EPR Registration (Extended Producer Responsibility)

What is Extended Producer Responsibility (EPR)?

Extended Producer Responsibility (EPR) is a policy approach under which producers, importers, and brand owners of certain products are held responsible for the end-of-life management of those products and their packaging. The Ministry of Environment, Forest and Climate Change (MoEFCC) has made EPR registration mandatory in India for multiple product categories. Non-compliance results in penalties, cancellation of import/business licences, and legal action under the Environment Protection Act, 1986.

Who Needs EPR Registration?

EPR registration is mandatory for:

  • Plastic Packaging EPR: Producers, importers, and brand owners (PIBOs) of any plastic packaging — rigid, flexible, multi-layered plastic, or carry bags. Governed by the Plastic Waste Management Rules, 2016 (amended 2022).
  • E-Waste EPR: Producers, importers, and brand owners of Electrical and Electronic Equipment (EEE) — mobile phones, computers, TVs, refrigerators, washing machines, ACs, etc. Governed by the E-Waste Management Rules, 2022.
  • Battery Waste EPR: Producers, importers, and brand owners of portable batteries, automotive batteries, and industrial batteries. Governed by the Battery Waste Management Rules, 2022.
  • Tyre EPR: Producers, importers, and brand owners of new tyres for any vehicle category. Governed by the Plastic Waste Management (Amendment) Rules for tyre waste.

EPR Registration Process

  1. Portal Registration: EPR registration is done on the Central Pollution Control Board (CPCB) EPR portal (https://eprplastic.cpcb.gov.in/ and https://ewaste.cpcb.gov.in/).
  2. Annual EPR Plan Submission: Every registered entity must submit an Annual EPR Plan specifying their production/import volumes and their plan for collection and recycling/disposal.
  3. EPR Targets Fulfilment: CPCB sets annual EPR targets (as a % of production/import). Targets must be met by purchasing EPR certificates from registered recyclers.
  4. EPR Certificate Procurement: EPR certificates are purchased from CPCB-registered recyclers/waste processors. We assist in identifying approved recyclers and procuring the required certificates at competitive prices.
  5. Annual EPR Return Filing: An annual EPR compliance return must be filed with CPCB with details of production/import, EPR targets, and certificates procured.

Our EPR Registration Services

  1. Determination of applicable EPR categories for your business
  2. Registration on CPCB EPR portals (Plastic, E-Waste, Battery, Tyre)
  3. Annual EPR Plan preparation and submission
  4. EPR target calculation and monitoring
  5. Procurement of EPR certificates from registered recyclers
  6. Annual EPR return filing with CPCB
  7. Compliance advisory and representation before CPCB in case of notices

Frequently Asked Questions – EPR Registration

Q: Is EPR registration required for importers?

Yes. Importers of products with plastic packaging, electronic/electrical equipment, batteries, or tyres are required to register for EPR in India. Customs authorities are increasingly verifying EPR registration at the time of import clearance. Without valid EPR registration, your import may be delayed or rejected at the port.

Q: What is the penalty for not registering under EPR?

Penalties under the Environment Protection Act include: fines up to Rs. 1 lakh per day of non-compliance, imprisonment up to 5 years, and court-directed suspension of manufacturing/import operations. CPCB can also direct customs to withhold clearance of future imports for non-compliant PIBOs.

Q: Do small importers also need EPR registration?

Yes. There is no minimum threshold exemption for importers under the EPR rules — all importers of covered product categories must register, irrespective of import volume. The EPR targets are set proportional to the import volume, so smaller importers have lower targets.

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Frequently Asked Questions

What is an IEC (Importer Exporter Code) and why is it mandatory in India?

An Importer Exporter Code (IEC) is a 10-digit identification number issued by the Directorate General of Foreign Trade (DGFT), Ministry of Commerce and Industry, Government of India. It is the primary business identification number required for any person or business engaged in import or export of goods and services.

IEC is mandatory because no import or export can be made without it (unless specifically exempted under the Foreign Trade Policy). It is required for Customs clearance, DGFT scheme applications, and receiving or making foreign trade payments through banks.

What are the main documents required for import-export in India?

Key documents for import-export operations in India include:

  • Shipping Bill (for exports) or Bill of Entry (for imports) — filed with Customs for clearance.
  • Commercial Invoice cum Packing List — details of goods, quantity, value, and packaging.
  • Bill of Lading / Air Waybill — transport document issued by the carrier.
  • Certificate of Origin (COO) — certifies the country of origin, needed for FTA benefits and some import requirements.
  • IEC Code — the importer/exporter identification number.
  • GST Invoice / LUT — for GST compliance on exports.
  • FSSAI Certificate — for food and agricultural imports.
  • BIS Certificate / NOC — for products under mandatory BIS certification.

What does DGFT do and why is it important for importers and exporters?

The Directorate General of Foreign Trade (DGFT) is the apex government body under the Ministry of Commerce and Industry responsible for formulating and implementing India's Foreign Trade Policy (FTP). Its key roles include:

  • Issuing and managing Importer Exporter Codes (IEC)
  • Administering export incentive schemes: Advance Authorisation, EPCG, RoDTEP, RoSCTL, SEIS
  • Granting export licences for restricted and SCOMET items
  • Issuing import licences for restricted items
  • Recognising Star Export Houses (status holders)
  • Fixing Standard Input Output Norms (SION)

Every Indian exporter and importer must interact with DGFT at some point — whether for obtaining an IEC, applying for export incentives, or seeking licences for restricted goods.

How can I find out if my product requires a special import licence in India?

India's import policy is classified under the ITC(HS) Classification of Export and Import Items published by DGFT. Every item has an import policy designation:

  • Free: Can be imported without any licence.
  • Restricted: Requires a specific import licence from DGFT before import.
  • Prohibited: Cannot be imported under any circumstances (e.g., beef in some categories).
  • Canalised: Can only be imported by government-designated agencies.

You can check the policy on the DGFT website by your ITC(HS) code, or contact Samarth EXIM for a free preliminary import policy check for your specific product.

What is the difference between Advance Authorisation and EPCG scheme?

Both are export promotion schemes under India's Foreign Trade Policy, but they serve different purposes:

  • Advance Authorisation (AA): Allows duty-free import of raw materials and inputs that are physically used in manufacturing export goods. The export obligation is the value of goods exported. Applicable before production.
  • EPCG (Export Promotion Capital Goods): Allows duty-free import of capital goods (machinery, equipment, tools) used in production of export goods. The export obligation is 6 times the duty saved, over 6 years.

They can be used together — EPCG for capital goods and Advance Authorisation for input materials — giving double duty savings on both machinery and raw materials.

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