EPR Compliance Advisory
Extended Producer Responsibility is expanding rapidly across India — plastics, e-waste, batteries, tyres, and used oil. We help brand owners, importers, and producers navigate CPCB EPR portal registration, target calculation, PRO management, annual compliance reporting, and BRSR integration.
EPR Obligations in India
Extended Producer Responsibility makes producers, importers, and brand owners (PIBOs) responsible for the end-of-life management of their products and packaging — even after the product is sold to the consumer. Non-compliance attracts environmental compensation, cancellation of EPR registration, and adverse BRSR disclosure.
Producers
Manufacturers of products containing plastic, electronics, batteries, or tyres. Responsible for collection and recycling of equivalent quantities.
Importers
Companies importing products or packaging into India. Same EPR obligations as domestic producers based on import volumes.
Brand Owners
Companies whose brand name appears on products or packaging, even if manufacturing is outsourced. Highest visibility to regulators.
Five Waste Streams Under EPR
Plastic Waste
PWM Rules 2016 (amended 2021)
All PIBOs of plastic packaging must register on CPCB EPR portal. Targets across 4 categories: Category I (rigid), II (flexible single layer), III (multi-layer), IV (compostable/multi-layer). Collection, recycling, and end-of-life processing targets increase annually. Single-use plastic ban for identified items since July 2022.
E-Waste
E-Waste Management Rules 2022
Covers 106 electronic products across 21 ITEW categories. Producers and manufacturers must collect and channel e-waste for recycling through authorised dismantlers/recyclers. Targets: 60% (FY23), increasing to 80% by FY27. EPR certificates tradeable on CPCB portal.
Battery Waste
Battery Waste Management Rules 2022
Covers portable, automotive, industrial, and EV batteries. Collection targets: 70% (FY24-25) increasing to 80% by FY26-27. Recycling efficiency: 50% for lead-acid, increasing for lithium-ion. Growing importance with India’s EV transition.
Tyre Waste
Tyre Waste Management Rules 2022
EPR for tyre producers and importers. Recovery targets for end-of-life tyres. Retreading, recycling (crumb rubber, pyrolysis oil), and energy recovery pathways. Annual returns to CPCB.
Used Oil
Hazardous Waste Rules 2016
Used lubricating oil is classified as hazardous waste. Generator responsibilities for collection, storage (90-day limit), and disposal through authorised re-refiners/recyclers. Manifest compliance required.
EPR Certificate Trading
CPCB EPR Portal
EPR credits generated by recyclers can be purchased by PIBOs to meet targets. The CPCB portal enables credit generation, transfer, and retirement. Surplus credits from one waste stream cannot offset shortfalls in another.
End-to-End EPR Advisory
Registration & Portal Filing
CPCB EPR portal registration for PIBOs and recyclers. Form preparation, document compilation, brand/product listing, and submission management. State-level SPCB registrations where required.
Target Calculation
Compute EPR obligations based on production/import/brand owner volumes. Category-wise plastic targets, e-waste collection targets by ITEW category, battery recycling efficiency thresholds, and tyre recovery targets.
PRO Selection & Management
Evaluate and select Producer Responsibility Organisations (PROs). Contract structuring, performance monitoring, evidence verification, and annual audit. Ensure PRO performance aligns with your EPR targets.
Collection System Design
Design efficient collection networks for each waste stream. Take-back programmes, collection centres, reverse logistics, consumer awareness campaigns, and kabaadiwala network integration.
Annual Return & Compliance
Preparation and filing of annual returns on CPCB EPR portal. Target achievement documentation, EPR certificate procurement, gap analysis, and corrective action plans for shortfalls.
BRSR & Sustainability Integration
Map EPR data to BRSR Principle 2 (product stewardship) and Principle 6 (waste management). Recycling rates, circular economy KPIs, and packaging sustainability metrics for ESG reporting and rating agencies.
RSustain EPR & Waste Tools
EPR Compliance Hub
EPR target calculator for plastic, e-waste, batteries, and tyres. Registration guidance and compliance tracking.
Launch tool →CircularFlow
Circular economy assessment with material flow analysis. Identify waste-to-value opportunities and circularity improvements.
Launch tool →ESG Compliance Calendar
Track EPR filing deadlines, annual return dates, and CPCB compliance windows for all 5 waste streams.
View calendar →Complementary Services
Waste Management
Comprehensive waste advisory across all 8 CPCB waste management rules
BRSR Compliance
EPR data feeds into BRSR Principle 2 and Principle 6 disclosures
Supply Chain ESG
Value chain packaging and waste management assessment
Environmental Clearances
CTE/CTO with waste management conditions
EPR Compliance FAQ
Who needs to register for EPR in India?
Any producer (manufacturer), importer, or brand owner (PIBO) whose products or packaging contain plastic, electronics, batteries, or tyres must register on the CPCB EPR portal. This includes companies whose brand name appears on packaging even if manufacturing is outsourced. Recyclers and dismantlers must also register. Registration is mandatory and non-registration is a violation of the applicable waste management rules.
What are the penalties for EPR non-compliance?
Non-compliance with EPR targets can result in: (1) environmental compensation calculated based on the shortfall in collection/recycling targets, (2) cancellation or suspension of EPR registration, (3) directions from CPCB/SPCB under the EP Act 1986, and (4) adverse disclosure in BRSR (non-compliance with environmental regulations under Principle 1 and Principle 6). The quantum of environmental compensation is determined by the pollution control authority and can be substantial for large producers.
What is a PRO and do I need one?
A Producer Responsibility Organisation (PRO) is a CPCB-registered entity that helps PIBOs meet EPR targets by organising collection, sorting, and channelling of waste to authorised recyclers. Using a PRO is not mandatory — PIBOs can set up their own collection systems — but most companies engage PROs for operational convenience. When selecting a PRO, evaluate their geographic coverage, recycler network, CPCB registration status, certificate generation track record, and pricing.
How are EPR targets calculated?
EPR targets are based on the quantity of products/packaging introduced into the market by the PIBO. For plastic waste, targets are specified as percentages by weight across 4 categories (rigid, flexible, multi-layer, compostable), increasing annually. For e-waste, targets are a percentage of the average weight of products sold in the preceding 3 years, by ITEW category. For batteries, targets are based on collection percentage and recycling efficiency by chemistry. The CPCB portal auto-calculates targets based on declared production/import volumes.
Can EPR certificates be traded?
Yes. The CPCB EPR portal enables trading of EPR certificates. Recyclers generate certificates upon processing waste; PIBOs purchase certificates to demonstrate target achievement. Certificates are waste-stream-specific — plastic EPR certificates cannot offset e-waste shortfalls. The trading mechanism creates a market-based incentive for recycling and allows PIBOs flexibility in how they meet targets. However, CPCB may impose restrictions on certificate trading to prevent misuse.
Get EPR Compliance Right
Book a consultation for CPCB portal registration, target calculation, PRO selection, or annual compliance support across all 5 waste streams.