EPR, or Extended Producer Responsibility, refers to the responsibility of a producer for the sustainable management of their product throughout its entire life cycle, including disposal. This concept is gaining momentum globally as a way to encourage producers to take responsibility for their environmental impact.
The following entities are required to comply with EPR guidelines:
These guidelines classify plastic packaging into four categories:
Category I: Rigid plastic packaging
Category II: Flexible plastic packaging of a single layer or multilayer (with differing types of plastic), plastic sheets or covers made from plastic sheet, carry bags, plastic sachet or pouches
Category III: Multilayered plastic packaging (with at least one layer of plastic and a minimum of one layer of material aside from plastic)
Category IV: Plastic sheet or carry bags made from compostable plastics
To register for EPR compliance, entities must submit the following information:
The Central Pollution Control Board (CPCB) has launched a centralized portal for EPR registration and related matters. CPCB will list Brand Owners and Plastic Waste Processors operating in more than two states, while the concerned State Pollution Control Board (SPCB) or Pollution Control Committee (PCC) will list those operating in one or two states.
Targets for EPR and obligations of PIBO
| Plastic packaging category | Year | EPR target (as %age of eligible quantity – category-wise) |
| 1 | 2021-22 | 25% |
| 2 | 2022-23 | 70% |
| 3 | 2023-24 | 100% |
(% of EPR target)
| Plastic packaging category | 2024-25 | 2025-26 | 2026-27 | 2027-28 and onwards |
| 1 | 50 | 60 | 70 | 80 |
| 2 | 30 | 40 | 50 | 60 |
| 3 | 30 | 40 | 50 | 60 |
| 4 | 50 | 60 | 70 | 80 |
(% of plastic produced for the year)
| Plastic packaging category | 2025-26 | 2026-27 | 2027-28 | 2028-29 and onwards |
| 1 | 30 | 40 | 50 | 60 |
| 2 | 10 | 10 | 20 | 20 |
| 3 | 5 | 5 | 10 | 10 |
| Plastic packaging category | Year | EPR target (as %age of eligible quantity – category-wise) |
| 1 | 2021-22 | 25% |
| 2 | 2022-23 | 70% |
| 3 | 2023-24 | 100% |
(% of EPR target)
| Plastic packaging category | 2024-25 | 2025-26 | 2026-27 | 2027-28 and onwards |
| 1 | 50 | 60 | 70 | 80 |
| 2 | 30 | 40 | 50 | 60 |
| 3 | 30 | 40 | 50 | 60 |
| 4 | 50 | 60 | 70 | 80 |
In the case of Category IV, a minimal level of recycling means the processing of plastic packaging waste for composting through industrial composting facilities.
End of life disposal:- Plastics that can’t be reclaimed are to be dispatched for end-of-life disposal.
Obligation for the usage of recycled plastic content:- Obligatory usage of recycled plastic in plastic packaging
(% of plastic produced for the year)
| Plastic packaging category | 2025-26 | 2026-27 | 2027-28 | 2028-29 and onwards |
| 1 | 30 | 40 | 50 | 60 |
| 2 | 10 | 10 | 20 | 20 |
| 3 | 5 | 5 | 10 | 10 |
| Plastic packaging category | Year | EPR target (as %age of eligible quantity – category-wise) |
| 1 | 2021-22 | 25% |
| 2 | 2022-23 | 70% |
| 3 | 2023-24 | 100% |
The Brand Owner using Category I (rigid) plastic packaging for their products shall have minimal obligation to exercise similar packaging as given below: Reuse of Category I rigid plastic packaging in food contact operations shall be subject to the regulation of FSSAI
Minimal obligation to reuse for Category I (rigid plastic packaging)
| Plastic packaging category | Year | Target (as percentage of Category I rigid plastic packaging in products sold annually) |
| A | Category I rigid plastic packaging with volume or weight equal or more than 0.9 litre or kg but lower than 4.9 litres or kg, as the case may be | |
| 1 | 2025-26 | 10 |
| 2 | 2026-27 | 15 |
| 3 | 2027-28 | 20 |
| 4 | 2028-29 and onwards | 25 |
| B | Category I rigid plastic packaging with volume of weight equal or more than 4.9 litres or kg | |
| 1 | 2025-26 | 70 |
| 2 | 2026-27 | 75 |
| 3 | 2027-28 | 80 |
| 4 | 2028-29 and onwards | 85 |
Quantity of rigid packaging reused by brand owner shall be calculated by reducing virgin plastic packaging manufactured/imported/bought in that year from the sales of the BO. The BO shall give this information on the centralized portal developed by CPCB
Quantity of Category I rigid plastic packaging reused shall be reduced from the total plastic packaging used under Category I by the obligated entities (BO)
The quantity of Category I rigid plastic packaging reused during the year 2022-2023 and 2023-2024 shall be reduced from the total plastic packaging used under Category I.
(% of EPR target)
| Plastic packaging category | 2024-25 | 2025-26 | 2026-27 | 2027-28 and onwards |
| 1 | 50 | 60 | 70 | 80 |
| 2 | 30 | 40 | 50 | 60 |
| 3 | 30 | 40 | 50 | 60 |
| 4 | 50 | 60 | 70 | 80 |
(% of plastic manufactured for the year)
| Plastic packaging category | 2025-26 | 2026-27 | 2027-28 | 2028-29 and onwards |
| 1 | 30 | 40 | 50 | 60 |
| 2 | 10 | 10 | 20 | 20 |
| 3 | 5 | 5 | 10 | 10 |
PIBOs can make use of their surplus EPR certificates in offsetting last year shortfall, carry forward into coming year and dealing it to other PIBOs. The offsetting, carry forward and sale of a surplus in one category can be used in the same category only.
PIBOs are required to file periodic targets and returns on the online portal created by CPCB under the EPR framework. The deals (offsetting, carry forward, sale and purchase) shall be recorded and submitted on the portal.
If you need any assistance with EPR target fulfilment for plastic waste, get in touch with us at Cercle X.