks | Internal data; our fee |
| Portal registration | 2 to 6 weeks after a complete application | CPCB fee by category and turnover |
| EPR certificate purchase | Through the year | Market price per tonne of certificates |
| Annual return and audit | By the notified due date | Auditor's fee under the 2026 rules |
| Reply to a notice | Within the time stated, usually 15 to 30 days | Our fee |
What can go wrong and the usual consequence
| Issue | Usual consequence |
|---|---|
| Selling without registration | Notice, directions to stop placing packaging on the market, compensation |
| Under-reporting quantities | Recalculation of obligation and compensation |
| Unmet targets | Environmental compensation per tonne of shortfall |
| Relying on cancelled certificates | Obligation treated as unmet |
| Late or missing annual return | Notice and possible suspension of registration |
Documents usually needed
Company
- Certificate of incorporation, GST, PAN and CIN
- Authorised person's details
Packaging data
- Category-wise quantities of packaging introduced
- Purchase and import records
- Brand and product list
Compliance
- Contracts with processors
- EPR certificate records
- Previous annual returns and auditor reports
Laws that apply
Obligations of producers, importers and brand owners.
Registration, categories, targets, certificates and environmental compensation.
Recycled content, reuse targets, carry forward, auditors and end-of-life routes.
The parent law under which the rules are made.
How we work
We are a litigation and advisory practice led by Advocate BK Singh, with offices in Dwarka (New Delhi) and Vaishali (Ghaziabad). This is what you can expect:
- Roles and categories mapped: before you register.
- Obligation calculated: with the 2026 targets.
- Processor contracts reviewed: to reduce certificate risk.
- Notices answered: with data, not just denial.
- Written fee terms: agreed stage by stage, never linked to the outcome.
Mistakes we see with plastic EPR
- Registering as a brand owner but forgetting importer obligations
- Misclassifying flexible packaging as rigid or vice versa
- Buying the cheapest certificates without checking the processor
- Assuming imported recycled content counts
- Missing the annual return because data is held by different departments
A snack brand with imports
Here's a made-up example. A Noida snack company registered as a brand owner and bought certificates for its multilayered pouches. It did not register as an importer, although it imported nuts in plastic bags and some packaging film.
A CPCB notice asked why it had not reported imported packaging. We mapped all packaging, registered the importer role, recalculated the obligation and arranged additional certificates. The company replied with the corrected data and an explanation, and the matter was closed with the corrected return accepted.
Cancelled certificates
Here's a second made-up example. A personal care brand learnt that certificates it had bought from a processor were cancelled after a CPCB audit found the processor had not processed the waste.
We reviewed the contract, which had a warranty and indemnity. The brand bought replacement certificates from a verified processor before the return deadline, and sent a legal notice to the original processor to recover the price. Its own compliance was restored.
Single-use plastic ban and carry bag rules
EPR is not the only plastic obligation. Since 1 July 2022, identified single-use plastic items have been banned across India, including plastic earbuds, balloon sticks, candy and ice-cream sticks, plastic flags, cutlery such as forks, spoons and knives, straws, stirrers, thin wrapping films for sweet boxes and cigarette packets, and plastic or PVC banners below a specified thickness. Plastic carry bags must be at least 120 microns thick since 31 December 2022. These bans apply to manufacture, import, stocking, distribution, sale and use.
State governments and local bodies enforce the bans through raids and fines, and some states have wider bans of their own. A business that is fully compliant with EPR can still face action for selling banned items. If you make, import or sell plastic items, check them against the central list and the state's list as well.
How compensation is calculated
When a PIBO does not meet its targets, the CPCB levies environmental compensation, calculated on the shortfall in tonnes at rates set in the EPR guidelines, which differ by category of packaging. The payment of compensation does not wipe out the obligation; the unmet target generally continues, and the guidelines provide for return of part of the compensation if the shortfall is later made good within the allowed period. Under the 2026 amendment, some shortfalls may be carried forward for up to three years.
A compensation notice should be read closely. Common errors include wrong quantities taken from incomplete returns, certificates not credited because of portal problems, double counting between a producer and its brand owner customer, and categories misassigned. A reply with reconciled data and portal screenshots often reduces the demand. Where the CPCB does not correct a clear error, legal remedies are available. See environmental compensation demand.
Plastic waste processors
Recyclers, waste-to-energy plants, cement kilns using plastic waste as fuel, and other processors must also register on the CPCB portal to generate EPR certificates. Their certificates depend on verified processing capacity and records of the plastic waste actually received and processed. Processors face audits and suspension if their claimed output exceeds what their plant can handle, or if records do not match. The 2026 introduction of registered environment auditors applies to them too. If you run or plan a processing business, build traceable records from collection to output, because your certificates, and your customers' compliance, depend on them.
Frequently Asked Questions
Who needs plastic EPR registration?
Producers, importers and brand owners of plastic packaging, and plastic waste processors.
Do small brand owners need to register?
Most do; check the current rules for any relief for micro and small enterprises.
What are the four categories?
Rigid, flexible, multilayered with a non-plastic layer, and compostable plastic packaging.
What is an EPR certificate?
A certificate generated by a registered processor for plastic waste processed, used by PIBOs to meet targets.
What changed in 2026?
Higher recycled content targets, reuse targets, carry forward of shortfalls, auditors, and exclusion of importers' recycled content.
What happens if I miss my targets?
Environmental compensation is levied on the shortfall, and the obligation may continue.
Can I carry forward a shortfall?
Under the 2026 rules, certain shortfalls may be carried forward for up to three years.
Does recycled content in imported packaging count?
No, under the 2026 amendment it does not count towards the importer's obligation.
Is e-commerce packaging covered?
Yes, brand owners and e-commerce entities using plastic packaging have obligations.
When is the annual return due?
By the date notified on the CPCB portal; check each year.
What if a certificate I bought is cancelled?
The obligation is treated as unmet; buy replacements and pursue the seller.
Can a CPCB EPR order be challenged?
Yes, through representation and, where appropriate, legal proceedings.
Plastic EPR to Sort Out?
Send us your packaging data and any notice. We will map your obligation and the next steps.
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.
Need help with Plastic Packaging EPR Registration and Targets?
Send us the notice, the order or a few photos. 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.
