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.
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.
Many importers assume that submitting a PAN card and GST certificate is enough. In reality, CPCB requires importer-specific compliance documents such as:
Failing to upload IEC is one of the top reasons for importer applications being rejected.
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.
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:
Non-compliance will attract penalties and could block your imports.
Importers often delay filings until the year-end. But CPCB requires both quarterly and annual returns.
If you import electronics packed in plastic, or batteries with outer cartons, you may need multiple registrations:
Many importers apply under only one category and later face penalties when SPCBs audit their packaging waste.
CPCB and SPCBs have the authority to inspect facilities or request importer documentation. Many importers fail to prepare compliance records such as:
Failure to present these records can result in suspension of your EPR certificate.
Before Importing:
At Import Stage:
After Import:
| 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 |
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.
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.
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.
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