Regional spotlight: Extended Producer Responsibility (EPR) in India — what's different and why it matters

India generated 3.4 million tonnes of plastic waste in 2023, yet formal recycling infrastructure handled only 30% of that volume, leaving approximately 2.4 million tonnes to enter landfills, waterways, or informal waste streams (Central Pollution Control Board, 2024). The country's Extended Producer Responsibility (EPR) framework, overhauled through the Plastic Waste Management (Amendment) Rules 2022 and the E-Waste Management Rules 2022, represents one of the most ambitious producer responsibility systems in the developing world. For engineers, compliance officers, and sustainability practitioners operating in or exporting to India, the EPR landscape here differs fundamentally from European or North American models in structure, enforcement, and implementation challenges.

Why It Matters

India's EPR regime is consequential for three reasons. First, the country is the world's third-largest consumer market with 1.4 billion people and a rapidly growing middle class that drives packaging, electronics, and consumer goods consumption. Multinational brands operating in India, including Unilever, Nestle, PepsiCo, Coca-Cola, and Samsung, face binding EPR obligations that affect product design, packaging, and end-of-life management.

Second, India's approach to EPR is structurally distinct. Unlike the European model, where producer responsibility organizations (PROs) operate within mature municipal waste management systems, India's EPR framework must operate alongside a massive informal waste sector that employs an estimated 4 million waste pickers nationally (Alliance of Indian Wastepickers, 2024). Integrating formal EPR compliance with informal sector livelihoods creates engineering, logistical, and social challenges that have no direct parallel in OECD countries.

Third, the enforcement architecture has shifted dramatically since 2022. The Central Pollution Control Board (CPCB) introduced a centralized online portal for EPR registration, target tracking, and certificate verification. Non-compliance now carries penalties of up to INR 1 crore (approximately $120,000) per violation, and environmental compensation can be levied under the National Green Tribunal Act. As of early 2025, the CPCB had issued show-cause notices to over 400 producers and importers for failure to meet plastic EPR targets (CPCB, 2025).

Key Concepts

The Three EPR Pillars in India

India's EPR framework operates across three distinct regulatory domains, each with its own rules, targets, and compliance mechanisms:

Plastic Waste Management Rules (2016, amended 2022): These rules mandate that producers, importers, and brand owners (PIBOs) collect and process specified quantities of plastic packaging waste. The 2022 amendments introduced mandatory recycling and reuse targets that escalate annually: for 2024-25, PIBOs must ensure collection and recycling of 70% of rigid plastic packaging and 50% of flexible plastic packaging, rising to 80% and 60% respectively by 2026-27.

E-Waste Management Rules (2022): These rules cover 106 categories of electrical and electronic equipment, mandating that producers collect and channel e-waste for authorized dismantling and recycling. Collection targets increase from 60% of sales weight in 2023-24 to 80% by 2028-29. The rules also restrict the use of hazardous substances including lead, mercury, cadmium, and hexavalent chromium, aligning partially with the EU's RoHS Directive.

Battery Waste Management Rules (2022): These rules establish EPR obligations for producers and importers of all battery types, including portable, automotive, industrial, and electric vehicle batteries. Collection targets range from 70% for lead-acid batteries to 30% for lithium-ion batteries in 2024-25, with progressive annual increases.

The EPR Certificate Trading System

India introduced an EPR certificate trading mechanism in 2023, creating a market-based approach to compliance that is unique globally. Under this system, authorized recyclers generate EPR certificates upon verified processing of waste. Producers can purchase these certificates from recyclers through the CPCB portal to fulfill their obligations. The certificate price effectively sets a floor for recycling economics: as of Q4 2025, plastic EPR certificates traded between INR 15,000 and INR 45,000 per tonne depending on plastic category, with multi-layered plastic (MLP) certificates commanding the highest prices due to limited recycling capacity (Indian Recycling Alliance, 2025).

This system creates financial incentives for recycling infrastructure investment while allowing producers flexibility in how they meet targets. However, it has also generated concerns about certificate fraud, with investigations in 2024 uncovering instances where certificates were issued for phantom processing that never actually occurred.

What's Working

Formalization of the Informal Sector

Several leading PIBOs and PROs have developed models that integrate informal waste pickers into formal EPR collection networks while improving their livelihoods. Hindustan Unilever Limited (HUL), working through its partnership with the PRO Nepra Resource Management, established collection networks across 36 cities that employ over 12,000 waste pickers as registered collection agents. These workers receive guaranteed minimum payments, personal protective equipment, health insurance, and access to digital payment systems. The program collected 112,000 tonnes of plastic packaging in 2024, meeting 78% of HUL's EPR obligations while increasing waste picker incomes by an average of 40% compared to pre-formalization earnings (Hindustan Unilever, 2025).

ITC Limited has taken a complementary approach through its WOW (Well-being Out of Waste) program, operating in over 40 cities with 28,000 registered waste collectors. The program uses a mobile app-based system for route optimization, collection tracking, and quality-based payments that incentivize source segregation at the household level. ITC reported collecting 130,000 tonnes of dry recyclable waste through the program in 2024 (ITC Limited, 2025).

Technology-Driven MRV Infrastructure

India's CPCB EPR portal, launched in 2023 and upgraded in 2024, provides centralized tracking of EPR registration, annual action plan submission, target allocation, and certificate issuance. The portal integrates with state pollution control boards (SPCBs) to enable multi-level monitoring. By January 2025, over 32,000 producers, 5,200 recyclers, and 280 PROs were registered on the platform.

Several technology companies have built solutions specifically for India's EPR ecosystem. Recykal, a Hyderabad-based waste management marketplace, operates a digital platform connecting waste generators with recyclers and providing automated EPR reporting. The platform processed transactions covering 450,000 tonnes of recyclable materials in 2024 and was valued at $100 million following a Series B funding round (Recykal, 2025). Saahas Zero Waste developed blockchain-based traceability for waste streams, providing auditable chain-of-custody documentation from collection point to recycler that reduces certificate fraud risk.

Material Recovery Facility Expansion

India added 847 authorized plastic waste processing facilities between 2022 and 2025, bringing the national total to approximately 3,200 facilities (CPCB, 2025). Processing capacity for rigid plastics (PET, HDPE, PP) now exceeds collection volumes in most states, creating competitive dynamics that benefit waste collectors through higher purchase prices. Dalmia Polypro, one of India's largest PET recyclers, expanded capacity from 36,000 to 60,000 tonnes per year at its facilities in Kanpur and Hyderabad, producing food-grade recycled PET (rPET) that meets both US FDA and FSSAI standards for food contact packaging.

What's Not Working

Multi-Layered Plastic Remains Problematic

Multi-layered plastic (MLP), widely used in sachets, chip packets, and flexible pouches, constitutes approximately 35% of India's plastic packaging waste by weight but has minimal economically viable recycling pathways. The current primary end-of-life route for collected MLP is co-processing in cement kilns, where the plastic serves as alternative fuel. While this qualifies for EPR certificate generation, it represents thermal recovery rather than material recycling, conflicting with circular economy principles.

India's sachet economy is a particular challenge: an estimated 200 billion single-use sachets are sold annually for products including shampoo, detergent, cooking oil, and spices (FICCI, 2024). These sachets weigh 2 to 5 grams each, making individual collection economically impractical. Despite multiple pilot programs, no technology has demonstrated commercially viable recycling of post-consumer MLP at scale in Indian conditions.

Enforcement Inconsistency Across States

While CPCB sets national EPR policy, enforcement is delegated to 35 state and union territory pollution control boards (SPCBs), creating significant variation in compliance scrutiny. States including Maharashtra, Karnataka, and Tamil Nadu have active enforcement programs with regular facility inspections and penalty actions. Other states lack dedicated EPR enforcement staff, meaning that producers registered in those states face minimal oversight. A 2024 audit by the Comptroller and Auditor General of India found that 14 SPCBs had not conducted a single EPR compliance inspection in the preceding fiscal year (CAG India, 2024).

This inconsistency creates arbitrage opportunities where producers register in low-enforcement states while operating nationally, undermining the system's integrity. The CPCB has proposed centralizing enforcement authority for large producers (those with annual EPR obligations exceeding 1,000 tonnes), but the proposal faces opposition from state governments citing jurisdictional concerns.

E-Waste Informal Processing Persists

Despite the formalized e-waste EPR framework, an estimated 90% of India's e-waste continues to flow through informal channels, primarily concentrated in recycling hubs in Delhi (Seelampur), Mumbai (Dharavi), and Moradabad (Toxics Link, 2025). Informal processors use acid baths, open burning, and manual dismantling without protective equipment to extract copper, gold, and other valuable materials. These practices release heavy metals, dioxins, and furans, creating severe occupational health hazards and environmental contamination.

The persistence of informal e-waste processing reflects both economic and structural factors: informal processors pay higher prices for e-waste than authorized facilities (INR 15 to 25 per kg versus INR 8 to 12 per kg from authorized recyclers), and the convenience of doorstep collection from households and small businesses gives informal networks a logistical advantage. Authorized e-waste recyclers operate at an average of 40 to 50% capacity utilization due to insufficient feedstock reaching formal channels.

EPR Certificate Integrity Concerns

The certificate trading system has been plagued by verification challenges. In September 2024, the CPCB suspended 47 recycler registrations following investigations that revealed fraudulent certificate issuance totaling approximately 85,000 tonnes of phantom processing (CPCB, 2024). Common fraud patterns include: inflating processing volumes through falsified weigh-bridge records, issuing certificates for waste that was dumped rather than recycled, and recyclers operating without required pollution control equipment while maintaining active registrations.

The CPCB responded by introducing mandatory CCTV surveillance at all registered recycling facilities, GPS tracking on collection vehicles above 3.5 tonnes, and third-party audit requirements for recyclers generating more than 500 certificates per quarter. These measures add compliance costs of INR 5 to 15 lakh ($6,000 to $18,000) per facility annually.

Key Players

Category	Organization	Role
Regulator	Central Pollution Control Board (CPCB)	National EPR policy, portal, certificate system
Regulator	State Pollution Control Boards (SPCBs)	State-level enforcement and facility authorization
PRO	Nepra Resource Management	Waste collection networks across 36 cities
PRO	Recykal	Digital marketplace connecting waste generators with recyclers
PIBO	Hindustan Unilever Limited	Leading FMCG company with integrated waste picker programs
PIBO	ITC Limited	WOW program covering 40+ cities
Recycler	Dalmia Polypro	India's largest PET recycler with food-grade rPET output
Technology	Saahas Zero Waste	Blockchain-based waste traceability
Advocacy	Alliance of Indian Wastepickers	Informal sector representation and rights
Research	Toxics Link	E-waste policy research and advocacy

Action Checklist

• Register on the CPCB EPR portal and submit annual action plans within the prescribed timelines for each waste category (plastic, e-waste, batteries)
• Map the informal waste collection ecosystem in operating geographies and develop integration strategies that maintain waste picker livelihoods
• Evaluate packaging portfolios for MLP content and develop phase-out plans for non-recyclable flexible packaging formats, prioritizing mono-material alternatives
• Establish due diligence protocols for EPR certificate procurement, including physical verification of recycler operations before entering purchase agreements
• Implement digital tracking systems for waste collection and processing to maintain auditable chain-of-custody documentation
• Monitor state-level enforcement trends and ensure consistent compliance across all operating states rather than relying on low-enforcement jurisdictions
• For e-waste obligations, partner with authorized recyclers who demonstrate adequate capacity utilization and environmental compliance
• Budget for escalating EPR costs as targets increase annually through 2028-29, with particular attention to MLP certificate pricing

FAQ

Q: How does India's EPR system differ from the EU's EPR framework? A: The most significant difference is structural. EU EPR operates through established PROs within mature municipal waste management systems where formal collection covers 90%+ of the population. India's system must function alongside a large informal waste sector, requiring integration models that have no European precedent. Additionally, India's EPR certificate trading system creates a market-based compliance mechanism, whereas most EU schemes use fixed fee structures. India's targets also differ: the EU's Packaging and Packaging Waste Regulation targets 65% recycling by 2025, while India's plastic EPR targets vary by material type and escalate on a different timeline.

Q: What are the penalties for EPR non-compliance in India? A: The penalty framework includes environmental compensation levied by the CPCB (calculated based on the shortfall between target and actual collection/recycling, multiplied by a per-tonne rate that varies by waste category), fines of up to INR 1 crore per violation under the Environment Protection Act, and potential registration cancellation that prohibits the sale of covered products in India. The National Green Tribunal can also impose separate penalties. In practice, enforcement has focused on show-cause notices and compliance timelines rather than maximum penalties, but the trend is toward stricter action as the system matures.

Q: Can multinational companies use global recycling credits to meet Indian EPR obligations? A: No. India's EPR system requires that collection and recycling occur within Indian territory. EPR certificates must be generated by CPCB-registered recyclers operating authorized facilities in India. There is no provision for cross-border credit transfer or offset. Companies operating in both India and the EU must maintain separate compliance programs for each jurisdiction, with separate budgets, partners, and reporting systems.

Q: How should companies approach the sachet and MLP challenge given limited recycling options? A: The practical approach involves three parallel strategies. First, redesign packaging to replace MLP with mono-material alternatives where technically feasible, accepting higher packaging costs (typically 15 to 30% more expensive) for materials that have established recycling pathways. Second, for products where MLP remains necessary, secure cement kiln co-processing partnerships that generate valid EPR certificates, while acknowledging that this represents energy recovery rather than material recycling. Third, invest in or support emerging MLP recycling technologies including pyrolysis and solvent-based dissolution, which are at pilot scale in India with several facilities expected to reach commercial operation by 2027.

Sources

• Central Pollution Control Board. (2024). Annual Report on Implementation of Plastic Waste Management Rules 2016 (as amended). New Delhi: Ministry of Environment, Forest and Climate Change.
• Central Pollution Control Board. (2025). EPR Portal: Registration and Compliance Statistics, January 2025. New Delhi: CPCB.
• Alliance of Indian Wastepickers. (2024). Informal Waste Sector Survey: Employment, Income, and Working Conditions. Pune: AIW.
• Indian Recycling Alliance. (2025). EPR Certificate Market Report Q4 2025: Pricing, Volume, and Trends. Mumbai: IRA.
• Hindustan Unilever Limited. (2025). Sustainability Report 2024: Packaging and Waste Management. Mumbai: HUL.
• ITC Limited. (2025). Sustainability Report 2024: WOW Programme Performance. Kolkata: ITC.
• Recykal. (2025). Annual Impact Report 2024. Hyderabad: Recykal Technologies Pvt. Ltd.
• Toxics Link. (2025). E-Waste Assessment 2024: Informal Sector Flows and Environmental Impacts. New Delhi: Toxics Link.
• Comptroller and Auditor General of India. (2024). Performance Audit of Waste Management Rules Implementation. New Delhi: CAG.
• Federation of Indian Chambers of Commerce and Industry. (2024). India Packaging Market Report: Trends, Volumes, and Sustainability Challenges. New Delhi: FICCI.