Plastic EPR in India: what a brand owner must do, and what it costs

If you sell goods in India under your own brand, in plastic packaging, and your business is bigger than a small enterprise, you have an Extended Producer Responsibility (EPR) obligation for that plastic.

In plain words, you must register with the Central Pollution Control Board (CPCB) and take responsibility for an amount of plastic waste equal to the plastic packaging you put on the market. Most brand owners do this by buying EPR certificates from registered recyclers and processors. You must also use a minimum share of recycled plastic, reuse some rigid packaging, label your packs and file an annual return.

We make plastic and paper packaging at Jagannath Polymers, so these rules shape part of the cost of the plastic packaging we sell to brand owners. For this guide we went to the notifications themselves, and we have linked each one below.

But I am a packaging maker, not a lawyer.

Treat this guide as a map of the rules as published, checked on 2 October 2026. The rules have been amended many times since 2016, so confirm your own position with a compliance professional before you act on it.

Are you a brand owner under the rules?

Let us start with who is covered.

The rules define a brand owner as a person or company who sells any commodity under a registered brand label or trademark. Two other groups have obligations too:

1. A producer makes plastic packaging, including intermediate material, and including packaging made on contract for brand owners.
2. An importer brings plastic packaging, or goods packed in plastic, into India for commercial use.

CPCB calls the three groups together PIBOs. One business can be more than one of them. A brand that imports some products in plastic packaging is both a brand owner and an importer, and registers in each role.

Now the important exception.

Schedule II says the obligation applies to brand owners "other than micro and small enterprises", as defined under the MSMED Act, 2006. CPCB's FAQ on PIBO registration says the same thing plainly: micro and small brand owners are exempted from fulfilling EPR obligations.

Since 1 April 2025, a micro enterprise has up to ₹2.5 crore of investment and ₹10 crore of turnover. A small enterprise has up to ₹25 crore of investment and ₹100 crore of turnover. The Press Information Bureau's year-end review of 30 December 2025 gives the full table.

One point is not clear from the text. The clause listing who must register names brand owners without repeating the micro and small exception. If you are a small brand owner, ask your advisor whether you still need a registration, even though you have no targets.

What does a brand owner have to do?

Here is the list, in the order we would take it.

1. Register on the CPCB portal before doing business. Since 28 June 2026, that is the Common EPR Portal. The old plastic EPR portal now says it is discontinued and that user data has been moved across. You link an existing account by registering with the same company PAN and authorised person's PAN. CPCB registers you if you operate in more than two states. If you operate in one or two, your State Pollution Control Board registers you, through the same portal.
2. Work out your EPR target for each category of plastic packaging. It is the average weight of virgin plastic packaging you bought and put on the market over the last two financial years, plus your average pre-consumer plastic packaging waste. Since 2023-24, the target is 100% of that figure.
3. Fulfil the target with EPR certificates. Only plastic waste processors registered under the rules can provide them. A minimum share must come from recycling, and the rest may come from end-of-life uses such as co-processing.
4. Use recycled plastic in your own packaging, at the share set for each category.
5. Reuse a share of your rigid packaging, if you use rigid packs of 0.9 litre or kg and above.
6. Print the required details on your packs: your name and the registration number generated through the portal. Since 1 July 2025, you may give this information through a barcode or QR code on the pack instead, under the 2025 amendment (G.S.R. 73(E), 23 January 2025).
7. File an annual return. The rules say 30 June of the next financial year. For 2025-26, the Ministry extended the deadline for producers, importers and brand owners to 31 December 2026, by an office memorandum dated 28 August 2026 published on the CPCB portal.

There is one more duty that is easy to miss in purchase. Registered entities must not deal with unregistered entities that are required to register.

So ask each of your plastic packaging suppliers for their EPR registration, and keep a copy on file.

Which category is your packaging in?

The EPR guidelines of 16 February 2022 (G.S.R. 133(E)) sort plastic packaging into categories. The 2024 amendment (G.S.R. 201(E), 14 March 2024) added a fifth. The examples in the right-hand column are mine, not the rules'.

Each category has its own target, its own certificates and its own penalty rate.

Surplus in one category can be used only within that same category.

What are the targets for 2026-27?

These tables come from the Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E), 31 March 2026) and the 2022 guidelines.

The recycled-content shares rise to 60%, 20% and 10% from 2028-29. For Category III, the recycled-content target counts only the weight of the plastic layers.

For rigid packaging (Category I), the reuse targets for 2026-27 are:

1. 15% for packs of 0.9 to under 4.9 litres or kg.
2. 75% for packs of 4.9 litres or kg and above used for drinking water.
3. 10% for packs of 4.9 litres or kg and above used for other products.

The 2026 amendment also added two reliefs.

1. Where a law, an FSSAI or CDSCO regulation, or a mandatory Indian Standard does not permit recycled plastic or reuse, those targets do not apply. You must cite that rule in your annual return.
2. A 2025-26 shortfall in recycled content for food-contact packaging, and in rigid-packaging reuse, can be carried forward over up to three years from 2026-27. At least one third must be cleared each year.

What happens if you fall short?

CPCB levies environmental compensation. Its revised guidelines of August 2024 set it at ₹2,900 per tonne of shortfall for Category I, ₹5,000 for Category II, and ₹7,900 for Categories III and IV. A second default is charged at twice the rate, and a third at three times.

It is tempting to compare these rates with the price of certificates and decide that paying is cheaper. The rules do not allow that shortcut. Payment does not absolve you of the obligation. The shortfall is carried forward for up to three years, and the compensation is refunded only partly (75%, 60% or 40%) as you clear the shortfall within one, two or three years.

Be careful with the certificates you buy, because the risk stays with you. In a reply to Parliament on 2 December 2024, the government said CPCB's random audit of registered plastic waste processors found irregularities, and that compensation was directed against certificates that did not conform, as the Press Information Bureau reported. A fair price paid to a processor you have checked is safer than a small saving on a certificate that fails an audit later.

What drives the cost?

There is no fixed price for EPR. I would think of the cost in five parts, and we use the same five parts in the calculation below.

1. Tonnes. Almost every cost scales with the tonnes of plastic packaging you put on the market, category by category. Lighter packaging means a smaller obligation, as we show in our guide on downgauging.
2. Certificates. Prices are set by the market. The 2024 amendment asks CPCB to fix a highest and a lowest price for certificates traded on its platform, at 100% and 30% of the compensation rate. By simple arithmetic, that is ₹870 to ₹2,900 per tonne for Category I, ₹1,500 to ₹5,000 for Category II and ₹2,370 to ₹7,900 for Categories III and IV. Ask your advisor how this band applies to your purchases today.
3. Recycled content. This cost shows up in your packaging price, not on a certificate invoice, so it is easy to miss. It also needs testing and supplier records.
4. Fees and administration. Registration and processing fees, an advisor or a person in-house, and monthly records of packaging purchased by category and weight.
5. Risk. Compensation for any shortfall, and the cost of replacing certificates that fail an audit.

Your calculation

Here is a way to put a yearly rupee figure on your EPR. Every figure in this example is an ASSUMPTION, chosen only to show the method. None of them is a market price, a quote or legal advice.

Take a home-care brand that is not a small enterprise. It sells in rigid bottles under 0.9 litre (Category I) and ships in plastic courier bags (Category II). Because the bottles are under 0.9 litre, the reuse target does not apply. Assume it uses the same tonnage this year as its two-year average.

Add ₹1,50,000 a year for fees, records and advice (assumed).

1. Total: ₹2,40,000 + ₹1,20,000 + ₹3,84,000 + ₹32,000 + ₹1,50,000 = ₹9,26,000 a year.
2. Per kg of plastic packaging: ₹9,26,000 ÷ 1,60,000 kg = about ₹5.80.
3. Per order, at 6,00,000 orders a year (assumed): about ₹1.54.

In this example, the recycled-content line is bigger than the certificates. It is also the line that is easiest to leave out of a budget, because no single invoice carries it.

Now test one lever. If the brand cuts the weight of its plastic packaging by 10%, the certificate and recycled-content lines fall by about 10% too, once the lower weights reach the two-year average. That is about ₹77,600 a year, before counting the material it no longer buys.

To repeat this with your own figures, do it category by category:

1. Tonnes = average plastic packaging over the last two financial years (plus pre-consumer waste).
2. Certificate cost = tonnes × your average price per tonne.
3. Recycled-content cost = packaging used in the year × the category share × your extra cost per kg.
4. Total = certificates + recycled content + reuse costs (if any) + fees and administration.
5. Cost per order = total ÷ orders shipped in the year.

I would start by pulling one year of packaging purchases from your accounts and sorting them into the five categories. On a first pass it is easy to put a laminate or a coated board in the wrong category, so do it slowly.

Then take the sheet to your compliance advisor.

You will have a much better conversation with numbers in hand. Our 10-point packaging specification review will then help you find the tonnes worth cutting first.