Overview
Extended Producer Responsibility (EPR) makes the businesses that put products on the market responsible for collecting and recycling them at the end of their life. In India, EPR is set by rules under the Environment (Protection) Act, 1986, made by the Ministry of Environment, Forest and Climate Change (MoEFCC), and administered by the Central Pollution Control Board (CPCB).
Three regimes matter most to our clients:
- E-Waste (Management) Rules, 2022, in force from 1 April 2023, covering electrical and electronic equipment.
- Battery Waste Management Rules, 2022, covering all types of batteries, including those built into equipment and vehicles.
- Plastic Waste Management Rules, 2016, as amended, with the Guidelines on EPR for Plastic Packaging notified in 2022.
Registration and compliance take place online. CPCB has moved its separate portals onto a common EPR portal with single sign-on, reported at https://epr.cpcb.gov.in. E-waste EPR is handled on https://eprewaste.cpcb.gov.in, and CPCB’s main site is https://cpcb.gov.in. Beware of look-alike sites that are not run by CPCB.
Note: CPCB has been consolidating its EPR portals and revising targets, certificate pricing and environmental-compensation guidelines. Check the latest CPCB notices before relying on older guidance.
Who needs it
- Manufacturers of notified electrical and electronic equipment, batteries or plastic packaging.
- Producers, a term that includes importers and brand owners who sell under their own name, whoever made the goods.
- Online sellers and marketplaces, who are increasingly required to show EPR registration.
- Refurbishers, recyclers and processors, who register under separate categories.
Products covered
| Regime | What it covers | Examples |
|---|---|---|
| E-waste | Electrical and electronic equipment listed in the schedule to the rules | Laptops, phones, TVs, appliances, lighting, medical and IT equipment |
| Batteries | Portable, automotive, industrial and electric-vehicle batteries | Li-ion packs, lead-acid batteries, button cells, batteries inside devices |
| Plastic packaging | Rigid, flexible and multilayer plastic packaging, and carry bags | Product packaging, e-commerce packaging, labels and wrappers |
The product schedules are set out in each set of rules, available on the MoEFCC and CPCB websites.
Documents required
- Company incorporation documents, PAN and GST registration
- Importer-Exporter Code (for importers)
- Authorised signatory details and authorisation letter
- Product or packaging list with categories, codes and quantities placed on the market in previous years
- Details of sales channels and states of sale
- For e-waste: technical documentation supporting RoHS compliance
- EPR plan or declaration in the format each rule requires
- Agreements or arrangements with registered recyclers, where applicable
Process
- Map your obligations. Identify which products and packaging fall under which rule, and your category (manufacturer, producer, importer, brand owner).
- Collect data. Compile quantities placed on the market by category and year, which determine your targets.
- Register on the CPCB portal. Create the account, enter company and product data, upload documents and pay the fee.
- Scrutiny and grant. CPCB reviews the application and may raise queries before granting registration.
- Plan target fulfilment. Arrange EPR certificates from registered recyclers or processors to meet annual targets.
- File returns. Submit periodic returns on the portal and keep records for audit.
Validity, renewal & surveillance
EPR is a continuing obligation, not a one-time certificate. Registrations must be kept valid and updated when product lines change, and targets rise over time. For example, e-waste recycling targets step up across the years set in the 2022 rules. CPCB checks compliance through the portal data and can audit producers. Shortfalls attract environmental compensation under CPCB guidelines.
Note: Registration fees, processing fees and environmental-compensation rates are set by CPCB and revised from time to time. We’ll share a current fee estimate for your categories.
How Aaditech helps
Aaditech helps manufacturers, importers and brand owners with EPR alongside their BIS and BEE approvals, so the same product data serves every filing. Our team is led by former Directors of the Bureau of Indian Standards and understands electrical and electronic products in technical detail.
- Obligation mapping across e-waste, battery and plastic packaging rules for your full product range.
- Data preparation: quantities, categories and codes in the form the portal expects.
- Portal registration and query handling with CPCB.
- Target planning: estimating annual obligations and arranging certificates through registered recyclers.
- Returns and records: periodic filings and an audit-ready record set.
- RoHS link-up: technical documentation for hazardous-substance compliance.
Our clients include Acer, KENT RO, Havells, Amazon and Flipkart. Contact us for an EPR obligation review.
