Last quarter, a Delhi-based importer from BrightWave Imports contacted us in frustration. He had been importing laptops and tablets for years, always confident that his paperwork was in order.
But when CPCB generated his new EPR targets, the numbers didn’t make sense to him. His responsibility seemed to jump suddenly, driven by past imports he didn’t even remember. When he tried asking around, all he got were vague answers like “Targets are automated” or “CPCB calculates it internally.”
The truth is: EPR targets follow a very predictable formula — but most importers never get to see how it works. This guide explains the entire math in a simple way so you can avoid sudden obligations, penalties, or compliance shocks.
Most importers think EPR is only for manufacturers. But under E-Waste Management Rules 2022, importers are legally treated as “producers.”
This means importers carry the same obligations as brand owners or manufacturers selling in India. CPCB sees it this way:
Importers often underestimate this because they don’t produce the product themselves. But the moment your shipment arrives in India, you are responsible for its eventual waste footprint.
For many importers, the biggest confusion is how CPCB decides the exact amount of recycling they must pay for. That’s where the next section becomes crucial.
CPCB’s target formula may seem complicated at first, but it is based on three simple inputs. Once you understand these, the entire yearly obligation becomes predictable.
CPCB calculates your target from the weight of products you imported in earlier financial years.
The important part is:
Only the weight of equipment becomes the base — not the number of units.
This is where importers often get stuck.
If your invoices don’t clearly mention weight, CPCB will not accept your data.
If your 2020–21 import weight is higher than other years, your targets for 2024–25 will spike. This is why companies are often surprised when their obligations suddenly jump.
Every EEE product category has an average expected life. CPCB assumes that imported products remain in consumer use until the lifecycle ends.
Examples:
Lifespan determines which import year becomes liable today.
For example, if you imported laptops in 2019–20 (5-year lifespan), those laptops are now considered “end-of-life” in 2024–25.
So your EPR target in 2024–25 is directly linked to what you imported in 2019–20.
Most companies don’t track historical weight carefully.
When CPCB asks for corrections, they struggle to find 4–6-year-old data, leading to delays, rejected filings, or provisional calculations.
Once CPCB determines the liable year, they apply a target percentage.
For example:
If the target for laptops this year is 60%, and your obligated waste is 1,000 kg, then your responsibility becomes:
1,000 kg × 60% = 600 kg of EPR obligation
This 600 kg is not the weight you must recycle.
This is the weight that must be further broken down into metal-wise obligations.
This is where the real complexity begins.
E-Waste EPR is not product-based.
It is metal-based.
Meaning once the target weight is calculated, it is divided into the key metals found in that category of electronics.
These metals include:
Importers are often shocked when they realize they must buy multiple types of EPR certificates, not just one.
Each EEE category has a pre-defined percentage of recoverable metals. These values are based on scientific recovery studies of dismantled devices.
| Product Type | Code | Gold % | Copper % | Aluminium % | Iron % |
|---|---|---|---|---|---|
| Smartphones | ITEW15 | 0.0015 | 0.85 | – | 17.02 |
| Laptops | ITEW3 | 0.0004 | 0.19 | 11 | 5 |
| Televisions | CEEW1 | 0.00012 | 0.5 | – | 27.1 |
| Tablets | ITEW19 | 0.0004 | 3.5 | – | 40 |
If your target for laptops is 600 kg, and laptops contain 11% aluminium, then your aluminium EPR certificate requirement automatically becomes 66 kg.
This is why some importers end up buying large quantities of aluminium or iron certificates, even though they assumed their responsibility was small.
Let’s use the example of BrightWave Imports again.
1,000 × 60% = 600 kg
Using laptop metal composition:
The importer must now purchase EPR certificates for:
And submit the certificates in the annual return filing.
Gold recycling capacity in India is small.
Only a limited number of recyclers recover gold at scale.
Because of this, CPCB has reduced the gold obligation temporarily.
Full compliance is being phased in gradually over the next few years.
This helps importers avoid unrealistic gold certificate requirements, but it also means planning is essential. If you wait until February or March, gold certificates may not even be available.
Importers commonly face CPCB notices due to preventable issues.
Here are the most frequent ones:
Mapping your product to the wrong EEE code completely changes the target.
If you cannot produce 4–6-year-old invoices or weight proofs, CPCB may assign “provisional” targets.
Metal-wise obligation varies significantly. Copper and aluminium requirements can be huge compared to gold.
These do not count in annual return filing and can lead to rejection.
Any new category with shorter lifespan will accelerate your obligations.
Too many importers rely on Excel sheets with missing weight columns.
Importers who succeed with compliance follow a few simple practices:
This saves money, time, and reduces the risk of penalties or environmental compensation.
For importers, EPR is not just a regulation — it’s a predictable system that rewards clarity and planning.
Once you understand how CPCB calculates obligations using lifespan, past imports, and metal composition, you can manage EPR costs more confidently and avoid unexpected compliance issues.
If you want expert assistance with registrations, metal-based EPR planning, or target calculations, our team can guide you end-to-end.
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Targets are based on your past import weight, product lifespan, and CPCB’s yearly target percentage.
Yes, because targets are metal-wise, not product-wise. You must buy certificates for each recoverable metal.
CPCB may refuse your filing or assign higher provisional targets until correct invoices are submitted.
India has limited gold recovery capacity, so CPCB uses reduced obligations during the transition phase.
Only certificates issued by CPCB-registered recyclers are valid; others will be rejected during annual returns.
