Introduction
If you’re an importer bringing electronics, plastics, batteries, or packaged goods into India, you’re already under the radar of the Central Pollution Control Board (CPCB). With the new Plastic Waste Amendment Rules (2025) and Battery Waste Management Amendment Rules (2025), compliance is stricter than ever.
From July 2025, all plastic and battery packaging must carry a CPCB-issued barcode or QR code linked to your EPR registration. Customs checks are tightening, and missing your registration could even stall your imports. Yet, many importers still repeat the same mistakes when applying for EPR registration.
This blog breaks down the top mistakes importers make, explains how to avoid them, and gives you a practical checklist to stay compliant in 2025 and beyond.
Why Importers Need to Pay Extra Attention in 2025
While producers and brand owners also face EPR obligations, importers have an additional layer of scrutiny: customs clearance. If your CPCB registration isn’t in place, your goods may never reach the Indian market.
- Multi-category coverage: Importers often bring in products that fall under more than one category (e.g., electronics packaged in plastic). This means multiple EPR registrations.
- Mandatory barcoding: From July 2025, every importer must print CPCB barcodes/QR codes on packaging, product brochures, or bulk cartons.
- Return filing: Importers must submit both quarterly and annual returns. Skipping these filings can block renewal.
- Penalties: Non-compliance can lead to suspension of IEC (Import Export Code), fines, and even stoppage of imports under the Environment Protection Act, 1986.
The Most Common Mistakes Importers Make
1. Skipping Importer-Specific Documents
Many importers assume that submitting a PAN card and GST certificate is enough. In reality, CPCB requires importer-specific compliance documents such as:
- IEC (Import Export Code)
- GST certificate with the correct address
- PAN of company and authorized signatory
- Corporate Identification Number (CIN) if registered
- Self-declarations on RoHS (for electronics) and awareness plans
Failing to upload IEC is one of the top reasons for importer applications being rejected.
2. Using Outdated Fee Structures
A surprising number of importers still quote fee slabs from before 2022. The updated CPCB fee slabs are:
| Annual Recycling Target (MT) | Registration Fees (₹) |
|---|---|
| < 50 MT | 2,500 |
| 50 – <100 MT | 7,500 |
| 100 – <1,000 MT | 1,50,000 |
| 1,000 – <5,000 MT | 10,00,000 |
| > 5,000 MT | 15,00,000 |
For new importers, the base fee is ₹10,000, regardless of volume. Many applications get delayed simply because the wrong payment is made.
3. Ignoring the Barcode/QR Code Mandate
This is the biggest compliance shift of 2025. Under both the Plastic Waste Management Rules (amended January 2025) and the Battery Waste Management Rules (amended February 2025), every importer must print CPCB-issued QR codes on:
- Packaging of batteries or battery packs
- Packaging of electronics with embedded batteries
- Plastic packaging (bottles, wrappers, multilayer plastics, etc.)
- Bulk cartons, not just retail packs
Non-compliance will attract penalties and could block your imports.
4. Filing Returns Incorrectly or Late
Importers often delay filings until the year-end. But CPCB requires both quarterly and annual returns.
- Quarterly returns → must be filed sequentially, one quarter at a time.
- Annual returns → due by 30th June of the following year.
- Missing returns can block renewal of your certificate.
5. Overlooking Multi-Category Imports
If you import electronics packed in plastic, or batteries with outer cartons, you may need multiple registrations:
- E-Waste EPR registration for electronics
- Plastic EPR registration for packaging
- Battery EPR registration for cells and packs
Many importers apply under only one category and later face penalties when SPCBs audit their packaging waste.
6. Not Preparing for SPCB/CPCB Inspections
CPCB and SPCBs have the authority to inspect facilities or request importer documentation. Many importers fail to prepare compliance records such as:
- Invoices showing QR/barcodes
- Proof of contracted recyclers
- Awareness campaign details (mandatory in annual returns)
Failure to present these records can result in suspension of your EPR certificate.
How to Avoid These Mistakes – The Importer’s Checklist
Before Importing:
- Obtain IEC, GST, PAN, CIN (if applicable).
- Identify product category (e-waste, plastics, batteries).
- Apply for EPR registration on CPCB portal.
- Pay correct CPCB fees based on recycling target.
At Import Stage:
- Ensure packaging carries CPCB QR/barcodes.
- Keep CPCB certificate handy for customs clearance.
After Import:
- File quarterly returns on time.
- File annual returns by June 30 every year.
- Maintain recycler contracts and invoices.
- Update any profile amendments (authorized person, GST address, etc.).
Importer vs Producer vs Brand Owner vs Recycler – A Quick Comparison
| Entity | Authority | Fees | Obligations | Validity |
|---|---|---|---|---|
| Importer | CPCB (multi-state) | ₹2,500 – 15,00,000 | IEC, barcode printing, quarterly & annual returns | 5 years |
| Producer | CPCB/SPCB | Same slabs | Sales data, RoHS compliance, awareness plan | 5 years |
| Brand Owner | CPCB/SPCB | ₹10,000 – 50,000 | Plastic packaging EPR compliance | 1–3 years |
| Recycler | SPCB/CPCB | ₹15,000 + AMC | Return filing, plant audits, EPR certificate issuance | 5 years |
Case Study – How One Importer Got It Right
In 2024, a Singapore-based electronics importer sought CPCB registration. Initially unaware of multi-category obligations, they applied only under e-waste. With expert guidance, they registered under plastic waste EPR as well.
By July 2025, their packaging carried CPCB-issued QR codes. They filed quarterly returns on time, and their annual compliance plan was approved without penalties. As a result, their imports cleared customs smoothly across five Indian states.
Lesson: Early preparation and category mapping saved them from hefty fines and shipment delays.
Penalties Importers Must Watch Out For
- Non-registration → suspension of IEC, customs blockage.
- No barcoding → penalties under EPA, 1986; imports may be seized.
- Late return filing → renewal refused, financial penalties.
- False declarations → cancellation of certificate for up to one year.
FAQs – Importer EPR Compliance (2025)
Yes. If you’re an importer, you must register under the CPCB EPR portal even if your foreign supplier already has compliance in their country.
₹2,500. For new importers, a flat ₹10,000 applies regardless of volume.
Yes. From July 2025, barcodes/QR codes are compulsory on plastic packaging, batteries, and products with embedded batteries.
Quarterly and annual returns are mandatory. Annual returns must be filed by June 30 of the next year.
No. If you import electronics in plastic, you must register separately for e-waste and plastic packaging.
Your EPR certificate lapses, customs may block imports, and CPCB can impose penalties.
Conclusion
EPR compliance is no longer optional—it’s the gateway to the Indian market for importers. From QR codes to quarterly returns, importers face stricter obligations in 2025. The best way to avoid costly mistakes is to stay ahead of regulations, map your product categories correctly, and maintain up-to-date compliance records.
Get Expert Support for Importer EPR Compliance
- Email: wecare@greenpermits.in
- Mobile: +91 78350 06182
