As the government keeps tightening its grip on plastic waste management, EPR compliance Filing is becoming an annual requirement for those selling packaging plastic. Plastics waste producers, importers, brand owners (PIBOs), and processors must obtain not only EPR Registration but also timely and proper filing of their EPR compliances with the Central Pollution Control Board (CPCB).
In this guide, we’ll provide a step-by-step explanation of how to file your EPR compliance for FY 2024–25, covering eligibility, documentation, portal navigation, and best practices to avoid penalties.
What is EPR Return Filing?
Extended Producer Responsibility or EPR is a policy approach where the producers are tasked with a significant monetary and/or physical responsibility for the treatment or disposal of post-consumer plastic items. Producers of plastic packaging or persons trading in plastic packaging shall take back, recycle, or dispose of plastic packaging in an environmentally friendly manner under the Plastic Waste Management (Amendment) Rules, 2022.
EPR compliance Filing is filing of plastic packaging material manufactured, imported, sold, collected, and processed annual compliances on behalf of CPCB. The compliance certifies whether an organization has attained its allocated objectives in regard to plastic waste management.
Who needs to file EPR Returns?
EPR return filing is offered to establish the following individuals:
- Producers: Businesses that manufacture plastic packaging material established in India.
- Importers: Importers of packaged products or plastic packaging material.
- Brand Owners: Entities selling products packed in plastic in their own brand name, i.e., e-commerce players.
- Plastic Waste Processors: Organizations treating plastic waste in the form of recycling, co-processing, incineration, or energy/fuel conversion.
Both these classes of entities have varying duties and need to file their respective returns on the CPCB EPR portal.
EPR Return Filing Schedule for FY 2024–25
The compliance will be filed prior to April 1, 2025, or June 30, 2025, for the financial year 2024–25. Filing of the compliance after the aforementioned date might leave leave authorization in abeyance or may involve penalty.
Step-by-Step Steps to EPR Compliance Filing in 2025
Step 1: Log in to the CPCB EPR Portal
Go to the official CPCB EPR website. Log in by using the login credentials which are created at the time of EPR Registration. Ensure your registration is active and up-to-date.
Step 2: Choose the Correct Filing Option
Log in and navigate to the “compliance Filing” option on the dashboard. Choose financial year 2024–25 for compliance filing.
Step 3: Enter Category-Wise Details
Depending on your business category, what you would have to enter would differ:
- Producers: Supply the quantity of plastic packaging produced and supplied.
- Importers: Supply imports of plastic packaging over the year.
- Brand Owners: Supply sales and quantity of plastic packaging brought to market.
- Plastic Waste Processors: Supply volumes of plastic waste processed and how processed (recycling, energy recovery, co-processing, etc.).
- Double-check that all submissions are accurate and backed up with documented facts.
Step 4: Upload Supporting Documents
Upload supporting documents in PDF. These are usually:
- GST invoices for production, sales, or imports
- PRO-Producer Responsibility Organisation contracts
- Plastic waste processor certificates issued by authorized processors
- PRO payment evidence, if any
- Description of the Post-Consumer Recyclate (PCR) that is packaged, if any
- If you are in more than one class (e.g., producer and importer), ensure that you submit separate compliances and documents for each class.
Step 5: File and Save Acknowledgement
After inputting all the data and uploading all the documents, please verify all of them. File the compliance and preserve the acknowledgment slip for future reference. Shortly after submission, CPCB will ask questions or clarification, hence track the portal for the updates.
Key Documents Required:
- EPR Registration Certificate
- GST Compliance and Invoices
- Certificate of processing used by the recyclers
- PRO agreements and receipts
- Information regarding the collection and processing of plastic waste
- Monthly and Quarterly Internal Tracking Reports
For Company Verification
- KYC Certificate
- Authorized Certificate
- Board Resolution
For Land Ownership Verification
- Rent Deed
- Lease Deed
- Land Ownership Certificate
For Tax Liability Verification
- Company Pan Card
- GST Certificate
For EPR Responsibility
- Sales Purchase Data of the Previous Financial Year
- EPR Plan
- EPR Certificates
- Annual Filing Receipt
What If You Get a Query from CPCB?
After you have filed, CPCB may raise discrepancies or clarification. If yes:
- Log in to the portal
- Verify your filing status
- Respond within the time frame given
- Upload supporting evidence or corrections if necessary
- Resolution of such queries in time is crucial so your compliance is not rejected.
Types of EPR Compliance in India
EPR (Extended Producer Responsibility) compliance in India is required by the Plastic Waste Management Rules, 2016 (revised in 2022), and is applicable to organizations handling plastic packaging. The compliance is divided into four primary types depending on the type of plastic packaging used:
- Category I – EPR Compliance for E-Waste
- Category II – EPR Compliance for Plastic Waste
- Category III – EPR Compliance for Battery Waste
- Category IV – EPR Compliance for Tyre Waste
There are unique recycling, reuse, and end-of-life disposal targets for each category. PIBOs have to register with the CPCB and achieve annual compliance levels by filing compliance and dealing with registered recyclers. Genuine EPR compliance provides environmental responsibility and avoids legal penalties.
Penalties for Non-Compliance
Non-filing of EPR compliance within the time limit or submission of incorrect or partial information can lead to:
- Levy of monetary penalties under Environmental Compensation Rules
- Suspension/cancellation of EPR Registration
- Prosecution under the Environment (Protection) Act, 1986
- Declination of future EPR authorisation applications
Preventive measures for early EPR compliance
- Begin preparation of documents as early as the financial year close (April 1)
- Plan with recyclers and PROs to prepare all certificates
- Keep valid and up-to-date EPR Registration
- Check all in-house finance and logistics personnel numbers
- File no earlier than absolutely necessary to avoid portal faults
EPR Registration Role
It is illegal to submit your EPR compliance if you don’t have a valid EPR Registration. Your EPR Registration is your formal authorization by CPCB that provides you with annual waste management targets and allows you to interact with PROs, recyclers, and processors.
Ensure your registration is:
- Filled in well in advance
- Approved before the compliance period
- Updated if due for expiration
Conclusion
EPR compliance filing is a yearly requirement to be held responsible for plastic waste disposal. Knowledge of the filing procedure, document preparation, and stuff in advance, and completion of all requirements will get you covered for 2025 without giving you a headache. Proper filing and timely filing not only saves you from fines but also makes your organisation eco-friendly and compliant. Plan, work hard, and submit it on June 30, 2025.
Frequently Asked Questions
Q1. What is the EPR Return Filing deadline for FY 2024-25?
Submit the EPR return between April 1 and June 30, 2025, on the CPCB EPR portal.
Q2. Do small-scale importers or manufacturers need to submit the EPR Return?
Yes, All plastic packaging material importers, manufacturers, and brand owners of all sizes must have EPR Registration and file annual returns.
Q3. Can returns for more than one category like brand owner and importer be filed?
Yes, but each one needs to be filed separately. The portal allows filing returns based on the registered categories.
Q4. What if wrong information is provided in the EPR return?
CPCB may raise queries and ask for clarification. Failure to clarify can lead to rejection, fine, and suspension of your EPR authorisation.
Q5. Is the appointment of a PRO required for EPR compliance?
Appointment is not required but recommended to appoint a registered PRO to meet targets in a structured manner and procure desired recycling certificates for return filing.
If you need further assistance or have any doubts, our experts are here to help you. Call us: 8881-069-069.
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