End-to-end compliance for PIBOs & Plastic Waste Processors — CPCB/SPCB portal registration, category-wise EPR target planning, EPR certificate procurement, recycled-content declarations, annual returns (Form IV) and EC defence.
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Overview
The Plastic Waste Management (PWM) Rules, 2016 were notified under the Environment (Protection) Act, 1986. The Extended Producer Responsibility (EPR) framework came into force via the 4th Amendment dated 16 February 2022, which introduced Schedule II — Guidelines on Extended Producer Responsibility for Plastic Packaging.
The rules have been amended multiple times — July 2022, April 2023, October 2023, March 2024, May 2025 (mandatory QR/barcode on packaging), and the 2026 Amendment (reuse obligations, carry-forward of deficits, registered environment auditors) — progressively tightening EPR targets, recycled-content obligations, and reuse requirements.
Under EPR, every Producer, Importer, and Brand Owner (PIBO) of plastic packaging — along with Plastic Waste Processors (PWPs) — must register on the Centralised EPR Portal at eprplastic.cpcb.gov.in (launched 5 April 2022) and fulfil category-wise targets for collection, recycling, end-of-life disposal, recycled content and (for Category I rigid) reuse.
Schedule II • Category-wise
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 Process
Our experts handle every step — from PIBO/PWP classification to ongoing annual returns and EPR certificate procurement — so you stay compliant without the overhead.
Identify your role (PIBO, PWP, raw material importer) and the plastic categories applicable to your packaging and operations across India.
Create a Single Sign-On account on epr.cpcb.gov.in, then navigate to the Plastic Packaging module at eprplastic.cpcb.gov.in.
Compile incorporation certificate, GST, PAN, CIN, IEC (for importers), CTE/CTO (for manufacturers & PWPs), GSTR-9, balance sheet, plastic material composition.
We determine whether your operations require CPCB central registration (3+ states) or SPCB/PCC state-level registration (1–2 states) and file accordingly.
Complete multi-part application: company details → plastic categories & HSN → sales/import data for last 2 FYs → pre-consumer waste → document uploads → fee payment.
Respond to any deficiency notices from CPCB/SPCB. On approval, the Registration Certificate is issued on the portal — typically 30–45 days end-to-end.
Buy category-wise EPR Certificates from CPCB-registered PWPs (1 certificate = 1 tonne of plastic processed). We manage tie-ups with recyclers and surplus certificate trades.
File by 30 June each FY. Details: tonnage introduced, waste collected, certificates procured, recycled content used, reuse percentages (Cat I). We track all deadlines.
Requirements
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.
Industries Covered
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.
🔍 Even service providers and IT/ITeS companies that import goods in plastic packaging are covered. Not sure if you qualify? Share your product SKU list — we'll confirm your obligation within 24 hours.
Schedule II Targets
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% |
Mandatory from FY 2025-26 — by weight of virgin plastic used in new packaging. Imported recycled content does not count.
| 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 | |||
Introduced by the 2026 Amendment for rigid plastic packaging, based on container volume.
| 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.
Penalties & Forms
Under CPCB's April 2024 EC Guidelines, non-compliance attracts environmental compensation calculated on the polluter-pays principle. Paying EC does not waive the target — the obligation rolls forward.
| Non-Compliance | Environmental Compensation | Additional Consequences |
|---|---|---|
| Non-Registration on Portal | Equivalent to 2× application fee per year of default | Cannot legally place plastic packaging on market |
| Shortfall in EPR Target | Formula-based — linked to category cost of recovery & recycling | Carry-forward allowed up to 3 years (per 2026 Amendment) |
| False Declaration / Data Fudging | Up to 4× the applicable EC amount | Registration suspension • Prosecution under EP Act |
| Missing Annual Return (Form IV) | Late fee + EC for AR non-filing | Registration marked defaulter • Certificate trading blocked |
| Use of Uncertified Recyclers | EPR credits treated invalid + EC for target shortfall | Reputational damage • Brand-level action |
| Continuing / Repeat Default | Progressive escalation per CPCB notification | Criminal prosecution under Section 15 EP Act 1986 |
⚠️Criminal Liability: Under Section 15 of the Environment (Protection) Act, 1986, non-compliance can attract imprisonment up to 5 years and/or fine up to ₹1 lakh, with additional penalty of ₹5,000 per day for continuing offences. Directors and authorised signatories can be 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 |
Whether you're a PIBO introducing plastic packaging into India, a plastic raw-material importer, or a Plastic Waste Processor — we handle the entire CPCB/SPCB compliance workflow. From registration to annual returns to EPR certificate trading.
FAQ
Common questions about Plastic EPR Registration under PWM Rules 2016 and its amendments.
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