Your EPR & ESG Questions, Answered by India's Leading Compliance Experts
From CPCB registration to ETP portal, URep targets to ESG reporting — find clear, expert answers here.
Frequently asked questions:
We understand this issue, and would recommend to raise online tickets on the CPCB portal highlighting the issue. They will resovle it from the Backend.
In this scenario, as the company is using plastic packaging to pack the Product(autocomponent) and sell to its buyer. Now there are 2 situation which comes up like - either the component manufacturer is treated as Brand owner or Producer(contract manufacturer). If as per your contract with the OEMs(buyer of auto component) is taking the obligation of these plastic packaging then the manufacturer shall register as producer and transfer the plastic packaging obligation to OEMs or if OEMs is not taking the responsibility and manufacturer has to take the obligation then Manfacturer shall register as brand owner under PWM regualtions and take the obligation of these plastic packaging utilised.
Yes. There is no exemption for importers based on MSME status. All importers bringing plastic packaging or packaged products into India must register on the CPCB EPR portal and file annual returns — regardless of business size.
CPCB is yet to come out with the proces of claimming exemption of Urep. As per recent communications, CPCB is building a feature on the PWM portal itself where in the Obligated entities can report the data for claimming exemption on UreP targets.
As the SSO require the Authorised person and its PAN to be same to link the EPR accounts under the common EPR portal(SSO), hence in this case you will have the update the authorised person as same in both the account. Reach out to our team who will help in this process
For EPR credits the ETP portal is to be considered for purchase and sale of EPR credits. This exchange is only for the purpose of buying and selling of credits, for the other compliance reporting the already exisiting EPR portal will function as is.
For marking & labelling under PWM rules cluase 11(2) has been amedned to incorporate the M&L requirements as specified for the recycled plastic used in food grade packaging. Reach out to our team for more details on specific cases
As per the recent virtual meeting conducted by CPCB and ETP operator. they have clarified for inhouse recycling and utilisation of EPR credits within the Entity. Provided the recycled entity and the Producer/brand owner entity has the same PAN. Reach out to our team for detailed clarification on the specific scenario
As per the PWM 10th Amendment, for the imported plastic packaging, the Importer will have to fulfil the Urep targets by buying the Urep certificate only. Any recycled content in the imported packaging will not be considered for the claim of URep fulfilment of targets.
As per the PWM 10th Amendment, for the imported plastic packaging, the Importer will have to fulfil the Urep targets by buying the Urep certificate only. The mechanism of fulfiling the Urep target by urep certificates is only provided to the Importer and for producer or brand owner it is not specified.Further currently the generation of Urep credits is not acitive hence you would not be able to buy now. However once the generation is active then the credits would be available on the offline or the Online ETP exchange
As per the PWM 10th Amendment, for the imported plastic packaging, the Importer will have to fulfil the Urep targets by buying the Urep certificate only. The mechanism of fulfiling the Urep target by urep certificates is only provided to the Importer and for producer or brand owner it is not specified.Further currently the generation of Urep credits is not acitive hence you would not be able to buy now. However once the generation is active then the credits would be available on the offline or the Online ETP exchange
For Micro and small Producers and brand owner the EPR targets obligation is not applicable. Not sure about if the MSME producer would be able to login to the ETP portal or no. Further for Micro and small Brand owner, they are not required to register of the EPR portal
Companies working like a trader of PCR granuels would need to register as seller under the CPCB PWM portal to ensure they are compliant to trade in granuels. However there are some issue regarding the post registration reporting of the transactions, however it is recommended to register as seller and seek clarity on post registration reporting from CPCB.
For onboarding on the common EPR portal the companies are required to unify and standardise the details of authorised person in all the accounts they are regsitered under. Please reach out to our team to understand the process in detail.
There is no specific food contact material definition provided under the PWM regulations. However, if there is any Food product licensed under FSSAI then the packaging used is subject to guidelines of FSSAI. Hence in such case the companies need to adhere to the standards and guidelines issued for the Food product and its packaging. Furhter, for the Labelling for Multiplayer laminate this would differ packaging to packaging, hence recommend to connect with our team for further details.
No, you would need to register separately under E-waste and Plastic waste. However both these login can be accessed through Common EPR SSO portal by one single login.
As per the recent 10th PWM amendment the UreP certificate is only allowed for Importer to fulfil its URep Obligations and it does not provide the similar option to Brand owner and Producer. hence your interpretation is right here
We understand the challenges faced today by
For EPR credits the ETP portal is to be considered for purchase and sale of EPR credits. However, as the ETP portal is yet to be fully deployed there might be scenario where in the EPR credits can be purchased by Registererd recycler offline. But wait for the official communication to come for the regulators to this effect.
As of now, CPCB has not defined any Timeline for registering on the common EPR portal. However, if anyone wants to access the ETP portal the onboarding to Common EPR portal becomes a pre requisite.
As per the PWM 10th Amendment, for the imported plastic packaging, the Importer will have to fulfil the Urep targets by buying the Urep certificate only. The mechanism of fulfiling the Urep target by urep certificates is only provided to the Importer and for producer or brand owner it is not specified.Further currently the generation of Urep credits is not acitive hence you would not be able to buy now. However once the generation is active then the credits would be available on the offline or the Online ETP exchange
As of now the Last date for file Annual return for FY25-26 on PWM plastic EPR portal is 30th June 2026
The current status of EPR ETP portal is same Non Functional now since 31st March 2026.Further the generation of the credits is still operational but the transfer of credits has been blocked from recycled login account. However we expect this to be resolved soon from CPCB. No specific date has been mentioned of communicated yet.
In the current Draft amendment the Moef has not provided clarity on the Plastic obligation whether it shall be Packaging or Plastic products as well. Further the similar kind of ambiguity lies for the other waste categories as well. However, in the larger scheme of Draft amendment, it is linked indirectly to the Other EPR regualtions frameworks as applicable. However, we are seeking clarity on this from Moef and our team will come back
Yes as per the amendmend the carry forward for shortfall is only allowed for the food contact application only. and carry forward is only allowed for shortfall in FY25-26 Urep targets only which is for next 3 years divided equally every year.
For Importer there is no relief to companies if they are Micro or small. For Importers obligation applies to all importers importing Plastic packaging or packaging with products in India.