Plastic EPR (Extended Producer Responsibility) is a mandatory compliance framework introduced under the Plastic Waste Management (PWM) Rules, 2016 and amended through Schedule II of the EPR Guidelines.
Under these rules, Producers, Importers, Brand Owners (PIBOs), and Plastic Waste Processors (PWPs) must register on the CPCB Plastic EPR Portal and fulfil annual recycling, waste processing, recycled-content, and reuse obligations.
The framework applies to all plastic packaging introduced in the Indian market, including rigid plastics, flexible packaging, multilayer packaging, and compostable plast
Manufacturers of plastic packaging materials.
Importers of plastic packaging, raw material, resin, or packaged products.
Businesses selling products in plastic packaging under their own brand.
Recyclers, Waste-to-Energy operators, composters, and plastic processors.
Manufacturers of biodegradable and compostable plastic products.
Under Schedule II of PWM Rules, plastic packaging is grouped into 4 categories — each with its own EPR target trajectory, recycling obligations, and recycled-content requirements.
| Category | Description | Typical Examples | Recycling Target (by FY 2027-28) |
|---|---|---|---|
| Category I — Rigid | Rigid plastic packaging | PET bottles, HDPE containers, jars, trays, PET preforms | 80% |
| Category II — Flexible | Flexible plastic packaging, single/multi-layer of same plastic, carry bags, sheets, pouches | LDPE/HDPE carry bags, PE film, plastic sachets, wrappers, pouches | 60% |
| Category III — Multilayer | Multilayer packaging with at least one plastic layer + one non-plastic layer | Chips packets, tetrapak-style cartons, metallised film, laminated pouches | 60% |
| Category IV — Compostable | Plastic sheets / carry bags made of compostable or biodegradable plastics | PLA bags, starch-based cutlery, compostable food packaging | 80% |
Note: Category IV products must obtain a compostability certificate from CPCB before being marketed, as their recycling target is met through industrial composting rather than mechanical recycling. For Category III, targets apply only to the plastic component of the multilayer packaging.
Our experts handle every step — from PIBO/PWP classification to ongoing annual returns and EPR certificate procurement — so you stay compliant without the overhead.
We identify your PIBO/PWP category and applicable packaging obligations.
Creation of SSO account and Plastic EPR portal onboarding.
Preparation and verification of all required documents and declarations.
Submission of complete online application with category-wise details.
Resolution of portal objections and deficiency notices.
Issuance of Plastic EPR Registration Certificate.
Support in sourcing valid EPR certificates from registered recyclers.
Form IV filing and yearly compliance management.
Accurate documents aligned with the CPCB’s mandated format are the key to avoiding deficiency notices and delays. Our team provides a role-specific checklist upfront.
Virtually every consumer goods business is a PIBO. If your product is shipped, sold, or distributed in India inside any form of plastic packaging — single-use bottle, wrapper, tetrapak, compostable bag — you must register. Here are the sectors we serve.
Targets are category-specific, escalate every financial year, and apply cumulatively. PIBOs fulfil targets by procuring EPR Certificates from CPCB-registered PWPs (1 certificate = 1 tonne processed)
| Plastic Category | FY 2024-25 | FY 2025-26 | FY 2026-27 | FY 2027-28 onwards |
|---|---|---|---|---|
| Category I — Rigid | 50% | 60% | 70% | 80% |
| Category II — Flexible | 30% | 40% | 50% | 60% |
| Category III — Multilayer | 30% | 40% | 50% | 60% |
| Category IV — Compostable | 50% | 60% | 70% | 80% |
| Plastic Category | FY 2025-26 | FY 2026-27 | FY 2027-28 | FY 2028-29 onwards |
|---|---|---|---|---|
| Category I — Rigid | 30% | 40% | 50% | 60% |
| Category II — Flexible | 10% | 10% | 20% | 20% |
| Category III — Multilayer | 5% | 5% | 10% | 10% |
| Category IV — Compostable | Not applicable — focus is on biodegradation & industrial composting | Not applicable — focus is on biodegradation & industrial composting | Not applicable — focus is on biodegradation & industrial composting | Not applicable — focus is on biodegradation & industrial composting |
| Container Volume | FY 2025-26 | FY 2028-29 onwards |
|---|---|---|
| Small rigid packaging (0.9 – 4.9 L/kg) | 10% | 25% |
| Drinking water packaging (≥ 4.9 L/kg) | 70% | 85% |
| Large non-water rigid (≥ 4.9 L/kg) | 10% | 25% |
How PIBOs meet targets: (1) Collect & recycle via tie-ups with registered PWPs; (2) Purchase EPR Certificates on the CPCB portal (surplus trading allowed); (3) Use recycled content sourced from authorised recyclers. The 2026 Amendment allows carry-forward of target shortfalls for up to 3 years, provided at least one-third of the shortfall is cleared each year.
Under CPCB’s April 2024 Environmental Compensation (EC) Guidelines, non-compliance with Plastic EPR obligations attracts financial penalties based on the “polluter pays” principle. Payment of EC does not eliminate the pending obligation — the unmet EPR target continues and must still be fulfilled in subsequent compliance years.
| Form | Purpose | Filed By | Frequency |
|---|---|---|---|
| Form I | Application for PIBO registration on CPCB/SPCB portal | Producer / Importer / Brand Owner | One-time (with updates) |
| Form II | Registration Certificate issued by CPCB/SPCB | Authority issues | On approval |
| Form III | Application for Plastic Waste Processor registration | Recycler / WTE / WTO / Composter | One-time (with updates) |
| Form IV | Annual Return on plastic packaging & EPR compliance | PIBO & PWP | Annual — due 30 June |
| EPR Action Plan | Strategy to meet collection, recycling, recycled content, reuse targets | PIBO | With registration + updates |
| EPR Certificate | Certificate of 1 tonne of plastic processed by PWP | CPCB generates via PWP | Per transaction |
Criminal Liability: Under Section 15 of the Environment (Protection) Act, 1986, failure to comply with Plastic EPR regulations may lead to imprisonment of up to 5 years, a fine of up to ₹1 lakh, or both. Continued non-compliance can attract an additional penalty of ₹5,000 per day. In certain cases, directors, partners, and authorised signatories may also be held personally liable.
| Form | Purpose | Filed By | Frequency |
|---|---|---|---|
| Form I | Application for PIBO registration on CPCB/SPCB portal | Producer / Importer / Brand Owner | One-time (with updates) |
| Form II | Registration Certificate issued by CPCB/SPCB | Authority issues | On approval |
| Form III | Application for Plastic Waste Processor registration | Recycler / WTE / WTO / Composter | One-time (with updates) |
| Form IV | Annual Return on plastic packaging & EPR compliance | PIBO & PWP | Annual — due 30 June |
| EPR Action Plan | Strategy to meet collection, recycling, recycled content, reuse targets | PIBO | With registration + updates |
| EPR Certificate | Certificate of 1 tonne of plastic processed by PWP | CPCB generates via PWP | Per transaction |
Common questions about Plastic EPR Registration under PWM Rules 2016 and its amendments.
All Producers, Importers, and Brand Owners (PIBOs) of plastic packaging must register — regardless of turnover or scale. Additionally, following the 2024 Amendment, importers of plastic raw material (resin, pellets, films, preforms) are also classified as importers and must register. Plastic Waste Processors (PWPs) — recyclers, waste-to-energy, waste-to-oil, and industrial composting units — must also register. Even service providers (IT/ITeS, R&D units) that import products in plastic packaging fall under the rules.
PIBOs operating in one or two states/UTs register with the concerned State Pollution Control Board or Pollution Control Committee (SPCB/PCC). PIBOs operating in three or more states/UTs register centrally with the Central Pollution Control Board (CPCB). All registrations are processed through the unified national portal at eprplastic.cpcb.gov.in.
Category I — Rigid (PET bottles, HDPE containers, jars)
Category II — Flexible (single- or multi-layer of same plastic, carry bags, pouches, sachets)
Category III — Multilayer (at least one layer of plastic plus at least one layer of non-plastic material, such as chips packets and tetrapak)
Category IV — Compostable (plastic sheets and carry bags made of compostable or biodegradable plastics, which require CPCB compostability certification)
Targets are category-specific and increase annually.
For FY 2024–25: Cat I 50%, Cat II 30%, Cat III 30%, Cat IV 50%
By FY 2027–28: Cat I 80%, Cat II 60%, Cat III 60%, Cat IV 80%
The collection target was already 100% by FY 2023–24. Targets are calculated on eligible quantity (MT), based on the average of the previous two fiscal years’ sales/imports.
Recycled-content obligations began in FY 2025–26 and increase annually.
Category I: 30% → 60% by FY 2028–29
Category II: 10% → 20%
Category III: 5% → 10%
Category IV: No recycled-content target
Imported recycled content does not count — only domestically sourced recycled plastic is eligible. FSSAI food-contact rules may restrict usage in some packaging.
Yes. As per the CBIC circular dated 3 June 2025, plastic raw material importers (including resin, pellets, films, and preforms) must be registered on the CPCB plastic EPR portal before customs clearance. This follows the 2024 Amendment expanding the definition of importer.
Environmental Compensation (EC) is a financial penalty based on the polluter-pays principle. As per CPCB April 2024 EC Guidelines, it applies for non-registration, EPR shortfall, false declarations, late returns, and repeat violations. Paying EC does not waive EPR obligations — the shortfall carries forward. The 2026 Amendment allows carry-forward up to 3 years from FY 2026–27, with at least one-third of shortfall to be met annually.
Form IV is the annual EPR return filed on the CPCB portal, due by 30 June of the following financial year. It includes plastic introduced in the market (category-wise, state-wise), waste collected and processed, EPR certificates purchased, recycled content usage, and reuse data. For FY 2024–25, the deadline has been extended to 31 March 2026.
Whether you are a PIBO introducing plastic packaging in India, a plastic raw material importer, or a Plastic Waste Processor — we manage the complete CPCB/SPCB compliance process for you.
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