EPR Registration for Importers in India
Importers of electronics, batteries and anything in plastic packaging carry Extended Producer Responsibility. Here is which CPCB registrations apply, how to register, and the yearly targets and returns.
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Short answer: if you import electrical or electronic goods, batteries (including batteries inside equipment), or any goods in plastic packaging, Indian law treats you as a producer or importer for Extended Producer Responsibility (EPR). You must register on the matching CPCB EPR portal before you sell, meet a yearly recycling target by buying EPR certificates from registered recyclers, and file returns. Most electronics importers need two or three registrations.
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Reviewed by Prashant Dwivedi, Co-Founder, iKargos · Last reviewed
Which EPR registrations does an importer need?
| If you import… | You are a… | Rules | CPCB portal | Our guide |
|---|---|---|---|---|
| Goods in plastic packaging, or plastic packaging itself | Importer (I): "a person who imports plastic packaging product or products with plastic packaging or carry bags or multilayered packaging or plastic sheets or like" | Plastic Waste Management Rules 2016, EPR Guidelines for Plastic Packaging (G.S.R. 133(E), 2022) | eprplastic.cpcb.gov.in | Plastic packaging EPR |
| Electrical & electronic equipment listed in Schedule I, incl. parts, spares, consumables; or used EEE | Producer: includes anyone who "offers to sell imported electrical and electronic equipment" or "imports used electrical and electronic equipment" | E-Waste (Management) Rules 2022 (G.S.R. 801(E)), in force 1 Apr 2023 | eprewaste.cpcb.gov.in | E-waste EPR |
| Batteries, or equipment containing batteries | Producer: importers of batteries and of equipment containing batteries are producers (Rule 3(1)(u)) | Battery Waste Management Rules 2022 (notified 22 Aug 2022) | eprbattery.cpcb.gov.in | Battery EPR |
| Tyres | see our tyre guide | Hazardous and Other Wastes Rules 2016, amended 2022 (tyre EPR) | eprtyres.cpcb.gov.in | Tyre EPR |
| Lubricating / base oil | see our used-oil guide | Hazardous and Other Wastes Second Amendment Rules 2023 (used-oil EPR) | eprusedoil.cpcb.gov.in | Used-oil EPR |
A laptop importer, for example, is a producer under the e-waste rules (the laptop), a producer under the battery rules (the battery inside it), and an importer under the plastic rules (the packaging). Importing end-of-life-regulated vehicles? See EPR for end-of-life vehicles.
How to register on a CPCB EPR portal
- Work out your streams using the table above, by product and by packaging.
- Open the matching CPCB portal and choose your role: Importer (plastic) or Producer (e-waste, battery).
- Fill the application. The battery portal pre-fills company details from your GST number. Keep your IEC, GST, PAN, authorised signatory details and product list with quantities ready.
- Pay the CPCB fee. The rules let CPCB charge registration and annual processing fees by procedure; the amounts are set by CPCB, not printed in the rules.
- Get the registration certificate. Plastic packaging: the guidelines say registration "shall be done within two weeks from the submission of a complete application". Battery: the certificate is issued in Form 1(B) after the application in Form 1(A).
- Every year: report the quantity you placed on the market, buy EPR certificates from registered recyclers to meet your target, and file returns on time (next section).
EPR targets for importers
Plastic packaging (importer): the target is a share of Q2, the average weight of plastic packaging imported and sold in the last two financial years (plus pre-consumer waste, minus quantity supplied to other obligated entities).
| Year | Target (% of Q2, category-wise) |
|---|---|
| 2021-22 | 25% |
| 2022-23 | 70% |
| 2023-24 onwards | 100% |
The guidelines also set a minimum recycling share of that target, by category:
| Category | 2024-25 | 2025-26 | 2026-27 | 2027-28+ |
|---|---|---|---|---|
| I Rigid | 50% | 60% | 70% | 80% |
| II Flexible | 30% | 40% | 50% | 60% |
| III Multilayer | 30% | 40% | 50% | 60% |
| IV Compostable | 50% | 60% | 70% | 80% |
E-waste (producer), Schedule III: recycling target by weight, as a share of the EEE placed on the market in year Y−X, where X is the product's average life.
| Year | Target |
|---|---|
| 2023-24, 2024-25 | 60% |
| 2025-26, 2026-27 | 70% |
| 2027-28 onwards | 80% |
- New producers (selling for fewer years than the product's average life) follow Schedule IV: 15% of FY 2021-22 sales in 2023-24, 20% of FY 2022-23 sales in 2024-25, then 20% of sales two years back.
- Importers of used EEE carry 100% EPR obligation for that material at end of life, unless it is re-exported.
Batteries: targets are set per battery type in the Battery Waste Management Rules 2022 schedules. See our battery EPR guide.
As notified in 2022. The e-waste rules were amended in 2023 (twice) and 2024; check the current text before relying on a figure.
Annual and quarterly return deadlines
| Stream | What to file | Due |
|---|---|---|
| Plastic packaging | Annual return on the portal | 30 June of the next financial year |
| E-waste | Quarterly and annual returns | End of the month after the quarter or year ends |
| Batteries | EPR plan (Form 1(C)) and annual return (Form 3) | 30 June of the next financial year |
Does customs check EPR registration?
- Batteries: on 23 Dec 2022, CPCB wrote to the Customs directorate (CBIC) asking that officials verify the CPCB registration certificate of battery importers at the time of clearing the consignment.
- E-waste: CPCB's notices page lists letters to Customs in 2023 and 2024 on releasing imported consignments of registered producers of 85, and later 106, EEE items. The e-waste rules also let CPCB "take help of Customs" for compliance checks (Schedule V).
So, register before your first shipment of covered goods. Importing electronics? They may also need BIS: check your product with our BIS checker.
What if an importer doesn't comply?
Environmental Compensation is levied on the "polluter pays" principle for not meeting EPR targets (plastic guidelines §9; e-waste rule 22; battery rule 13). CPCB can also revoke a registration obtained with false information.
Exemptions worth knowing
- The e-waste rules do not apply to micro enterprises (as defined under the MSMED Act 2006). They also exclude waste batteries and packaging plastics, which have their own rules.
- Under the plastic guidelines, micro and small enterprises are excluded from the brand-owner category only. Importers are not exempted on that basis.
Frequently asked questions
Do importers need EPR registration in India?
Which CPCB portal should an importer use?
Is EPR registration needed for batteries inside imported equipment?
How long does plastic EPR registration take?
When is the EPR annual return due?
What is the EPR target for plastic packaging importers?
Does customs check EPR registration at import?
Can importers of used electronics register under EPR?
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