Plastic Waste Management Certificate : Extended Producer Responsibility (EPR) Part 2

This article is the second part of our EPR blog series. It focuses on the Plastic Waste Management Certificate and the process for obtaining EPR authorization in India.

In Part 1, we covered EPR requirements for E-Waste Management Certificate, read here https://www.consultancycounsel.com/post/extended-producer-responsibility-epr-part-1-e-waste-management-certificate

In Part 3, we cover EPR requirements for Battery Waste Management Certificate, read here

https://www.consultancycounsel.com/post/battery-waste-management-certificate-extended-producer-responsibility-epr-part-3

Introduction

Plastic waste is piling up across India, with millions of tonnes generated every year, clogging our rivers, landfills, and streets. From single-use bags to packaging, plastic is everywhere, and its persistence in the environment taking hundreds of years to break down thereby posing a massive threat to ecosystems and human health. To tackle this crisis, India’s regulations put the responsibility squarely on those who produce or import plastic products. This is where Extended Producer Responsibility (EPR) comes in. 

EPR is a policy that makes producers, importers & brand owners accountable for managing their products’ waste, from production to disposal, including collection, recycling, and safe handling. For plastic waste, this means companies must register with the Central Pollution Control Board (CPCB) to get an EPR authorization, ensuring they play their part in reducing plastic pollution. Let’s break down what this means, why it matters, and how it works.

Plastic Waste Management Rules, 2016

The governing body for regulation of EPR and grant of certificate is Central Pollution Control Board (CBCB) at central level and Pollution Control Committees (PCCs) or State Pollution Control Board (SPCB) at state level. Plastic Waste Management Rules form the foundation of India’s Extended Producer Responsibility (EPR) framework. 

These rules are periodically amended to address emerging challenges and ensure effective, up-to-date solutions for managing plastic waste. The rules are designed to ensure that plastic producers and users take responsibility for the entire lifecycle of the plastic they introduce. This includes collection, recycling, and environmentally sound disposal.

Who is it for

These rules apply to every Producer, Importer, Brand owner (PIBOs), Plastic Waste Processors (PWPs);

Producer (P) : Anyone who manufactures or imports carry bags, multilayered packaging, plastic sheets, or similar items. It also includes businesses or individuals that use plastic sheets or multilayered packaging to package or wrap their products.

Importer (I) : A person or company that brings goods into the country and holds a valid Importer-Exporter Code (IEC), unless specifically exempted.

Brand Owner (BO) : Any person or company that sells products under a registered brand name or label.

Plastic Waste Processors (PWP) : Entities involved in recycling, waste-to-energy conversion, waste-to-oil processes and industrial composting also need to register

Validity

The validity period for a fresh registration is for a period of one year and for a renewed registration the validity is shall be for a period of three years.

Renewal

The renewal of EPR registration for PIBOs requires submitting the application along with necessary documents at least four months before the expiry of the current registration. It is mandatory that all annual reports for the intervening registration period are filed by June 30 of the following year, as per EPR Guidelines, since renewal applications will not be processed otherwise. Additionally, audit report findings are considered during the renewal process. Upon receipt of complete documents from Producers and Brand Owners, the registration is renewed typically within 15 days.

Plastic Packaging Categories 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

Registration Process

Getting an EPR certificate for plastic waste is a structured process, mostly handled through the CPCB’s online portal. Here’s how it works:

1. Registration with CPCB Portal

First step is to register with CPCB’s centralized EPR portal for plastic packaging. This digital platform is where businesses submit applications and track compliance.

2. Portal-Based Application

First, identify whether you are a producer, importer, brand owner, or recycler. Provide details about the types of plastic packaging you handle and the scale of your operations. Enter all technical and comprehensive information accurately to prevent delays or queries from the authorities.

3. Documentation and Compliance

Upload documents proving your business’s legitimacy, operational capacity, and a solid plan for collecting and recycling plastic waste. This includes details on how you’ll meet EPR targets, like collection and recycling quotas, and partnerships with authorized recyclers.

4. Physical Follow-Ups Requirement

While the process is mostly online, CPCB or SPCB may ask for physical verification, facility inspections, or clarifications to ensure you’re ready to handle plastic waste responsibly.

5. Ongoing Compliance

Once registered, you must keep detailed records of plastic waste collected, recycled, or disposed of. Annual and quarterly reports are submitted via the CPCB portal to show you’re meeting targets and staying compliant.

How CCC Can Help Navigating the EPR process

CCC can handle the technical documentation, portal submissions, and coordination with recyclers and authorities, ensuring your registration is smooth and stress-free. We also help with ongoing compliance, so you can focus on your business while staying on the right side of the law.

Benefits of Plastic Waste Management Certificate

Securing an EPR certificate comes with real advantages such as:

1. Legal Safety & Avoidance of Penalties

Compliance with the Plastic Waste Management Rules keeps you safe from fines and other legal hassles. The 2025 amendments introduced stricter penalties under Rule 19, including fines and stricter penalties for serious violations.

2. Permission to Operate & Market Access

An EPR certificate allows you to legally manufacture, import, or sell products with plastic packaging in India, ensuring no regulatory roadblocks.

3. Enhanced Brand Image & Trust

Showing you are EPR-certified signals to customers, partners, and investors that you’re serious about sustainability. It’s a badge of environmental responsibility that builds trust.

4. Environmental Protection

By following EPR guidelines, you ensure plastic waste is collected, recycled, or disposed of properly, reducing pollution in soil, water, and air.

5. Better Regulatory & Operational Planning

EPR forces you to plan your waste management processes, from collection to recycling. This streamlines operations, prepares you for audits, and makes compliance easier.

Post EPR Certificate Compliances

Getting the certificate is just the start. Here’s what you need to do to stay compliant:

1. Adherence to Approved EPR Plan

Follow the collection and recycling plan approved by the CPCB, using only authorized collection centers, dealers, or take-back systems for plastic waste.

2. Collection & Recycling Targets

Meet the CPCB’s year-wise targets for collecting and recycling plastic waste. Keep verifiable records of waste transferred to authorized recyclers.

3. Quarterly & Annual Returns

Submit detailed reports on the CPCB portal about the plastic waste you’ve collected, recycled, or disposed of, along with invoices and recycler certificates, within deadlines.

4. Record Maintenance

Keep records of all plastic waste activities like generation, collection, storage, transport, and recycling and ensure documentation is accessible for audits.

5. Authorised Recycler Engagement

Work only with CPCB/SPCB-authorized recyclers and obtain valid recycling certificates to claim EPR credits on the portal.

6. Safe Storage & Handling

Store plastic waste in an environmentally safe way, with proper labeling to prevent leaks or mismanagement until it’s handed over to recyclers.

7. Consumer Awareness

Run campaigns to educate consumers about proper plastic waste disposal. Share details of collection centers or take-back systems on your website, packaging, or product manuals.

8. Renewal & Audit

Apply for certificate renewal before it expires and cooperate with CPCB/SPCB inspections or audits, providing all required records promptly.

Conclusion

Extended Producer Responsibility (EPR) for plastic waste is not just a mere regulatory requirement. By getting an EPR certificate, your business stays compliant, reduces environmental harm, and builds a reputation as a responsible player in the fight against plastic pollution. With CCC by your side, we will handle the complexities, from registration to compliance, so you can focus on growing your business while keeping India cleaner and greener.