Plastic Packaging EPR: Who Must Register and Why

Extended Producer Responsibility, or EPR, means the companies that put plastic packaging into the market are responsible for collecting and recycling an equivalent amount. In India the rule comes from the Plastic Waste Management Rules, 2016, as amended in 2022, and it affects far more businesses than people realise.

Who has to register

Three groups are covered: producers who make plastic packaging, importers who bring in packaging or packaged goods, and brand owners who sell products in plastic packaging. Together they are called PIBOs. If your product goes to customers in a plastic pouch, bottle, wrapper or carry bag with your brand on it, you are probably a brand owner for this purpose. Recyclers and processors of plastic waste also have to register on the same system.

The four categories

The 2022 amendment divides plastic packaging into four categories. Category I is rigid plastic packaging. Category II is flexible packaging of a single layer or multiple layers, along with plastic sheets, carry bags, sachets and pouches. Category III is multilayered packaging that has at least one plastic layer and one layer of another material. Category IV is plastic sheets and carry bags made of compostable plastic. Your obligations are worked out category by category.

How the system works

Registration and reporting are done on the centralised EPR portal run by the Central Pollution Control Board. PIBOs have to meet yearly targets, which they do by buying EPR certificates generated by registered recyclers and processors. They then file an annual return showing what they put on the market and how the target was met. Targets and certificate rules are updated by notification, so confirm the current ones for your category.

Common mistakes

Small brands often assume the rule only applies to big manufacturers. Others do not keep records of how much packaging they buy or import in each category, which makes the annual return hard to prepare. Working with the packaging supplier to get category-wise quantities is a good first step.

How we can help

Our EPR plastic waste service covers registration and annual returns, and recyclers can look at plastic waste processor registration. Related guides on EPR annual returns and the state board explainer are linked from our environment, waste and plant setup section.