1. What is UREP, and how does it affect compliance from FY 2025 – 26?
UREP stands for “Use of Recycled Content in Plastic Packaging”. From FY 2025–26, PIBOs must ensure a specified percentage of recycled plastic content in their packaging, category-wise, and report this on the CPCB portal. Exact percentage requirements by category should be confirmed from the latest PWM amendments and CPCB notifications before implementation.
2. What does “Reuse” mean on the EPR portal, and when is it applicable?
“Reuse” refers to packaging that is used multiple times instead of being disposed of after a single use. Under current rules, reuse obligations are particularly applicable for Category 1 rigid plastic packaging with volume or weight:
- Equal or more than 0.9 litres / kg but less than 4.9 litres/kg;
- More than 4.9 litres/kg for packaging of drinking water and
- More than 4.9 litres/kg used for packaging of products other than drinking water
Entities must track and report reuse of such packaging as per CPCB guidance.
3. Do exports need to be reported under EPR?
Yes. Export quantities must be reported on the CPCB EPR portal. Typically, this involves: Preparing export data in the prescribed Excel (.xls) bulk-upload format (including customer name, address, contact details, plastic type, etc.).
- Uploading sample export invoices and supporting documentation as required.
The prescribed Excel template for a given filing period (e.g., 2024–25) can be downloaded from the portal’s “Export Data” or equivalent section.
4. Do obligated entities need to upload export invoices?
Yes. It is mandatory to provide export invoices along with shipping documents as proof. These must be compiled and uploaded:
- As a ZIP file containing all required documents.
- Along with the detailed export data (invoice-wise) in the format prescribed on the portal at the time of filing the annual return.
5. How do we handle deviations in tonnage due to opening/closing stock differences?
The CPCB portal allows up to 40% deviation between procurement and sales quantities to account for stock differences, in-transit material and similar factors. However, entities must maintain proper stock records, invoices and other supporting documents to justify any deviations, as these may be examined during audits or inspections.