Introduction

The rapid growth in plastic consumption, combined with poor waste handling, has become a major contributor to environmental damage. Plastic that is not properly collected or processed often ends up in landfills, water bodies, and natural ecosystems, creating long-term pollution and health risks. Recognizing this challenge, India has taken several policy and regulatory steps to control plastic pollution and promote responsible plastic use.

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In this direction, the Ministry of Environment, Forest and Climate Change (MoEFCC), Government of India, introduced the Plastic Waste Management Rules in 2011. These rules have been revised and strengthened over time to encourage a circular economy, where plastic materials are reused, recycled, and responsibly managed instead of being discarded after use. The objective has been to reduce the environmental harm caused by plastic products and packaging.

A major shift in policy came with the introduction of Extended Producer Responsibility (EPR) under the Plastic Waste Management Rules, 2016. Under this framework, the responsibility for plastic waste management was extended beyond municipal bodies to include Producers, Importers, and Brand Owners (PIBOs)—the entities that place plastic products and packaging into the market. To further strengthen this system, MoEFCC issued detailed Guidelines on Extended Producer Responsibility for Plastic Packaging on 18 February 2022, providing a structured mechanism for implementation and enforcement.

This Standard Operating Procedure (SOP) brings together the latest EPR guidelines and presents a practical framework for their application. It also aims to support Urban Local Bodies in Uttar Pradesh by enabling them to use the EPR system as a financial and administrative tool for improving plastic waste management across the state.

What is EPR for Plastic Packaging?

Under the Plastic Waste Management Rules, Extended Producer Responsibility (EPR) refers to the obligation of a producer to ensure that their product is managed in an environmentally safe manner until it reaches the end of its life.

In simple terms, EPR for plastic packaging means that companies that manufacture, import, or sell products in plastic packaging must take responsibility for what happens to that plastic after consumers use it. This includes setting up systems to collect waste plastic, sending it for recycling or reuse, and ensuring that whatever cannot be recycled is disposed of in an environmentally safe way.

The EPR framework is designed to move India towards a circular economy, where plastic does not become waste after a single use, but is instead brought back into the production cycle. Under this system, PIBOs are required to:

  1. Arrange for the collection of plastic waste generated from their products
  2. Ensure that the waste is processed and recycled
  3. Use recycled plastic in manufacturing, wherever required
  4. Ensure safe end-of-life disposal for non-recyclable plastic
  5. Meet their obligations through the EPR credit system in coordination with Plastic Waste Processors (PWPs)

Through this approach, the burden of managing plastic waste is placed on those who introduce plastic into the market, ensuring greater accountability and reducing pressure on public waste management systems.

Why is EPR for Plastic Packaging Required?

Extended Producer Responsibility (EPR) was introduced to move the responsibility for plastic waste away from local governments and towards the companies that manufacture, import, and sell plastic-packaged products. Earlier, municipal bodies were left to manage the growing volume of plastic waste without having either sufficient funds or control over how much plastic entered the market. EPR corrects this imbalance by making producers accountable for the waste generated by their products.

EPR also supports India’s transition to a circular economy, where plastic materials are kept in use for as long as possible through recycling, reuse, and better product design. By placing legal responsibility on producers, the EPR system encourages them to reduce unnecessary packaging, use recycled materials, and adopt environmentally friendly product designs. In this way, EPR does not just manage waste—it also prevents waste at the design stage.

Through this framework, companies are motivated to rethink how much plastic they use, how their packaging is designed, and how easily it can be collected and recycled after use.

Key Objectives of EPR

The EPR framework is built around the following core goals:

  1. Creating an integrated system for plastic waste management
  2. Reducing the burden of plastic waste management on Urban Local Bodies and Gram Panchayats
  3. Ensuring recycling and safe end-of-life disposal of plastic waste
  4. Strengthening the circular economy by returning plastic into the production cycle
  5. Promoting research, innovation, and investment in eco-friendly packaging and product design

Benefits of EPR for Urban Local Bodies and Gram Panchayats

When EPR is effectively implemented, it provides multiple environmental and financial benefits to local governments:

  1. It helps prevent plastic from entering landfills, drains, rivers, and other natural ecosystems
  2. It reduces greenhouse gas emissions, leading to improved air quality
  3. It increases recycling and reuse, improving overall waste circularity
  4. Better segregation and organized collection lead to higher revenue from recyclable materials
  5. Improved packaging design makes plastic easier to recycle and reuse

In addition to environmental gains, EPR also brings social and economic benefits:

  1. It creates jobs by integrating waste pickers and informal workers into the formal plastic value chain
  2. It allows waste management costs to be shared between government bodies and the private sector
  3. It improves accountability, traceability, and transparency across the plastic waste management system

Challenges in Implementing EPR

Despite its benefits, implementing EPR across states and local bodies faces several practical challenges:

  1. Poor segregation of waste at the household and commercial levels
  2. Limited awareness among consumers and stakeholders about EPR guidelines and waste flows
  3. Absence of well-organised take-back and collection networks, which are costly and complex to set up
  4. Shortage of trained staff at material recovery facilities and waste collection centres
  5. Rapid growth in plastic waste, including waste brought in from other states
  6. Difficulties in transporting waste to recycling or processing facilities due to distance and poor infrastructure
  7. Resistance from some stakeholders, especially Plastic Waste Processors, to register and participate in the EPR system
  8. Lack of reliable data, monitoring systems, and digital tracking
  9. Absence of uniform technical standards for plastic waste processing

Components of the New EPR Guidelines for Plastic Packaging

India’s EPR framework for plastic packaging legally requires Producers, Importers and Brand Owners (PIBOs) to take responsibility for the plastic they introduce into the market by ensuring that it is collected, recycled, and safely disposed of after use. This obligation was significantly strengthened when the Ministry of Environment, Forest, and Climate Change (MoEFCC) issued detailed EPR Guidelines for Plastic Packaging in February 2022.

These guidelines expanded the scope and enforceability of EPR and brought more actors and materials under regulatory control. The key features of the new framework are as follows:

  1. The EPR rules apply not only to producers, importers and brand owners, but also to Plastic Waste Processors (PWPs), including recyclers, co-processors, waste-to-energy plants, online marketplaces, e-commerce platforms, and large retail chains.
  2. EPR obligations now cover both pre-consumer (industrial scrap and rejects) and post-consumer plastic packaging waste.
  3. Plastic packaging is divided into four legally defined categories:
    1. Rigid plastic packaging
    2. Flexible plastic packaging
    3. Multi-layered plastic packaging
    4. Compostable plastic
  4. The Central Pollution Control Board (CPCB) has established a centralised digital platform (www.eprplastic.cpcb.gov.in) to implement the EPR system. This portal is used for registration, reporting, target tracking, certificate generation and compliance monitoring for PIBOs and plastic waste processors across India.
  5. The guidelines prescribe progressive annual recycling targets, starting at 25% and increasing up to 100%, depending on the category of plastic and the compliance year.
  6. The policy requires reuse of rigid plastic packaging and mandates a gradual reduction in the use of virgin plastic for packaging.
  7. The EPR framework is based on the “Polluter Pays” principle. If a PIBO fails to meet its EPR targets, it is liable to pay Environmental Compensation, which is used for environmental protection, pollution control and waste management.

Key EPR Compliance Milestones

The guidelines introduce phased compliance requirements:

  1. From 2024 onwards, PIBOs must fulfil their EPR obligations primarily through verified recycling
  2. From 2025 onwards, brand owners must ensure reuse of rigid plastic packaging
  3. From 2025 onwards, a minimum percentage of recycled plastic must be used in packaging

Types of Plastic Covered Under EPR for Plastic Packaging

The EPR framework covers all major types of plastic packaging through four defined categories:

Category I – Rigid Plastic Packaging

This includes hard and moulded plastic packaging such as bottles, containers and tubs, commonly made from:

  1. PET (Polyethylene Terephthalate)
  2. HDPE (High-Density Polyethylene)
  3. PP (Polypropylene)

Category II – Flexible Plastic Packaging

This includes single-layer or multi-layer flexible packaging such as pouches, wrappers and sachets, made from materials such as:

  1. PVC
  2. LDPE
  3. PP
  4. PS

These plastics are commonly used in food, FMCG and consumer product packaging.

Category III – Multi-layered Plastic Packaging

This refers to packaging that contains at least one layer of plastic and at least one layer of another material, such as aluminium or paper. These are classified under:

  • Plastic material code “Other”

Such packaging is widely used for chips, beverages, pharmaceuticals and ready-to-eat products.

Category IV – Compostable Plastic Packaging

This includes:

  1. Plastic sheets used for packaging
  2. Carry bags made from compostable plastic

These materials must meet the Indian standard IS / ISO 17088:2021, which specifies the technical requirements for compostable plastics.

Who are Plastic Waste Processors (PWPs)?

Plastic Waste Processors (PWPs) are entities that handle and process plastic waste after it has been collected. They play a central role in fulfilling EPR obligations by converting waste plastic into usable material, energy or safely treated residue.

PWPs include organisations engaged in:

  1. Plastic recycling into pellets, chips or finished products
  2. Waste-to-energy processing, including co-processing in cement and steel plants
  3. Plastic-to-fuel or plastic-to-oil conversion
  4. Industrial composting of compostable or biodegradable plastic

All PWPs must be registered on the CPCB’s Centralised EPR Portal (www.eprplastic.cpcb.gov.in). No plastic waste processing activity can be carried out legally without this registration.

EPR Processing Codes for PWPs

When registering on the portal, PWPs must select the appropriate processing activity from the following categories:

Recycling

  1. R1 – Recycling Category I plastic into pellets or chips
  2. R2 – Recycling Category II plastic into pellets or chips
  3. R3 – Recycling Category III plastic into pellets, chips or fibres
  4. R4 – Recycling Category I plastic into finished products
  5. R5 – Recycling Category II plastic into finished products
  6. R6 – Recycling Category III plastic into finished products

Composting

  1. C1 – Processing Category IV (compostable plastic) through industrial composting

End-of-Life Processing

  1. E1 – Co-processing of plastic waste in cement plants
  2. E2 – Co-processing of plastic waste in steel plants
  3. E3 – Waste-to-energy processing
  4. E4 – Waste-to-oil processing

End-of-Life Disposal

Only plastic waste that cannot be recycled is allowed to be sent for end-of-life disposal. This includes uses such as:

  1. Road construction
  2. Waste-to-energy
  3. Waste-to-oil

Such disposal must comply with the guidelines issued by the Indian Road Congress and the Central Pollution Control Board (CPCB) from time to time.

Role of Urban Local Bodies and Gram Panchayats

Urban Local Bodies and Gram Panchayats that operate plastic processing facilities—such as Material Recovery Facilities (MRFs), composting units or waste-to-energy plants—must also register as Plastic Waste Processors (PWPs) on the CPCB EPR portal. This allows them to participate in the EPR system and receive financial and compliance benefits linked to plastic waste processing.

Roles and Responsibilities of Stakeholders under Plastic EPR

The responsibilities of different stakeholders under the Extended Producer Responsibility (EPR) framework for plastic packaging are defined under Clauses 10 to 13 of the EPR Guidelines notified by the Ministry of Environment, Forest and Climate Change (MoEFCC). Although Urban Local Bodies and Gram Panchayats are not directly assigned EPR targets, they play a critical role in ensuring that the plastic waste management system functions effectively on the ground.

Producers, Importers and Brand Owners (PIBOs)

PIBOs are the entities that introduce plastic packaging into the market and are therefore legally responsible for managing the waste generated from it.

Key Obligations of PIBOs

PIBOs must:

  1. Register themselves on the Centralised EPR Portal developed by the Central Pollution Control Board (CPCB) and obtain a valid registration certificate.
  2. Submit an EPR Action Plan through the portal, specifying category-wise EPR targets where applicable.
  3. Maintain accurate records of the quantity and category of plastic packaging purchased and sold.
  4. Create a separate waste collection stream, in coordination with Urban Local Bodies or Gram Panchayats, to collect plastic packaging waste. This may include systems such as deposit-refund schemes, buy-back models or other structured collection mechanisms to prevent plastic packaging waste from mixing with general municipal waste.
  5. File annual returns with CPCB or the concerned State Pollution Control Board (SPCB) detailing the quantity of plastic packaging waste collected and processed for fulfilling EPR obligations.

In summary, PIBOs are responsible for:

  1. Registration on the EPR portal
  2. Submission of EPR Action Plans
  3. Meeting targets for recycling, reuse, use of recycled content and end-of-life disposal
  4. Supporting plastic collection and recovery systems
  5. Submitting annual returns and compliance certificates

Plastic Waste Processors (PWPs)

Plastic Waste Processors are entities involved in recycling, co-processing, waste-to-energy, waste-to-oil and industrial composting of plastic waste.

Key Obligations of PWPs

PWPs must:

  1. Register on the CPCB Centralised EPR Portal and obtain a valid registration certificate.
  2. Submit annual returns on the portal showing category-wise quantities of plastic waste processed.
  3. Issue plastic waste processing certificates only if they are registered under the Plastic Waste Management Rules, 2016, as amended (except for road construction cases).
  4. Issue certificates in the name of the registered PIBO or local authority, based on mutually agreed arrangements.
  5. Ensure that certificates issued do not exceed their installed processing capacity.
  6. Maintain complete records and make them available for inspection by CPCB or SPCB.
  7. Follow CPCB-prescribed environmental and health standards in their processing activities.
  8. Avoid double counting — plastic for which one PWP has already generated credit cannot be used again by another PWP for generating EPR certificates.

Where plastic waste is used in road construction, PIBOs must submit a self-declaration in the CPCB-prescribed format, verified by the concerned local authority.

Entities Required to Obtain EPR Registration

Under the Plastic Waste Management (PWM) Rules and the Extended Producer Responsibility (EPR) framework, entities that introduce plastic or plastic-packaged products into the market are required to ensure that the plastic waste generated from their products is properly collected, processed and disposed of through registered Plastic Waste Processors (PWPs).

To meet their EPR obligations, PIBOs and other covered entities must:

  1. Ensure plastic waste is processed in accordance with an approved EPR Action Plan
  2. Obtain EPR certificates from registered PWPs based on the quantity of plastic waste processed
  3. Use these certificates to meet their assigned EPR targets

If an entity fails to comply with the Plastic Waste Management Rules, it becomes liable to environmental compensation and other regulatory or disciplinary actions.

Who Must Register on the CPCB EPR Portal

The following entities are required to obtain an EPR Registration Certificate through the centralised portal developed by the Central Pollution Control Board (CPCB):

  1. Producers
  2. Importers
  3. Brand Owners
  4. Sellers of plastic raw material
  5. Importers of plastic raw material
  6. Manufacturers of plastic raw material
  7. Producers operating as MSMEs
  8. Plastic Waste Processors engaged in:
    • Recycling
    • Waste-to-energy
    • Waste-to-oil
    • Industrial composting

Exemptions:
Brand owners classified as Micro and Small Enterprises under MSME norms are exempted from mandatory EPR registration.

Inclusions:
Online marketplaces, e-commerce platforms, supermarkets and large retail chains are covered under the EPR framework and must register.

Which Authority Grants Registration

  1. PIBOs operating in more than two states must obtain registration from CPCB
  2. PIBOs operating in one or two states must obtain registration from the concerned State Pollution Control Board (SPCB) or Pollution Control Committee (PCC)

All applications are filed through the CPCB’s EPR portal:
https://eprplastic.cpcb.gov.in

Step-by-Step EPR Registration Process

  1. Online Registration
    The applicant must create an account on the CPCB EPR portal by submitting basic company details and verifying credentials.
  2. Document Upload and Application Submission
    The applicant must upload the required documents and submit the completed EPR registration form online.
  3. Scrutiny by CPCB / SPCB
    The authorities review the application and supporting documents. If any errors or inconsistencies are found, the applicant will be asked to correct them.
  4. Approval or Rejection
    Based on the review, the authority will either approve the application and grant EPR registration or reject it, providing reasons for rejection.
  5. Implementation and Reporting
    After approval, the registered entity must implement its EPR Action Plan and submit annual reports detailing how plastic waste has been collected, processed and disposed of in compliance with EPR requirements.

Documents Required for EPR Registration (Part A)

Applicants must upload the following documents while submitting Part A of the EPR application on the CPCB portal. Each file must be in PDF format and not exceed 5 MB.

Mandatory Documents

  1. Company’s PAN, CIN and GST Registration Certificate
  2. PAN and Aadhaar of the authorised signatory
  3. Previous EPR Registration Certificate (for renewal cases, if applicable)
  4. Details of products manufactured or marketed, including type and quantity
  5. Photographs of plastic packaging showing different EPR categories used
  6. District Industries Centre (DIC) Registration Certificate of the State or Union Territory, where applicable

In addition to the above, applicants are also required to upload a valid Consent to Operate (CTO) under Part B of the application.

Movement of EPR Application within WBPCB (West Bengal PCB)

(Under Plastic Waste Management Rules, 2022)

After submission on the CPCB EPR portal, the application is processed by the State Pollution Control Board as per the following workflow:

Step

Process

Authority

Time Limit

1

Online application filed by PWP / PIBO / SIMP / ULB is forwarded through the CPCB portal to WBPCB for processing

CPCB Portal

Immediate

2

After fee payment, the Waste Management Cell reviews the application for completeness. If any document or information is missing, the applicant is notified through the portal

Waste Management Cell

Within 5 days

3

Physical inspection and audit of the unit

Regional Office / Waste Management Cell

Within 15 days

4

The Waste Management Cell sends the application with its recommendation to the Competent Authority. Applications containing false or misleading information are rejected and the fee is forfeited

Waste Management Cell

Within 10 days

5

Registration Certificate is issued online through digital signature. If the application is not processed within 30 days, the system automatically generates deemed registration

CPCB Portal

After 30 days

Application Fees for EPR Registration

A. Registration Fees for PIBOs

Plastic Waste Introduced (TPA)

Fee (₹)

Up to 1,000 TPA

10,000

1,000 – 10,000 TPA

20,000

Above 10,000 TPA

50,000

B. Registration Fees for Plastic Waste Processors (PWPs)

Processing Capacity (TPA)

Fee (₹)

Up to 200 TPA

5,000

200 – 2,000 TPA

20,000

Above 2,000 TPA

50,000

C. Annual Processing Fee

All registered PIBOs and PWPs are required to pay an annual processing fee equal to 25% of their original application fee for renewal and continued compliance.