If you are an importer in India dealing with plastic packaging, batteries, electronics, or tyres, you cannot ignore Extended Producer Responsibility (EPR). Under the rules notified by the Ministry of Environment, Forest and Climate Change (MoEFCC), importers are treated as “producers” and must take responsibility for the post-consumer waste generated from their products.
From filing registrations with the Central Pollution Control Board (CPCB) to meeting recycling targets and filing annual returns, compliance has become both a legal necessity and a business differentiator. This blog explains EPR services for importers, covering registration, licensing, compliance obligations, costs, and the latest rule amendments.
Why EPR Matters for Importers
Legal Compliance: CPCB mandates importers to obtain EPR registration for plastics, batteries, e-waste, and tyres before selling in India.
Sustainability Pressure: Large corporations demand that their partners demonstrate recycling and waste management compliance.
Market Access: Customs and DGFT clearance increasingly rely on valid EPR certificates.
Avoiding Penalties: Non-compliance may lead to fines, suspension of operations, or even cancellation of licenses.
Takeaway: For importers, EPR is not optional—it’s the foundation for long-term, sustainable operations in India.
Categories of Importers Covered Under EPR
EPR rules cover multiple product streams. Let’s break them down:
1. Plastic Importers
Packaging materials, films, bottles, and multilayer plastics.
Importers of FMCG goods, electronics with plastic packaging, or industrial packaging must register under the Plastic Waste Management Rules.
2. Battery Importers
Lead-acid and lithium-ion batteries.
Importers of EV batteries, power backup systems, and consumer electronics with batteries.
Mandatory EPR targets for recycling and material recovery.
3. Electronics Importers (E-Waste)
Computers, mobiles, appliances, and accessories.
Importers are responsible for e-waste collection, recycling, and meeting annual return filing.
4. Tyre Importers
New and used tyres, as well as products containing tyres.
Obligated to register with CPCB and ensure environmentally sound recycling.
Takeaway: No matter what you import—plastics, batteries, electronics, or tyres—you are considered a Producer under EPR rules and must comply accordingly.
Step-by-Step Guide: EPR Registration Process for Importers
1. Identify Applicability
Check if your product falls under Plastic, Battery, E-Waste, or Tyre categories.
Importers are automatically classified as Producers under CPCB rules.
Submit category-wise product and packaging details.
4. Pay Fees
CPCB charges are based on sales turnover (battery), recycling targets (plastic/e-waste), or product weight categories.
Example: Producers handling less than 50 MT of e-waste pay lower fees, while large importers handling >5000 MT pay up to ₹15 lakh for registration.
5. Obtain EPR Certificate
After evaluation, CPCB issues an EPR Registration Certificate.
Validity: typically 3–5 years, depending on product stream.
6. Fulfil Recycling Targets
Meet year-wise recycling obligations by partnering with authorised recyclers/refurbishers.
Obtain EPR certificates from recyclers to offset obligations.
7. File Annual/Quarterly Returns
Report imports, recycling certificates purchased, and targets achieved.
File on CPCB’s online portal by 30th June every year.
Takeaway: The process may look complex, but professional consultants simplify it through documentation support, portal handling, and recycler partnerships.
Fees & Costs for EPR Registration (Importers)
Waste Stream
Fee Range (Approx.)
Basis of Fee
Plastic Packaging
₹10,000 – ₹50,000
Based on tonnage handled annually
Batteries
₹10,000 – ₹40,000
Based on company turnover
E-Waste
₹2,500 – ₹15,00,000
Based on recycling targets (MT)
Tyres
₹15,000 – ₹50,000
Fixed registration + AMC charges
Takeaway: Costs depend on your import volume and turnover, but failing to register may result in environmental compensation far higher than fees.
Compliance Obligations Importers Must Meet
Collection & Recycling Targets: Yearly percentage obligations increasing over time.
Tie-ups with Authorised Recyclers: Only CPCB-registered recyclers’ certificates are valid.
Awareness Programs: Importers must conduct consumer awareness drives (for batteries and e-waste).
Return Filing: Annual return by June 30th and quarterly updates for high-volume categories.
Labelling & QR Codes (2025 Amendments): Importers must print EPR registration numbers or QR codes on packaging and product brochures for plastics and batteries.
Takeaway: Compliance doesn’t end with registration—it’s a yearly responsibility involving collection, recycling, and reporting.
Case Study
A Gurgaon-based electronics importer dealing in laptops faced customs clearance issues in 2023 due to a missing EPR certificate. After engaging consultants, the importer:
Registered with CPCB under E-Waste EPR.
Tied up with two authorised recyclers.
Purchased recycling certificates equivalent to 500 kg of laptops sold.
Result: Customs held back consignments worth ₹3 crore earlier. After compliance, shipments were cleared smoothly, and the company won a new corporate client due to its sustainability credentials.
Common Mistakes Importers Should Avoid
Assuming Brand Owner’s EPR covers imports – Importers are separate producers.
Not registering across all categories – Many importers need EPR for multiple waste streams (e.g., electronics + plastic packaging).
Late filing of returns leads to penalties and suspension.
Working with unregistered recyclers – Certificates won’t be recognised.
Ignoring new amendments – Example: mandatory QR codes on packaging from July 2025.
Takeaway: Awareness and proactive compliance prevent costly business disruptions.
Comparison: EPR Across Waste Categories for Importers
Category
Examples of Imports
EPR Portal
Validity
Key Compliance
Plastic
FMCG packaging, electronics packaging
Plastic EPR Portal
1–3 years
Recycling % targets
Battery
EV batteries, inverters, mobiles
Battery EPR Portal
5 years
Material recovery targets
E-Waste
Electronics, IT products, appliances
E-Waste EPR Portal
5 years
Sales-data based targets
Tyres
New/used tyres
CPCB Portal
5 years
Sales-data-based targets
Why Partner with Green Permits
Navigating the EPR landscape can be overwhelming for importers. That’s where Green Permits Consulting makes the difference:
End-to-End Support: From documentation to portal registration and compliance filings.
Industry Expertise: Handling plastics, batteries, electronics, and tyres under one roof.
Recycler Network: Strong partnerships with CPCB-approved recyclers across India.
Risk-Free Compliance: Avoid penalties, delays, and customs issues.
Sustainability Branding: Enhance your ESG profile and attract eco-conscious clients.
Conclusion
EPR is no longer a back-office compliance task—it directly affects your ability to import, sell, and grow in India. For importers of plastics, batteries, electronics, and tyres, timely EPR registration and compliance ensure smooth business operations and sustainable growth.
