EPR For Plastic

The full form of EPR is Extended Producer Responsibility. It is a cornerstone environmental policy under India’s Plastic Waste Management (PWM) Rules, 2016, and the subsequent 2022 amendments. At its core, EPR for plastic shifts the financial and physical burden of collecting, managing, and recycling plastic packaging waste from municipal authorities to the businesses that introduce the plastic into the environment. This policy is driven by the urgent need to combat plastic pollution and promote a circular economy. When you achieve plastic EPR compliance, you are ensuring that a specific percentage of the material you sell is recovered and processed responsibly. The authority responsible for enforcing this framework is the CPCB (Central Pollution Control Board), making CPCB EPR plastic compliance the primary regulatory challenge for all obligated entities. Ignoring the mandate for epr plastic waste management can lead to significant environmental compensation penalties.

Key Objectives of EPR Plastic Guidelines

• Promoting Circularity: Encouraging the reuse of rigid plastic packaging and the use of recycled content.
• Targeted Collection: Establishing mandatory, year-on-year escalating targets for the collection and recycling of plastic epr packaging waste.
• Standardization: Mandating registration and reporting through a centralized CPCB EPR plastic portal.
• Reducing Environmental Leakage: Ensuring that all epr plastic waste is channeled through formal waste processing facilities.

The law on EPR for plastic clearly defines the entities responsible for compliance, collectively known as PIBOs:

Entity	Definition & Responsibility	Compliance Requirement
Producer	Manufactures plastic packaging (e.g., plastic sheets, films, carry bags).	Responsible for the epr plastic packaging generated by their manufacturing process.
Importer	Imports plastic packaging or products packaged in plastic into India.	Responsible for the imported quantity of plastic epr packaging.
Brand Owner	Sells products under a registered brand name/trademark and uses plastic packaging for selling/marketing.	Responsible for all packaging used for their products, regardless of where it was manufactured.
Plastic Waste Processor (PWP)	Entities engaged in recycling, co-processing, waste-to-energy, or waste-to-oil.	Must also register on the CPCB EPR plastic portal for verification, but are not PIBOs.

Exemptions for Brand Owners

A critical detail in the CPCB EPR plastic framework is the exemption for micro and small Brand Owners. However, all Producers and Importers are covered, irrespective of size. Instacertify can help you determine if your business falls under the micro or small category based on the MSME Development Act, 2006, saving you unnecessary compliance effort if you qualify for exemption.

The complexity of EPR plastic waste compliance stems from the categorization of plastic packaging. Your mandatory targets and compliance methods depend entirely on which of the four categories your packaging falls into.

Category I: Rigid Plastic Packaging

These are hard, self-supporting plastic containers. They are generally the easiest to recycle.

• Examples: PET bottles for soft drinks, jars for food and cosmetics, and tubs for dairy products.
• Unique Obligation: PIBOs dealing in Category I packaging have an additional mandatory obligation to reuse a specified percentage of the packaging (e.g., water bottles, containers) starting from 2025-26.

Category II: Flexible Plastic Packaging

This category covers single-layer or multi-layered flexible plastic packaging (other than those specified in Category III).

• Examples: Plastic sheets, wrapping material, pouches (single-layer), and carry bags (where the thickness requirement is met).

Category III: Multi-Layered Plastic Packaging (MLP)

This refers to packaging where plastic is combined with layers of non-plastic materials (like aluminum or paper) which makes it difficult to recycle.

• Examples: Chips packets, laminated tubes, and sachets for shampoo or coffee.
• Unique Obligation: Due to its poor recyclability, the use of Category III packaging is highly regulated, and the recycling targets are mandatory.

Category IV: Compostable Plastics

This includes plastic sheets or carry bags made from compostable plastic (must conform to IS/ISO 17088 standards).

• Examples: Bags used for wet waste, specialized shopping bags.
• Note: These products still fall under the epr plastic framework and require registration and compliance to verify their compostability.

Instacertify provides precise classification services for your entire product portfolio, ensuring accurate target setting for your EPR for plastic liability.

The CPCB EPR plastic guidelines mandate that PIBOs fulfill three distinct obligations. Failure to achieve these targets is considered non-compliance, attracting environmental penalties.

A. Mandatory EPR Target (Collection & Recycling)

This is the central requirement of plastic epr. PIBOs must ensure the collection and recycling/end-of-life disposal of a percentage of the plastic they introduce into the market. The targets are calculated based on the weight of plastic placed on the market (PoM) in a given financial year and are set to increase progressively:

Financial Year	Target Percentage (Based on PoM)
2024-25	70% (for Category I, II, III)
2025-26	80% (for Category I, II, III)
2026-27 onwards	100% (for Category I, II, III)

Note: PIBOs must also cover 30% of the PoM for the preceding two years until 2023-24 (known as historical waste).

B. Mandatory Reuse of Rigid Plastic Packaging (Category I)

To promote true circularity, the guidelines mandate a minimum level of reuse for rigid plastic packaging (Category I):

Financial Year	Minimum Reuse % of Category I (by weight)
2025-26	10%
2026-27	20%
2027-28 onwards	30%

C. Mandatory Use of Recycled Plastic Content

PIBOs must also incorporate a minimum percentage of recycled plastic content into their new products/packaging. This applies specifically to Category I, II, and III plastic packaging.

Financial Year	Minimum Recycled Content % (by weight)
2025-26	30% (Cat I), 10% (Cat II), 5% (Cat III)
2026-27	40% (Cat I), 20% (Cat II), 10% (Cat III)
2027-28	50% (Cat I), 30% (Cat II), 15% (Cat III)

The complexity of tracking three separate, escalating obligations for multiple categories is why expert guidance on epr plastic waste is indispensable.

The CPCB requires comprehensive documentation to verify your status as a PIBO dealing with epr plastic waste. While the specific list can vary, the core requirements include:

• PAN Card and CIN (Corporate Identification Number) of the Company.
• GST Certificate for all operational sites.
• MSME/Udyam Registration Certificate (if claiming exemption for small Brand Owner status).
• Details of the Authorized Signatory (PAN, Aadhar).
• Consent to Operate (CTO) or Consent to Establish (CTE) from the SPCB/PCC (for Producers).
• Import-Export Code (IEC) (for Importers).
• Quantity (in Metric Tonnes) of plastic epr packaging manufactured/imported/used in the previous two financial years.
• Documentary proof of sales.

Achieving and maintaining compliance for EPR for plastic involves a structured process that Instacertify manages from start to finish.

Step 1: Preliminary Analysis & Classification

We begin by analyzing your business type (P/I/BO) and your product portfolio to determine the total weight of plastic placed on the market (PoM) and classify it into the four mandatory plastic epr categories.

Step 2: CPCB Portal Registration & Documentation

We prepare all necessary documentation and initiate the online registration process on the centralized CPCB EPR plastic portal. This involves submitting applications for all your production/import units.

Step 3: EPR Action Plan Development & Submission

A key requirement is the submission of a detailed action plan. We draft a robust, auditable plan outlining how you will meet your mandatory targets for collection, recycling, reuse, and recycled content over the defined period.

Step 4: CPCB Scrutiny & Approval

We liaise with the CPCB and State Pollution Control Boards (SPCBs) to address any queries or deficiencies in your application, ensuring swift approval of your epr plastic registration.

Step 5: Fulfillment Strategy & EPR Certificate Procurement

Once the registration is granted, we advise on the annual fulfillment strategy. This involves:

• Identifying the quantity of EPRCs needed across specific categories.
• Sourcing and purchasing certificates from registered and verified PWPs (Plastic Waste Processors) via the electronic platform.

Step 6: Quarterly & Annual Reporting

We prepare and submit the mandatory quarterly and annual returns on your behalf, providing data on the quantity of plastic placed on the market, the targets fulfilled, and the details of the EPRCs procured/surrendered.

Step 7: Ongoing Compliance & Renewal

We monitor changes in the EPR for plastic regulations and ensure timely renewal of your registration, providing a continuous, penalty-free compliance cycle.

The timeline is heavily dependent on the preparedness of the documents and the workload of the CPCB/SPCBs, but generally follows this schedule:

Stage	Activity	Estimated Timeframe
Initial Phase	Document Preparation & Data Collation	7 – 14 Days
Registration	Online Submission & Fee Payment	1 Day
Approval Phase	CPCB Scrutiny, Query Resolution, & Final Grant	30 – 60 Days (Varies based on CPCB efficiency)
Post-Approval	EPR Certificate Procurement & Reporting	Ongoing (Annual Cycle)

Note: Instacertify actively tracks your application and addresses all CPCB queries instantly, aiming to secure your plastic epr registration in the minimum possible time.

The total cost for meeting your epr plastic waste liability is broken down into two main components:

Cost Component	Description	Typical Range/Applicability
Statutory Fees (to CPCB)	Mandatory, one-time application fee for registration.	Varies based on the quantity of plastic handled (TPA) and the type of business (PIBO/PWP). Generally low compared to other costs.
Professional Fees (Instacertify)	Consultancy charges for documentation, submission, action plan drafting, follow-up, and annual reporting.	Highly variable. Depends on the size of the PIBO (Micro, Small, Medium, Large) and the complexity (number of categories, number of units).
Fulfillment Cost (EPRCs)	The largest financial component—the cost of purchasing EPR Certificates to meet your mandatory targets.	Varies widely based on EPR plastic category, market demand, and the prevailing price per kg/MT of the certificate. This is the true cost of EPR for plastic compliance.

Important: The cost of EPR Certificates is a market-driven expense and is typically the most significant investment for epr for plastic compliance. Instacertify assists in identifying the most competitive and legitimate sourcing for these certificates, providing cost-optimization advice.