CPCB EPR Rules Explained for Importers: Plastics, E-Waste & Batteries

Introduction

Importing goods into India is no longer just about managing customs duties and shipping logistics. Today, businesses that bring plastics, electronics, or batteries into the country are also responsible for ensuring that the waste from these products is properly collected and recycled. This responsibility comes under the regime of Extended Producer Responsibility (EPR).

Over the past few years, the Central Pollution Control Board (CPCB) has updated its regulations to align with global sustainability goals. Importers — whether of electronics, plastic packaging, or lithium-ion batteries — are now legally bound to register with CPCB, pay applicable fees, file quarterly and annual returns, and ensure barcoding of packaging from July 2025. Non-compliance can lead to penalties, cancellation of registrations, and even restrictions on imports.

This blog provides importers with a complete breakdown of CPCB’s EPR rules in 2025 across plastics, e-waste, and batteries. If you are an importer of electronics, packaged goods, or batteries, this is your roadmap to compliance.

What is EPR and Why Does it Matter for Importers?

Extended Producer Responsibility (EPR) is a policy mechanism that shifts the responsibility of managing the lifecycle of a product — including its end-of-life waste — from the government to the producer or importer.

For importers, this means:

• Ensuring that the waste generated from the products they bring into India is collected and recycled.
• Getting registered on the CPCB EPR portal for plastics, e-waste, and batteries.
• Filing regular returns and showing evidence of waste management through EPR certificates.
• Printing barcodes/QR codes linked to their EPR registration numbers on packaging and products (mandatory from July 2025).

EPR is not just a compliance requirement. For businesses, it signals credibility, responsibility, and alignment with India’s sustainability commitments. Foreign brands entering the Indian market increasingly face due diligence questions about whether their supply chains comply with EPR.

Who Needs to Register for EPR?

EPR registration is mandatory for the following categories of importers:

• Importers of Electrical and Electronic Equipment (EEE): Mobile phones, laptops, refrigerators, washing machines, and other appliances.
• Importers of Plastic Packaging: Including producers, importers, and brand owners (PIBOs) that introduce packaging material into India.
• Importers of Batteries: Covering lithium-ion, lead-acid, zinc-based, nickel-cadmium, and EV batteries.
• Foreign Brands Entering India: Companies selling in India through distributors or e-commerce platforms.

If an importer operates in more than two states, registration must be done with CPCB directly. Those importing into only one or two states may fall under the jurisdiction of the State Pollution Control Boards (SPCBs).

Key 2025 Updates Importers Must Note

The EPR rules have evolved significantly since 2022. The following updates are especially important for importers in 2025:

1. Mandatory Barcoding/QR Code from July 2025
   • Importers must print EPR registration numbers as barcodes or QR codes on:
     • Plastic packaging
     • Batteries and battery packs
     • Equipment containing batteries
     • Packaging of electronic items
   • This ensures traceability and easy verification of compliance.
2. Fee Structure for Importer Registration
   Registration fees differ depending on the category:
   • E-Waste Producers/Importers: Between ₹2,500 and ₹15,00,000 depending on annual recycling target.
   • Battery Importers: ₹10,000 to ₹40,000 depending on company turnover.
   • Plastic PIBOs: ₹10,000 to ₹50,000 based on plastic waste generation (in tonnes per annum).
3. Returns and Reporting Obligations
   • Quarterly returns must be filed sequentially, followed by an annual return.
   • Importers must include details such as sales, packaging, awareness activities, and recycling certificates.
4. Cross-Category Registrations
   • Importers dealing in both electronics and plastics must register separately under both categories.
   • A single IEC (Import Export Code) is not enough — multiple registrations are required if you handle multiple waste categories.
5. Validity and Renewal
   • Registrations are generally valid for five years.
   • Renewal applications must be filed well before expiry, and compliance with returns is a precondition for renewal.

Step-by-Step Process for Importers to Get EPR Registration

Step 1: Sign Up on CPCB Portal

• Register on the respective portal:
  • E-Waste: eprewastecpcb.in
  • Plastics: cpcbeprplastic.in
  • Batteries: eprbatterycpcb.in
• Provide IEC, GST, PAN, CIN (if applicable), and contact details of the authorized signatory.

Step 2: Upload Mandatory Documents

• GST certificate
• Import Export Code (IEC)
• PAN (Company & Authorized Signatory)
• Incorporation Certificate (if applicable)
• Consent certificates (if setting up local processing)
• Process flow diagram (for recyclers/processors)

Step 3: Pay Applicable Fees

• Based on turnover or recycling targets, fees range from ₹10,000 for small importers to ₹15,00,000 for large importers.

Step 4: Obtain EPR Certificate

• CPCB issues an EPR certificate valid for five years.

Step 5: File Quarterly and Annual Returns

• Returns must be filed online through the CPCB portal.
• Quarterly reports require sales and recycling updates, while the annual return requires an awareness plan and EPR fulfillment details.

Importer vs Producer vs Brand Owner vs Recycler

Entity	Authority	Fees	Obligations	Validity
Importer	CPCB	₹10,000 – ₹50,000+ (category-specific)	Registration, barcoding, quarterly & annual returns	5 years
Producer (Domestic)	CPCB/SPCB	₹2,500 – ₹15,00,000 based on targets	Registration, recycling targets, awareness plan	5 years
Brand Owner	CPCB/SPCB	₹10,000 – ₹50,000	Fulfill obligations via certificates from recyclers	1–3 years
Recycler	SPCB/CPCB	₹15,000 (new registration)	Recycling, issue of EPR certificates	5 years

Importer Obligations in Detail

• Product & Packaging Barcoding: From July 2025, all plastic packaging, batteries, and e-waste imports must carry EPR registration barcodes or QR codes.
• Quarterly Return Filing: Importers must sequentially file Q1, Q2, Q3, and Q4 returns, disclosing quantities imported and waste managed.
• Annual Reporting: Includes awareness initiatives, recycling data, and a compliance statement.
• Awareness Plan: Importers must show how they are informing consumers about waste collection and recycling.
• Record-Keeping: Maintain invoices, recycling certificates, and waste procurement records for audits.
• SPCB Consents (if applicable): Importers setting up recycling or refurbishing facilities must also obtain local state consents under Air, Water, and Hazardous Waste Rules.

Mini Case Study: A Foreign Electronics Importer in 2024

A European company importing laptops and tablets into India faced compliance risks under the updated E-Waste Management Rules. In 2024, it registered with CPCB under the e-waste category with an annual recycling target below 100 MT. By paying ₹7,500 in registration fees, the company secured its EPR certificate valid for five years.

The importer filed quarterly returns, worked with registered recyclers to procure EPR certificates, and ensured barcoding of packaging. As a result, it avoided potential penalties across multiple states. By July 2025, the company implemented QR code printing across its product packaging, ensuring seamless market access and demonstrating compliance to distributors and customers.

Penalties for Non-Compliance

Importers who fail to comply face significant risks, including:

• Monetary Penalties: Environmental compensation charges imposed by CPCB/SPCB.
• Suspension or Cancellation: CPCB may suspend or cancel EPR registration.
• Customs Implications: DGFT can restrict IEC codes of non-compliant importers.
• Legal Action: Prosecution under the Environment (Protection) Act, 1986.

In short, failing to comply can halt imports and disrupt entire supply chains.

FAQs

Conclusion

The CPCB’s EPR framework has transformed compliance for importers in India. Importers of plastics, electronics, and batteries now carry direct responsibility for the waste generated by their products. With the July 2025 barcoding mandate, quarterly returns, and strict fee structures, compliance has become unavoidable.

While the rules may seem complex, they are manageable with proper planning and expert support. By securing CPCB registration, maintaining accurate records, and partnering with recyclers, importers can avoid penalties, safeguard their supply chains, and build credibility in the Indian market.

Need help with EPR registration and compliance?
Green Permits Consulting provides end-to-end support for importers across plastics, e-waste, and batteries.

📧 Email: wecare@greenpermits.in
📞 Mobile: +91 78350 06182

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