EPR โ Extended Producer Responsibility
End-to-end EPR compliance across plastic packaging, e-waste, batteries, tyres, used oil, and end-of-life vehicles โ from CPCB registration to target fulfilment, return filing, and credit trading.
EPR Made Simple โ So You Can Focus on Your Business
Extended Producer Responsibility (EPR) places legal responsibility on producers, importers, and brand owners to ensure their products โ and the waste they generate โ are collected and managed at end-of-life. Since 2022, EPR has become mandatory for plastic packaging, e-waste, and battery waste categories under India's revised rules.
Non-compliance carries severe penalties including cancellation of licences, hefty fines, and public naming. Greenovate has helped 200+ companies establish compliant EPR systems โ from those new to the obligation to those looking to optimise their existing programmes.
EPR Categories We Handle
Full-Spectrum EPR Services
End-to-end EPR compliance for Producers, Importers & Brand Owners (PIBOs)
Upcoming Deadlines
Action RequiredAnnual EPR returns for FY 2025โ26 are due by June 30, 2026. Contact us now to ensure timely filing and avoid penalties.
Book a Free Consultation โDetailed EPR Compliance
Click any category below to expand requirements, targets, penalties, and how Greenovate manages your EPR obligation end-to-end.
What is it?
Under Plastic Waste Management Rules 2016 (amended 2022), all Producers, Importers, and Brand Owners (PIBOs) of plastic packaging must register on the CPCB EPR portal and annually demonstrate collection and recycling of the plastic they place on the Indian market.
Why is it required?
India generates over 35 lakh tonnes of plastic waste annually. CPCB has made EPR mandatory to shift financial and operational responsibility for end-of-life plastic from municipalities to producers โ enforcing the "polluter pays" principle.
EPR Target Obligation
| Plastic Category | FY 25โ26 | FY 26โ27 | FY 27โ28 | FY 28โ29+ |
|---|---|---|---|---|
| Rigid Plastic Packaging | 60% | 70% | 80% | 90% |
| Flexible Plastic Packaging | 45% | 60% | 75% | 90% |
| Multilayer Plastic Packaging | 40% | 55% | 70% | 90% |
| PET Bottles & Containers | 70% | 80% | 85% | 90% |
Penalty for Non-Compliance
- Environmental Compensation (EC) per kg of shortfall โ calculated based on cost of plastic waste management
- CPCB show-cause notice followed by suspension / cancellation of EPR registration
- Inability to operate legally as a producer/importer without valid EPR registration
- Public disclosure of non-compliant PIBOs on CPCB portal
How Greenovate Helps
- CPCB EPR portal registration โ producer / importer / brand owner categorisation
- Plastic placed-on-market (POM) quantity estimation per category (rigid, flexible, multilayer, PET)
- Annual EPR target calculation and gap analysis
- PRO identification, due diligence, and empanelment agreements
- EPR credit purchase reconciliation and shortfall avoidance
- Quarterly and annual CPCB return filing with audit trail
What is it?
Under E-Waste (Management) Rules 2022, producers and importers of Electrical and Electronic Equipment (EEE) โ including IT equipment, consumer electronics, large appliances, solar panels, and medical devices โ must register on the CPCB portal, set annual collection targets, and ensure recycling through CPCB-authorised dismantlers/recyclers via an EPR credit mechanism.
Why is it required?
India is the world's third-largest e-waste generator, producing over 16 lakh tonnes annually. Only 22% is formally recycled. CPCB's credit-based EPR system incentivises formal recycling by creating an auditable, market-based mechanism for producers to fund and verify waste collection.
EPR Target Obligation
- FY 2023โ24 โ 60%
- FY 2024โ25 โ 70%
- FY 2025โ26 โ 80%
- FY 2026โ27 โ 90%
- FY 2027โ28+ โ 100%
- Credits purchased from CPCB-registered recyclers
- Annual return by 31 March each year
- Quarterly progress updates on portal
- Recycled content in new EEE (from 2026)
- Solar panel & EV battery covered separately
Penalty for Non-Compliance
- Environmental Compensation per tonne of EPR shortfall โ payable to CPCB Environment Fund
- Suspension of EPR registration, preventing legal import/sale of EEE
- CPCB show-cause notice published on national portal
- Seizure of EEE at ports for unregistered importers
How Greenovate Helps
- CPCB portal registration โ categorisation per EEE Schedule I
- Placed-on-market (POM) volume calculation per equipment category
- Authorised e-waste recycler / dismantler network empanelment
- EPR credit purchase strategy โ minimise cost while meeting targets
- Quarterly progress tracking and annual return filing
- Solar PV module EPR compliance support
What is it?
Under Battery Waste Management Rules 2022, producers and importers of portable, automotive, industrial, and EV batteries must register on the CPCB portal and ensure their batteries are collected at end-of-life and recycled through CPCB-authorised recyclers โ with phase-wise collection targets and mandatory recycled content in new batteries.
Why is it required?
Battery waste contains hazardous heavy metals (lead, cadmium, lithium, cobalt) that contaminate soil and groundwater if improperly disposed. India's rapid EV growth makes battery EPR critical โ estimated 1 lakh tonnes of EV battery waste by 2030 demands a formal collection infrastructure built today.
EPR Target Obligation
| FY 23โ24 | 25% |
| FY 24โ25 | 40% |
| FY 25โ26 | 60% |
| FY 26โ27 | 80% |
| FY 28โ29+ | 100% |
| FY 23โ24 | 70% |
| FY 24โ25 | 80% |
| FY 25โ26 | 90% |
| FY 26โ27+ | 100% |
| FY 23โ24 | 90% |
| FY 24โ25+ | 100% |
| By 2026 | 5% |
| By 2028 | 10% |
| By 2030 | 15% |
| EV Recyclability | 60% |
Penalty for Non-Compliance
- Environmental Compensation: โน5,000 per tonne shortfall for portable batteries; โน10,000 per tonne for industrial/automotive
- CPCB show-cause notice and EPR registration suspension
- Failure to meet recycled content targets: Additional EC levied from 2026
- EV manufacturers face dual penalty โ collection shortfall + recycled content default
How Greenovate Helps
- CPCB portal registration โ all battery categories (portable, automotive, industrial, EV)
- Battery placed-on-market (POM) quantity calculation and phase-wise target planning
- CPCB-authorised battery recycler and refurbisher network empanelment
- EPR credit reconciliation โ collection vs. target gap tracking
- Annual return filing and compliance documentation
- Recycled content certification and source tracking support
What is it?
Under the Waste Tyre Management framework and CPCB's EPR guidelines, tyre producers and importers must register on the CPCB portal and ensure that a specified percentage of tyres placed on the Indian market is collected at end-of-life and processed through authorised retreaders, pyrolysis units, cement co-processors, or crumb rubber manufacturers.
Why is it required?
India discards over 12 lakh tonnes of waste tyres annually. Uncontrolled burning releases highly toxic dioxins and furans classified as persistent organic pollutants. CPCB's EPR framework creates a structured channel for collection, retreading, and energy recovery โ replacing illegal dumping and burning.
EPR Target Obligation
| Financial Year | Target |
| FY 2023โ24 | 60% |
| FY 2024โ25 | 80% |
| FY 2025โ26 onwards | 100% |
- Retreading & retread tyre manufacturing
- Pyrolysis (oil recovery) โ CPCB guidelines
- Cement kiln co-processing (TDF)
- Crumb rubber manufacturing (sports / infill)
- Steel wire recovery & recycling
Penalty for Non-Compliance
- Environmental Compensation for shortfall in collection targets
- CPCB show-cause and suspension of EPR registration
- Seizure of waste tyres stored beyond 90 days without authorisation
- Criminal prosecution for illegal burning under EP Act 1986
How Greenovate Helps
- CPCB portal registration for tyre producers and importers
- Placed-on-market (POM) tyre quantity estimation (SKU-wise)
- Authorised retreader, pyrolysis unit, and co-processor empanelment
- Collection logistics planning and waste tyre generator tie-ups
- EPR credit reconciliation and annual return filing
- Co-processing agreement structuring with cement plants
What is it?
Under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules 2016 and CPCB's Used Oil EPR framework, producers and importers of lubricating oils, transformer oils, and hydraulic fluids must register on the CPCB EPR portal and ensure used oil is collected and re-refined only through CPCB-authorised re-processors โ preventing hazardous dumping and illegal burning.
Why is it required?
Used oil is classified as hazardous waste under Schedule I of HW Rules. India generates over 1.5 lakh tonnes of used/waste oil annually. Indiscriminate burning (common in small workshops) releases carcinogenic polycyclic aromatic hydrocarbons (PAHs) and heavy metals. EPR makes lubricant producers responsible for proper end-of-life management of the waste their product generates.
EPR Target Obligation
| Year | Target |
| FY 2024โ25 | 30% |
| FY 2025โ26 | 50% |
| FY 2026โ27 | 65% |
| FY 2027โ28+ | 75% |
- Register on CPCB EPR portal as lubricant producer / importer
- Declare volume placed on market (POM) annually
- Collection only through CPCB-authorised re-refiners
- Annual return filing with collection quantity proof
- SPCB HW authorisation if storing used oil on-site
- Consignment notes (Form 6/7) for all transfers
Penalty for Non-Compliance
- HW Rules violation: Up to โน1 crore fine + 7 years imprisonment
- Environmental Compensation for shortfall in collection targets
- CPCB show-cause notice and EPR registration suspension
- SPCB inspection and closure orders for unauthorised on-site accumulation
- Directors' personal liability under EP Act 1986
How Greenovate Helps
- CPCB EPR portal registration for lubricant producers/importers (automotive, industrial, marine)
- Annual placed-on-market (POM) volume estimation per oil category
- CPCB-authorised re-refiner identification, evaluation, and empanelment
- Collection logistics and consignment note (Form 6/7) management
- Annual EPR return filing and compliance calendar management
- SPCB HW authorisation support if on-site used oil storage is involved
What is it?
Under the End-of-Life Vehicles (Management) Rules 2025 (notified by MoEFCC), automobile producers and importers must register on the CPCB EPR portal and establish take-back systems ensuring end-of-life vehicles are processed only at Registered Vehicle Scrapping Facilities (RVSFs) โ with mandatory depollution (removal of fluids, batteries, tyres, and catalysts) before metal shredding.
Why is it required?
India has over 50 lakh vehicles past their fitness certificate limit, leaking hazardous fluids including engine oil, coolant, brake fluid, and refrigerant. Informal scrapping without depollution contaminates soil and groundwater. ELV EPR shifts responsibility to vehicle manufacturers to fund safe, formal scrapping through the RVSF network โ a completely new producer obligation for automakers.
EPR Target Obligation
| Milestone | Date |
| CPCB portal registration | FY 2025โ26 |
| Phase 1 take-back targets | FY 2026โ27 |
| Full EPR obligations | FY 2027โ28 |
| Recycled content targets | By 2030 |
- Register all vehicle models on CPCB portal
- Annual POM (units sold) report per segment
- ELV collection only via RVSF โ no informal channel
- Mandatory depollution certificate per vehicle scrapped
- Certificate of Deposit (CoD) from RVSF as EPR credit
- Consumer take-back incentive scheme (buyback/discount)
Penalty for Non-Compliance
- Environmental Compensation for failure to meet ELV take-back targets
- Non-registration: Violation under EP Act 1986 โ show-cause and prosecution
- Vehicles scrapped outside RVSF: Criminal offence for both producer and scrapper
- Directors' personal liability for deliberate non-compliance
- Loss of production licence in extreme cases under MoRTH / SIAM regulations
How Greenovate Helps
- CPCB portal registration for 2W, 3W, 4W, and CV manufacturers / importers
- Annual POM (units placed on market) calculation per vehicle segment
- RVSF identification, evaluation, and formal agreement structuring
- Consumer take-back campaign and dealer-level collection programme design
- Depollution protocol documentation and RVSF compliance verification
- Annual EPR return filing and compliance calendar management
How We Manage Your EPR
Register
CPCB portal registration and entity verification for all applicable EPR categories.
Plan
Calculate your annual targets and develop a compliant, cost-effective EPR plan.
Execute
Coordinate with authorised PROs/recyclers and purchase EPR credits as needed.
Report
File quarterly updates and annual returns with full audit documentation.
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