EPR Compliance Checklist for Plastic Importers in 2025: Registration to Annual Returns

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Earlier this year, Marvex Polymers Pvt. Ltd., a mid-sized importer based in Mumbai, faced a sudden setback. Their shipment of plastic closures worth ₹30 lakh was halted at customs. Everything was in order — invoices, IEC, GST — except one thing: EPR Registration.

The owner told us he always assumed EPR applied only to manufacturers. But in 2025, the rules have changed. Importers introducing plastic packaging or plastic-containing products into India are now held equally responsible for managing the waste that follows.

To help avoid the uncertainty and losses firms like Marvex experienced, here’s a clear and practical checklist covering everything from registration to annual returns.

EPR Compliance

Who Must Comply With EPR in 2025 (Importer Perspective)

Any importer bringing plastic or plastic-packaged products into India falls under EPR regulations.

You must comply if you import:

  • Plastic packaging (rigid, flexible, multilayered, compostable)
  • Finished goods packed in plastic
  • Plastic bottles, jars, caps, lids, containers
  • Plastic granules/resins/preforms
  • Plastic components used in manufacturing

Applicable EPR Categories

  • Category I: Rigid plastics
  • Category II: Flexible plastics
  • Category III: Multilayer plastics
  • Category IV: Compostable plastics

Why it matters for importers

Once these products enter the Indian market, you must ensure an equivalent quantity of plastic waste is processed or recycled through authorized processors.

EPR Registration Checklist for Plastic Importers (2025)

Before starting the online application, gather the following documents to avoid delays.

Documents Required

Document Requirement
PAN (Company) Required
GST Certificate Required
CIN (if applicable) Required
IEC (Import Export Code) Required
PAN or Aadhaar of Authorized Person Required
Plastic packaging data for last 2 years Required
Raw material procurement details Required
Digital signature image Required
DIC Registration If applicable

Step-by-Step EPR Registration Process for Importers

A complete and accurate application significantly reduces approval time.

Steps

  • Visit the CPCB Plastic EPR Portal
  • Create login credentials for the authorized person
  • Fill in company information and operational states
  • Upload PAN, GST, CIN, IEC
  • Enter plastic consumption for previous years
  • Provide raw material procurement details
  • Enter pre-consumer and post-consumer waste generation
  • System automatically calculates EPR targets
  • Upload signatures, covering letter, declarations
  • Pay registration fees online
  • Download EPR certificate after approval

EPR Obligations for Plastic Importers in 2025

Your responsibility begins with registration — and continues annually.

Key obligations:

  • Fulfil category-wise recycling targets assigned by CPCB
  • Purchase recycling certificates only from registered PWPs
  • Maintain accurate documentation for audits
  • File annual returns by June 30
  • Keep operational details updated

Record-Keeping Checklist for Importers

Poor documentation is the most common reason for penalties. Maintain these records for at least 3–5 years:

Records to keep:

  • Import invoices
  • Plastic packaging specifications
  • Waste generation calculations
  • Recycling certificates purchased
  • Agreements with PWPs
  • Annual returns
  • Awareness activity documentation
  • Acknowledgements from CPCB portal

These records help prove compliance during audits and prevent unexpected penalties.

Annual Return Filing Checklist (2025)

Every importer with EPR registration must file returns — regardless of the import volume.

Annual return must include:

  • Plastic introduced into the market (category-wise)
  • Waste generated
  • Recycling certificates purchased
  • Recycled content used
  • Awareness activities
  • State-wise break-up

Deadline:

30 June of the following financial year.

Compliance Risks Importers Face in 2025

EPR is now a top priority for both CPCB and customs. Importers ignoring compliance are facing real consequences.

Common risks:

  • Customs holds and delayed clearance
  • Suspension of EPR registration
  • Environmental Compensation
  • Increased storage and demurrage costs
  • Interrupted supply chain and lost orders

Humanized scenario

A Gujarat-based importer had purchased recycling certificates from a processor who later turned out to be operating beyond approved capacity. During audit, the importer was held responsible for due diligence and had to correct the deficit at his own cost. This shows why compliance isn’t just about ticking boxes — it’s also about choosing the right partners.

Complete Importer Compliance Checklist for 2025

Requirement Status Notes
EPR Registration completed Ensure GST/IEC accuracy
Plastic categories mapped Categories I–IV
Import invoices organized Keep both digital & physical
Procurement details updated Registered + unregistered
Certificates purchased Only from valid PWPs
Annual return filed Deadline: 30 June
Awareness initiatives documented Required for annual return

Conclusion & CTA

EPR compliance for plastic importers is now a core regulatory requirement directly tied to customs clearance and business continuity. Getting registered early, maintaining proper records, and filing timely returns will keep your operations moving smoothly in 2025 and beyond.

If you need expert help with EPR registration, documentation, certificate procurement, or annual returns, our team at Green Permits is here to support you.

📞 +91 78350 06182
📧 wecare@greenpermits.in

Book a Consultation with Green Permits

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FAQs

Yes. If you import any kind of plastic packaging or products containing plastic, EPR registration with CPCB is mandatory before importing or selling in India.

Importers need basic company documents (GST, PAN, CIN), plastic import data for the last two years, KYC of the authorized person, and packaging category details.

You must register on the CPCB portal, meet annual recycling targets, work only with registered plastic waste processors, and file annual returns by June 30 every year.

If your documents are correct, CPCB usually takes 15–30 working days to grant registration.

Non-compliance can lead to penalties, customs issues, blocked imports, and suspension of your EPR registration.