EPR Registration: Types and Applicability

EPR Registration is a statutory environmental compliance applicable to businesses that introduce specified products, packaging or materials into the Indian market and consequently generate post-consumer waste. It places responsibility on producers, importers and other obligated entities to ensure that such waste is collected, recycled, processed or otherwise managed in an environmentally sound manner. The exact registration, recycling target, reporting requirement and compliance mechanism differ according to the particular waste stream covered under the applicable rules.

What Is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility, commonly known as EPR, is based on the principle that the responsibility of a business does not necessarily end once its product is sold. Where a regulated product ultimately becomes waste, the producer may remain responsible for ensuring that the prescribed quantity of that waste enters an authorised recycling or waste-management system.

In India, EPR operates through different waste-management rules framed under the Environment (Protection) Act, 1986. The Ministry of Environment, Forest and Climate Change (MoEFCC) presently maintains separate regulatory frameworks for plastic packaging, e-waste, batteries, waste tyres, used oil and end-of-life vehicles, among other environmental waste-management requirements.

EPR Registration Is More Than a Registration Certificate

Registration is only the starting point of EPR compliance. After registration, an obligated entity may have to calculate annual EPR liability, purchase or obtain valid EPR certificates, meet recycling or reuse requirements, maintain records and file prescribed returns.

A business therefore cannot treat EPR as a one-time licence. Its continuing obligations depend on the quantity and category of regulated products or materials placed in the Indian market during the relevant financial years.

Legal Provisions Governing EPR in India 

There is no single legislation called the "EPR Act". Instead, EPR obligations are created under different waste-management rules framed under the Environment (Protection) Act, 1986, and each waste stream has its own definitions, targets and compliance mechanism.

The principal EPR regimes presently relevant to businesses include the Plastic Waste Management Rules, 2016; E-Waste (Management) Rules, 2022; Battery Waste Management Rules, 2022; Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 for waste tyres and used oil; and Environment Protection (End-of-Life Vehicles) Rules, 2025.

Types of EPR Registration in India

1. EPR Registration for Plastic Packaging

EPR Plastic Registration is governed by the Plastic Waste Management Rules, 2016, read with the Guidelines on Extended Producer Responsibility for Plastic Packaging introduced through the 2022 amendments and subsequent amendments. The framework principally covers Producers, Importers and Brand Owners, commonly referred to as PIBOs.

Producer

A producer introducing plastic packaging into the market can become responsible for the plastic packaging associated with its business activities. Its liability is calculated category-wise according to the prescribed methodology and quantities reported through the EPR system.

Under the EPR framework, the target reached 100% of the eligible quantity from FY 2023-24, while separate minimum recycling, reuse and recycled-content obligations apply according to the relevant category and year.

Importer

An importer bringing packaged goods, plastic packaging or other covered material into India may independently attract EPR obligations. Importing through a foreign manufacturer does not by itself shift the Indian environmental compliance responsibility outside the country.

Importers should therefore examine both the product and its packaging before importation. IEC and import data also become important for determining and verifying the applicable liability.

Brand Owner

A business selling products under its own brand may qualify as a Brand Owner even where the actual packaging or manufacturing is carried out by another entity. Contract manufacturing or outsourcing should therefore not automatically be treated as an exemption from EPR.

Plastic EPR obligations can include recycling, reuse of eligible rigid plastic packaging, use of recycled plastic content and permitted end-of-life processing. CPCB's system records registrations, EPR certificates and compliance transactions.

2. EPR Registration for E-Waste

EPR E-Waste Registration is regulated by the E-Waste (Management) Rules, 2022, which came into force on 1 April 2023. The rules apply to manufacturers, producers, refurbishers and recyclers dealing with electrical and electronic equipment listed in Schedule I, subject to the exclusions specified in the rules.

A producer includes an entity that manufactures and sells covered electrical or electronic equipment under its own brand, sells equipment manufactured by another supplier under its own brand, sells imported covered equipment, or imports used electrical and electronic equipment.

Who Is a Producer Under E-Waste Rules?

The definition applies irrespective of the selling technique, which means online retail, dealerships and similar channels do not by themselves remove the obligation. Covered producers are required to register and fulfil their EPR targets through the prescribed portal mechanism.

E-Waste Recycling Targets

E-waste compliance operates substantially through recycling certificates generated by registered recyclers. Producers must fulfil prescribed targets based on the quantity of electrical and electronic equipment placed in the market and the average life assigned to the particular product.

Under Schedule III, the recycling target is 70% for FY 2025-26 and FY 2026-27, rising to 80% for FY 2027-28 and thereafter, subject to the rules and applicable product calculations. Importers of used electrical and electronic equipment are subject to a 100% EPR obligation for imported material after its end of life if it is not re-exported.

3. EPR Registration for Batteries

EPR Battery Registration is governed by the Battery Waste Management Rules, 2022, together with subsequent amendments notified by MoEFCC, including amendments issued through 2025. The framework applies broadly to batteries irrespective of chemistry, shape, volume, weight, material composition and use.

Batteries Covered Under EPR

The Provision recognises major battery streams such as portable batteries, automotive batteries, industrial batteries and electric vehicle batteries. Producers must identify the battery type and applicable material stream because EPR targets and certificate accounting are linked with the prescribed battery categories and recovered materials.

Manufacturers and importers introducing batteries into the market are required to comply with EPR obligations. Producers, recyclers and refurbishers operate through the centralised registration and EPR mechanism maintained by CPCB.

4. EPR Registration for Waste Tyres

Waste tyre EPR forms part of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, as amended to introduce the EPR framework for waste tyres. The system requires regulated tyre producers and recyclers to participate through CPCB's waste-tyre EPR mechanism.

Who Is Covered?

The definition of producer includes entities manufacturing and selling new tyres domestically, entities selling new tyres manufactured by others under their own brand, and persons selling imported new tyres. Import-related categories can also cover tyres brought into India for specified commercial purposes under the applicable rules.

Compliance is not satisfied merely by selling tyres through dealers or distributors. The obligated producer must account for its EPR liability and fulfil the prescribed obligation through the recognised recycling and certificate system.

5. EPR Registration for Used Oil

EPR for used oil is another important compliance introduced under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, as amended. CPCB operates a dedicated used-oil EPR system for producers, importers, collection agents and recyclers.

Applicability to Oil Businesses

Businesses manufacturing or importing base oil or lubrication oil can attract EPR liability based on the quantities prescribed under the framework. Importers of used oil are also brought within the compliance mechanism and must examine their separate responsibilities under the applicable rules.

The framework aims to channel used oil towards authorised re-refining, recycling or other permitted processing instead of uncontrolled disposal. Registration, transaction reporting and returns provide traceability from the obligated producer to the authorised processor.

6. EPR for End-of-Life Vehicles

A relatively recent EPR regime is contained in the Environment Protection (End-of-Life Vehicles) Rules, 2025, which came into force from 1 April 2025. The rules cover vehicle producers, registered owners, bulk consumers, Registered Vehicle Scrapping Facilities and other specified entities involved in handling end-of-life vehicles.

Which Vehicle Producers Are Covered?

A producer includes an entity manufacturing or assembling and selling vehicles under its own brand, selling vehicles under its brand where they are produced by another manufacturer, or importing vehicles. The rules cover motor vehicles including electric vehicles, battery-operated vehicles, e-rickshaws and e-carts, while specified agricultural vehicles are excluded.

Vehicle producers fulfil EPR primarily through certificates generated by Registered Vehicle Scrapping Facilities based on eligible steel recovered through scrapping. For FY 2025-26, the prescribed target begins at a minimum of 8% of steel linked with the corresponding historical vehicle-placement year for the relevant transport or non-transport category.

When Is EPR Registration Applicable?

Determining applicability requires looking at the actual business model rather than merely the company's registered activity. A company may be subject to one EPR regime, several regimes simultaneously, or none, depending on the products and materials it places in the Indian market.

Manufacturing Covered Products

A manufacturer selling regulated electrical equipment, batteries, tyres, vehicles or products using regulated plastic packaging should examine EPR before commencing commercial sale. Manufacturing through a third party does not automatically remove responsibility where the applicant qualifies as a producer or brand owner under the relevant rules.

Importing Into India

Importers are specifically covered under several EPR frameworks. Electronic goods, batteries, tyres, lubricating oils and packaged products should therefore be reviewed for EPR implications before regular import operations begin.

Selling Under Your Own Brand

A company can incur EPR responsibility even when it does not own a factory. Private-label businesses and brand owners using contract manufacturers must identify whether the law treats them as the obligated producer or Brand Owner.

Multiple EPR Registrations

One business can require more than one EPR registration. For example, an importer of an electronic device containing a battery and supplied in plastic packaging may potentially have obligations under the e-waste, battery and plastic packaging frameworks, depending upon the exact facts and regulatory classification.

Basic EPR Registration Process

EPR registration is increasingly administered through CPCB's online systems. CPCB has also introduced a Common EPR Portal/Single Sign-On structure, and the legacy plastic EPR portal ceased regular operations from 28 June 2026 after migration of user data to the Common EPR Portal.

Step 1: Determine the Applicable EPR Category

The first exercise is legal classification of the product, packaging and role of the applicant. Incorrectly registering as a manufacturer, producer, importer or Brand Owner can affect both registration and future EPR liability.

Step 2: Compile Business and Product Data

Typical information includes PAN, GST details, constitutional documents, authorised-person details, product or material information and historical production, procurement, sales or import data. For plastic EPR, the notified guidelines specifically contemplate business and authorised-person identification information during registration.

Step 3: Submit the Online Application

The applicant applies through the relevant CPCB EPR system and provides the information required for that particular waste stream. Registration should be obtained before carrying on an activity where the rules prohibit regulated entities from operating without registration.

Step 4: Fulfil EPR Targets

After registration, the entity must determine its annual liability and meet the required recycling, reuse, recovery or scrapping obligation. Depending on the applicable rules, compliance may involve obtaining valid EPR certificates generated by registered recyclers or authorised facilities.

Step 5: File Returns and Maintain Records

Registration does not remove annual compliance responsibilities. Sales, import, procurement, recycling certificates, waste quantities and other prescribed information must be correctly reconciled and reported through the relevant system.

Consequences of Non-Compliance

Failure to register, furnishing incorrect information, non-fulfilment of EPR targets or dealing with unregistered entities can lead to regulatory action. Depending on the applicable waste-management rules, consequences may include environmental compensation, suspension or cancellation of registration and other proceedings available under environmental law.

For plastic packaging, environmental compensation is expressly linked with the polluter pays principle, and payment of environmental compensation does not itself extinguish the outstanding EPR obligation. The unfulfilled obligation can continue to be carried forward in accordance with the applicable framework.

Conclusion

EPR Registration has developed into a broad environmental compliance framework covering several major waste streams in India. Plastic packaging, electrical and electronic equipment, batteries, tyres, lubricating oils and vehicles can each create separate producer responsibility obligations under different rules.

Businesses should therefore avoid treating "EPR Registration" as one universal certificate. The correct compliance depends upon the product, packaging, role of the entity, quantities introduced in the market, applicable financial year and specific recycling or recovery requirements prescribed under the relevant rules. If you need assistance, feel free to contact with Compliance Calendar LLP.