Frequently Asked Questions

Everything you need to know about EPR Registration, filing, compliance, and our process.

1. What is the annual return under EPR, and when must it be filed?

The annual EPR return is a statutory filing that reports:

  • Quantity of plastic packaging placed on the market (category-wise).
  • Details of waste management and recycling undertaken.
  • EPR credits purchased and used.
  • Overall compliance status against EPR targets.

It must be filed on the CPCB EPR portal by the prescribed due date, which is generally 30th June for the previous financial year (subject to any specific notifications).

2. Can the annual return be filed late, and what happens in case of non-filing?

If the annual return is not filed by the statutory deadline, the CPCB EPR portal auto-files the return and levies an auto-filing fee. The targets are auto-computed based on previous years, with an automatic increase as per Environment compensation Guidelines. In addition, CPCB can impose Environmental Compensation (EC) and other penalties for non-filing or delayed filing.

3. What are the consequences of non-compliance with EPR rules?

Under Rule 18 of the PWM Rules, 2016 (as amended), Environmental Compensation(EC) is levied on entities that do not comply with the rules. Common violations where EC may be imposed include non-fulfilment of category-wise EPR obligations, non-filing of returns and non-payment of required amounts.Entities should always refer to the latest CPCB EC guidelines for the applicable rates. A detailed note on the applicable EC is given here.

4. How is the annual EPR liability/target computed for a Producer?

For Producers, the eligible quantity Q1in metric tonnes (MT) is calculated as:

  • A= Average weight of plastic packaging material (category-wise) sold in the last two financial years.
  • B= Average quantity of pre-consumer plastic packaging waste in the last two financial years.
  • C= Annual quantity supplied in the previous financial year to entities covered under sub-clause 4(iii) (registered PIBOs).

Formula:

  • Q1(in MT) = A+B-C.

This Q1is then used to compute category-wise EPR targets as per PWM Rules and CPCB guidelines. The quantity of plastic packaging in goods exported is reduced while computing the total obligation

5. How is the annual EPR liability/target computed for an Importer (PIBO)?

For Importers under PIBO, the eligible quantity Q2in MT is calculated as:

  • A= Average weight of all plastic packaging material and/or plastic packaging of imported products (category-wise) imported and sold in the last two financial years.
  • B= Average quantity of pre-consumer plastic packaging waste in the last two financial years.
  • C= Annual quantity supplied in the previous financial year to entities covered under sub-clause 4(iii) (registered PIBOs).

Formula:

  • Q2(in MT) = A+B-C.

Category-wise targets are then applied on Q2as per PWM Rules and CPCB guidelines.

The quantity of plastic packaging in goods exported is reduced while computing the total obligation

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