EPR — Extended Producer Responsibility (India)

Definition

EPR (“Extended Producer Responsibility”) is a regulatory regime that shifts responsibility for end-of-life management of specific product categories from municipalities + consumers to the Producers, Importers, and Brand Owners (PIBOs) that introduce those products into the Indian market. The producer must collect + recycle / dispose / refurbish a specified percentage of the waste arising from products of equivalent category previously placed in the market — discharged either by performing the activity directly OR by purchasing EPR credit certificates from approved recyclers / Producer Responsibility Organisations (PROs).

The regime is operationalised through separate notifications + dedicated CPCB-managed EPR portals for each product category:

Plastic packaging — Plastic Waste Management Rules 2016 + EPR Guidelines (Feb 2022, revised 2024)
E-waste — E-Waste Management Rules 2022 (effective 1 April 2023)
Batteries — Battery Waste Management Rules 2022
Used tyres — Used Tyre Management Rules 2022

Each scheme has its own targets, registration process, credit certificate format, + annual return cycle on the CPCB portal.

Why EPR exists

Three policy objectives:

Internalise end-of-life cost — without EPR, the cost of plastic / e-waste / battery disposal sits with municipalities + the environment; EPR puts it on the producer who designed the product
Drive circular product design — when producers bear the recycling cost, they have an incentive to design for recyclability (fewer multi-layer plastics, modular electronics, removable batteries)
Build a formal recycler economy — by mandating credit purchases from CPCB-registered recyclers, EPR moves volumes from informal kabaadi-walla aggregators to authorised facilities with safety + environmental compliance

EPR for plastic packaging — the most-cited regime

Plastic packaging is the largest EPR programme by participating PIBOs (40,000+ registered) and tonnage.

Scope

Plastic packaging is categorised into 4 categories under the EPR Guidelines:

Category I: rigid plastic packaging
Category II: flexible plastic packaging (single layer + multi-layered)
Category III: multi-layered plastic packaging (with at least one layer other than plastic)
Category IV: plastic sheet / cover used for packaging + carry bags made of compostable plastic

Who registers

Producers (P): manufacturers of plastic packaging
Importers (I): importers of plastic packaging or plastic-packaged products
Brand Owners (BO): entities owning the brand on plastic-packaged products sold in India (regardless of who manufactured the packaging)

Each registers on the CPCB plastic EPR portal with PAN, GSTIN, factory address, + introduction-quantity self-declaration. A unique EPR Registration Certificate is issued.

Targets

Annual targets escalate over the EPR Guidelines schedule:

FY 2024-25 onwards: 100% of EPR target for plastic packaging introduced in the preceding 2 years (averaged for Category I + II + III; separate handling for Category IV compostable plastic)
Recycling targets within the EPR target: progressive escalation, with minimum recycled content (Cat I + II) requirements building over time

EPR credit certificates

The producer doesn’t typically collect + recycle plastic directly. Instead:

Registered Plastic Waste Processors (PWPs) — recyclers, co-processors, waste-to-energy operators — collect plastic waste + generate EPR credit certificates on the CPCB portal
Producers / Importers / Brand Owners purchase these credits to discharge their EPR obligation

Credit price is market-determined; cost depends on plastic category + recycler region. Cat I (rigid, easier to recycle) credits are typically cheapest; Cat III (multi-layered) credits are typically most expensive.

Annual return

PIBOs file an annual return on the CPCB EPR portal declaring:

Introduction quantity by category for the FY
EPR target = Introduction quantity × Recycling / End-of-life-management % target
EPR credits retired against the obligation (with credit certificate IDs)

Failure to file or shortfall in credit retirement attracts environmental compensation (penalty) levied by CPCB.

EPR for e-waste

Governed by E-Waste Management Rules 2022, effective 1 April 2023 (replacing the 2016 Rules).

Scope

109 categories of EEE (Electrical + Electronic Equipment) listed in Schedule I + II, including:

Information technology + telecommunication equipment
Consumer electronics (TV, audio, video equipment)
Large + small household appliances
Lighting (LEDs, CFLs, fluorescent tubes)
Medical devices, monitoring instruments
Toys, leisure + sports equipment

EPR target

Recycling target % of preceding-year introduction quantity, escalating annually
Cat I (IT + telecom) typically has the highest recycling target given material recovery value (gold, copper, palladium)

EPR credit certificate

Authorised recyclers / refurbishers issue EPR credit certificates on the CPCB e-waste EPR portal. PIBOs purchase + retire credits against their obligation.

EPR for batteries

Governed by Battery Waste Management Rules 2022.

Scope

5 battery categories:

Portable batteries
Automotive batteries (lead-acid + lithium-based)
Industrial batteries
Electric vehicle batteries
Other batteries

EPR target

Collection + recycling target % of preceding-year sales quantity, escalating annually
Mineral recovery targets within the EPR target for end-of-life Li-ion EV batteries (cobalt, lithium, nickel)

BRSR linkage

EPR sits at the intersection of BRSR Principle 2 (Sustainable Products) and the BRSR Core circularity attribute (Embracing Circularity):

Principle 2 disclosure: the producer’s EPR obligations, fulfilment %, EPR credit retirement quantum
Circularity Core attribute: the recycled / reused fraction of the producer’s own waste outputs (separate from EPR end-of-life-of-product flows)

These two are not the same denominator. An FMCG entity may have introduced 1,000 tonnes of plastic packaging into the market (EPR obligation: 1,000 tonnes × target %) AND generated 50 tonnes of process plastic waste in its operations (BRSR Core circularity attribute scope). Both are reported, in different parts of BRSR.

For the upstream Principle 2 framework, see NGRBC Principle 2 — Sustainable Products. For the BRSR Core circularity attribute formula + audit findings, see Embracing Circularity Disclosure.

Common EPR questions

Who pays for EPR — the producer or the consumer? Statutorily, the producer. Operationally, the credit cost often gets passed through to product price — so the consumer pays indirectly. The EPR Guidelines do not regulate the price pass-through.

What if I import a product with plastic packaging? Importing PIBO is registered as the Brand Owner (or Importer if they’re not the brand owner). EPR obligation falls on the importing entity at the point of introduction into India. Re-exports of unsold inventory can be netted out with supporting documentation.

Is EPR linked to GST input credit? No direct linkage. EPR credit purchase invoices carry GST at the applicable rate (currently 18% for service supplies); this GST is creditable as input tax credit if used in the course or furtherance of business. The EPR obligation itself is non-creditable.

Does EPR cover the whole supply chain? No. EPR is limited to the categories notified in the relevant Rules (plastic packaging, EEE, batteries, used tyres). Many other waste categories — paper, glass, textile, organic — have no EPR regime currently.

What is the penalty for EPR non-compliance? Environmental compensation is levied by CPCB on the gap between obligation + retired credits, plus annual return non-filing penalties. The penalty amount is per-tonne of shortfall, scaled by the relevant Rule schedule.

Does EPR apply to SMEs? Yes — there’s no SME exemption based on size. A small producer of 10 tonnes of plastic packaging is subject to the same EPR framework as a 10,000-tonne producer. Many SMEs participate via aggregator PROs that handle the EPR portal interaction + credit procurement for a service fee.

What is a PRO (Producer Responsibility Organisation)? A PRO is a third-party entity that helps PIBOs discharge their EPR obligation — handles registration, annual return filing, credit procurement, recycler coordination. Some PIBOs handle EPR in-house; many (especially SMEs + small brand owners) outsource to PROs.

For end-to-end EPR compliance + plastic / e-waste / battery credit management routed through partner CA firms + PROs, this is part of the broader BRSR + sustainability service scope. See NGRBC Principle 2 — Sustainable Products for the producer-responsibility narrative within BRSR.