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# EPR Compliance in India: E-Waste, Battery, and Plastic Waste

Extended Producer Responsibility makes manufacturers and importers responsible for the entire lifecycle of their products including post-consumer waste collection and recycling. India has separate EPR frameworks for e-waste, batteries, plastic packaging, tyres, and used oil — each with its own targets, portals, and compliance requirements.

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At a glance

EPR categories

5

Auth steps

6

E-waste targets

60-100%

## EPR categories in India

### E-Waste (Electronics)

**Rules:** E-Waste Management Rules 2022

**Portal:** CPCB EPR Portal for E-Waste

**Applies to:** Manufacturers, importers, and brand owners of electrical and electronic equipment

Collection targets, recycling targets, registration on portal, quarterly returns

### Battery Waste

**Rules:** Battery Waste Management Rules 2022

**Portal:** CPCB EPR Portal for Battery Waste

**Applies to:** Battery manufacturers, importers, assemblers, and brand owners

Collection targets based on battery chemistry, recycling/refurbishment targets, EPR obligations

### Plastic Packaging

**Rules:** Plastic Waste Management Rules 2016 (amended)

**Portal:** CPCB EPR Portal for Plastic Packaging

**Applies to:** Producers, importers, brand owners using plastic packaging

EPR targets for plastic waste collection and recycling, registration, annual returns

### Tyre Waste

**Rules:** Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules 2022

**Portal:** CPCB EPR Portal for Tyre Waste

**Applies to:** Tyre manufacturers, importers, recyclers

Collection and recycling targets for end-of-life tyres

### Used Oil

**Rules:** Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules 2022

**Portal:** CPCB EPR Portal for Used Oil

**Applies to:** Used oil generators, recyclers, importers

Collection targets, recycling obligations, disposal methods

## E-Waste collection targets schedule

YearCollection Target

2023-202460% of quantity sold in 2018-2019

2024-202570% of quantity sold in 2019-2020

2025-202680% of quantity sold in 2020-2021

2026-202790% of quantity sold in 2021-2022

2027 onwards100% of quantity sold in 2022-2023

## EPR authorization process

01

### Determine applicable EPR category

Identify which EPR rules apply to your products: E-Waste for electronics, Battery Waste for batteries, Plastic for packaging, Tyre/Oil if applicable.

02

### Register on CPCB EPR Portal

Create account on the relevant CPCB portal for your category. Submit company details, product information, and expected sales volumes.

03

### Engage PRO or recycler for compliance

You can fulfill EPR obligations directly or through a Producer Responsibility Organization (PRO). PROs handle collection, recycling, and reporting on your behalf.

04

### Submit EPR Plan

Develop and submit annual EPR plan detailing how you will meet collection and recycling targets, including tie-ups with recyclers or PROs.

05

### Obtain EPR Authorization

CPCB/SPCB reviews plan and grants EPR Authorization certificate. Valid for 5 years, renewable.

06

### File quarterly/annual returns

Report actual collection and recycling quantities against targets. Returns are mandatory even if targets are not fully met.

## Product labeling requirements

Product must display crossed-bin symbol (for E-Waste) indicating it should not be disposed with general waste

Battery products must display chemistry type and recycling information

Plastic packaging must display recycling code and material identification

Company contact information for return/collection must be provided

QR codes linking to EPR information increasingly required

## Frequently asked questions

### What happens if I don't meet EPR collection targets?

Non-compliance with EPR targets can result in: Environmental Compensation (financial penalty) based on shortfall and category, suspension or cancellation of EPR Authorization, restriction on manufacturing/importing, and potential legal action. CPCB calculates environmental compensation using standardized formulas. It's better to file returns showing partial compliance than to not file at all.

### Can foreign manufacturers comply with Indian EPR requirements?

Yes. Foreign manufacturers importing into India must obtain EPR Authorization just like domestic manufacturers. They can: (1) Establish Indian subsidiary to act as importer of record and EPR entity, (2) Appoint an Authorized Representative in India who takes EPR responsibility, or (3) Ensure their Indian importer takes EPR responsibility ( importer must then register as brand owner). Many companies use PROs to handle the operational compliance.

### What is a Producer Responsibility Organization (PRO)?

PROs are specialized agencies that help producers meet EPR obligations. Services include: collection network setup, logistics for waste transport, tie-ups with registered recyclers, quarterly return filing on your behalf, and ensuring recycling targets are met through verified certificates. Using a PRO is optional but common, especially for smaller producers or foreign companies without India operations.

### How are EPR targets calculated for new market entrants?

For new companies with no sales history, CPCB may calculate targets based on projected sales or apply a graduated approach. Some categories allow target exemption for first year of operations, followed by increasing percentages. Contact CPCB or your PRO for specific guidance based on your entry timing and product category.

### What documents prove EPR compliance?

Key compliance documents include: EPR Authorization certificate from CPCB/SPCB, Recycler agreements or PRO contracts, Quarterly/Annual EPR returns filed on portal, Recycler certificates showing quantities recycled, Invoices and transport documents for waste movement, and Bank guarantees (if required). These must be retained for 5+ years for audit purposes.

**Disclaimer:** This guide reflects current EPR rules under E-Waste 2022, Battery Waste 2022, and Plastic Waste Management Rules. Targets and portal procedures are subject to CPCB notifications. Always verify current requirements on official CPCB portals.

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