EPR Compliance

Overview

Extended Producer Responsibility requires every producer, importer and brand owner (PIBO) to take responsibility for the end-of-life waste generated by the products and packaging they put on the Indian market. The framework is administered by the Central Pollution Control Board (CPCB) and enforced through the State Pollution Control Boards, under rules notified by the Ministry of Environment, Forest and Climate Change.

Five waste streams are currently regulated: plastic packaging (rigid, flexible, multi-layered), e-waste under the E-Waste Management Rules 2022, battery waste (lithium-ion, lead-acid, portable, EV), used tyres, and used oil. Each stream has its own registration category, annual collection and recycling targets, and reporting calendar.

The compliance sequence is straightforward on paper: register on the CPCB portal, calculate your annual targets based on the volume you placed on the market, acquire EPR certificates from authorized recyclers or processors, file periodic returns, and maintain traceability records. In practice, the portal's workflows, certificate verification processes, and shifting target schedules mean most PIBOs need someone tracking this full-time. Saanvi Advisory handles the registration and ongoing compliance so the business can focus on operations.

What’s Included

• CPCB Portal Registration. Preparing and filing the EPR registration or authorization application on the Central Pollution Control Board's online portal, mapped to the correct waste-stream category.
• Target Calculation. Working out the annual collection, recycling and recovery targets based on the weight and volume of regulated products placed on the Indian market during the financial year.
• EPR Certificate Procurement. Sourcing verifiable digital EPR certificates from CPCB-authorized recyclers, dismantlers and processors to meet the year's targets.
• Returns & Compliance Reporting. Filing mandatory annual returns and action plans with CPCB and the relevant State Pollution Control Board, detailing collection and recycling volumes.
• Traceability & Audit Readiness. Setting up QR-coded or barcoded tracking for plastic packaging where applicable, and maintaining verified credit chains that hold up under a compliance audit.
• Penalty Prevention. Monitoring target shortfalls before they trigger Environmental Compensation levies, registration suspension, or prosecution under the Environment Protection Act, 1986.

Engagement Process

1. Applicability Assessment

   Identifying which waste streams apply, confirming the registration category, and mapping the annual target calendar.

2. Registration & Target Setting

   Filing on the CPCB portal, securing authorization, and calculating the first year's targets.

3. Certificate Procurement & Filing

   Acquiring EPR certificates, filing periodic returns, and closing out the financial year's compliance cycle.

4. Ongoing Compliance Monitoring

   Tracking target changes across annual cycles, renewing registrations, and maintaining audit-ready documentation.

Who This Is For

Producers, importers and brand owners placing products or packaging in any of the five regulated waste streams on the Indian market. This includes manufacturers of electronics, batteries, tyres and plastic packaging, as well as importers and companies selling under their own brand name.