FAQ

Registration of PIBO / PWP as per EPR Guidelines

Notified by MoEF&CC โ€“ Frequently Asked Questions for Producers, Importers, Brand Owners, and Plastic Waste Processors

1 What is Extended Producer Responsibility (EPR)?

EPR means the responsibility of a producer for the environmentally sound management of the product until the end of its life.

2 Have EPR Guidelines been notified by Government?

Yes. MoEF&CC vide Fourth Amendment to Plastic Waste Management Rules 2016 notified EPR Guideline on February 16, 2022.

3 Which entities shall register on the centralized portal developed by CPCB?

The following entities shall register on the centralized portal developed by CPCB:

  • Producer (P)
  • Importer (I)
  • Brand Owner (BO)
  • Plastic Waste Processor engaged in:
    • (a) Recycling
    • (b) Waste to Energy
    • (c) Waste to Oil
    • (d) Industrial Composting
4 What assistance is provided for filling of application?
  • ๐Ÿค– AI Chatbot provided at the right side of the login and sign-up page of the portal.
  • ๐Ÿ“ž Helpline no.: 011-43102469
  • โ„น๏ธ i-button with assisting provided in specific sections
  • ๐Ÿ“„ Standard Operating Procedure uploaded on website
  • ๐Ÿ“„ Instruction sheet for filing of application uploaded on website
5 Which PIBOs are required to register with SPCB/PCC?

PIBOs which are operational in one or two states/UTs are required to register with the concerned SPCB/PCC.

6 Which PIBOs are required to register with CPCB?

PIBOs which are operational in more than two states/UTs are required to register with CPCB.

Note: Brand Owners (BO) including online platforms/marketplaces and supermarkets/retail chains other than those, which are Micro and Small Enterprises as per the criteria of Ministry of Micro, Small and Medium Enterprises, Government of India.

For details Section 3 & 4 of aforementioned EPR Guidelines may be referred to.

7 What are the documents required for KYC for registration of PIBOs?

Required Documents:

  • PDF copy of Company's PAN, CIN & GST (combined copies of GST invoices in all States/UTs where the PIBO is operating)
  • PDF copy of Authorized person's PAN & Aadhar

Note: Proprietorship and partnership firms shall provide PAN and GST number for registration on EPR portal. CIN number is applicable for the companies registered with Ministry of Corporate Affairs.

8 Which are the plastic packaging categories covered under EPR?

Category I: Rigid plastic packaging

Category II: Flexible plastic packaging of single layer or multilayer (more than one layer with different types of plastic), plastic sheets or like and covers made of plastic sheet, carry bags, plastic sachet or pouches

Category III: Multilayered plastic packaging (at least one layer of plastic and at least one layer of material other than plastic)

Category IV: Plastic sheet or like used for packaging as well as carry bags made of compostable plastics

For details please refer EPR Guidelines (Section 5)

9 What is Pre-consumer plastic packaging waste?

Pre-consumer plastic packaging waste means plastic packaging waste generated in the form of reject or discard at the stage of manufacturing of plastic packaging and plastic packaging waste generated during the packaging of product including reject, discard, before the plastic packaging reaches the end-use consumer of the product.

10 What is Post-consumer plastic packaging waste?

Post-consumer plastic packaging waste means plastic packaging waste generated by the end-use consumer after the intended use of packaging is completed and is no longer being used for its intended purpose.

11 What is EPR target for Producers & Importers?

EPR target is the plastic waste which is introduced in the market by the PIBO. Details given in section 7 of the EPR Guidelines may be referred to.

12 Whether all PIBOs are required to submit Consent granted under Air & Water Act?

All producers are required to submit the consents issued to their production facilities. Brand-owners having their own production facilities are required to submit the consents.

13 What shall be liabilities of producer/importer in case concerned Brand owners are currently not registered on the centralized EPR portal?

The producer/importer may register on the said portal and their liabilities for fulfilling of EPR target to be adjusted during filling of Annual report on the portal if the concerned Brand owners are currently not registered on the centralized EPR portal.

14 What shall be EPR liabilities of any entity if it falls under the category of brand owner as well as importer?

The entity first has to register as a brand owner and provide the entire details in terms of plastic waste generation including imported plastic by the firm. After registration as brand owner the entity shall register as importer, provide details of imported plastics and the imported material sold to the said brand owner. Therefore zero liabilities has to be fulfilled by the firm as importer.

15 Are units engaged in export exempted from fulfilling EPR Obligations?

Yes. Export oriented units are exempted from fulfilling EPR obligations.

16 Which category of PIBOs are exempted from fulfilling EPR obligation?

The Micro & Small category of Brandowners are exempted from fulfilling EPR obligation. Remaining all entities are required to be registered on Centralized EPR portal in line with notified EPR Guidelines.

17 How much application fees / annual processing / renewal fees to be paid for Registration of PIBOs/ PWP?

a. Application fees for Registration of PIBOs

Sl. No.PW Generation Slab (TPA)Processing Fees (โ‚น)
1< 100010,000
21000 โ€“ 1000020,000
3> 1000050,000

b. Application fees for Registration of PWP

Sl. No.Production capacity Slab (TPA)Processing Fees (โ‚น)
1< 2005,000
2200 โ€“ 200020,000
3> 200050,000

c. Renewal fees: Same as Registration fees

d. Annual Processing Fees: 25% of Application fees (for PIBOs as well as PWP)

18 What shall be proceedings in case of rejection of application?
  • If entity is operating in one State/UT or more than two states/UTs: The applicant has to apply for fresh application on the portal with same login credential and repay the applications fees as per SOP.
  • If entity is operating in two States/UTs: The applicant has to apply for fresh application on the portal with same login credential and repay the applications fees as per SOP. In case application is rejected by one or both State/UTs.
19 Do PIBOs who have obtained a valid CPCB/SPCB/PCC registration also need to apply on the Centralized EPR Portal?

Yes. All the PIBOs need to apply on the Centralized EPR portal with necessary application fee.

20 Our entity collects plastic waste; do we need to register as PWP?

Only entities engaged in plastic waste processing (recycling, co-processing, waste to energy, waste to oil) have to be registered as PWP.

21 What if PIBO has inhouse recycling unit for their packaging plastic?

PIBO will have to register as PIBO and as Recycler both with relevant documentation. Credits can only be issued to recyclers and transaction of credits to PIBO shall be documented.

22 What are the documents required to register on the centralized portal, if entity falls in more than one sub category?
  • Different email id is required to register in each category.
  • Company KYC (Company's PAN, GST & CIN) documents shall be same for each category.
23 What shall be proportion of plastic waste in Municipal Solid Waste (MSW) in case of co-processing and incineration?

Equivalent quantity of plastic shall be considered for generation of EPR Certificates. Characterization of waste may be carried out to determine the actual plastic quantity. As per report titled "Assessment & Characteristics of Plastic Waste generated in 60 cities", published by CPCB, average plastic waste generation is around 6.92% of MSW. In absence of actual characterization, this average plastic percentage shall be considered for the purpose.

24 What material is to be considered for EPR in case of MLP (at least one layer of plastic and at least one layer of material other than plastic)?

As per OM dated 03-02-2023 published by MoEF&CC, "EPR target is on weight basis, while registering for EPR of multi-layered plastic packaging, in which plastic sheet or like, is a part, the complete weight of multi-layered plastic packaging will be covered under EPR".

25 What is the EPR liability associated with third party manufacturer of products?

If the third party does not have a brand name associated with them, the EPR liabilities are to be taken by the concerned Brand Owners/Producers to whom the product is being sold.

26 What is the definition of "Operations" for PIBOs?

Operation means selling of plastic packaging product or products with plastic packaging or carry bags or multilayered packaging or plastic sheets or like into the Indian Market.

27 What is the definition of "Raw material" for Brand owners, Producer & Importer?

Raw material for Brand owner and importer is plastic packaging of products or carry bags or multilayered packaging or plastic sheets or like.

Raw material for Producer is resin/granules being used to manufacture carry bags or multilayered packaging or plastic sheets or like.

28 We do not import plastic packaging but products with plastic packaging โ€“ what information should we submit?

Details of plastic packaging which is imported along with the product is to be given in this section.

Note: The weight of the plastic packaging (including all layers) must be reported, not the weight of the entire product.

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Why You Must Act Now (Lessons from 2025)

โฑ๏ธ

Early Preparation is Key

Many PIBOs underestimated the time required to collect, validate, and categorize packaging data. Those who began early met deadlines with confidence.

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๐Ÿ“Š

Finance Teams Need Forecasting

EPR fees are now a measurable line item. Collaboration between sustainability, legal, and finance is critical.

๐Ÿ’ก Align budgets & cycles

๐ŸŽฏ

Packaging Data Accuracy Matters

Many producers struggled with inaccurate weights or missing supplier data, leading to massive financial risks.

๐Ÿ’ก Use 3rd-party expert reviews

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Complex Portfolios Need Tailored Approaches

Multi-brand companies face challenges consolidating packaging data across varying material types and categories.

๐Ÿ’ก Require a customized data model

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