EPR registration for importers, producers and brand owners
Customs now checks your EPR registration before it releases your imports. Plastic packaging, electronics and batteries each need their own. We prepare and file each registration and your yearly returns. You sign where the law asks.
Each rule takes its own registration. Under the plastic rules each role does too.
What does your business do?
You register as an importer
If you import goods in plastic packaging for your business the plastic rules count you as an importer. The same goes for plastic itself: resin, pellets, film, preforms, sheets and carry bags. Customs checks that registration before it releases them. Electronics and batteries need their own registrations as well.
If you sell goods in plastic packaging under your registered brand or trade mark you are a brand owner under the plastic rules. That holds when a contract manufacturer packs them for you too. Sell electronics or batteries under your name and you count as a producer under those rules. If you also import the plastic rules ask you to register again as an importer.
You register as a producer
That covers plastic packaging and the films and preforms that go into it. It also covers a contract manufacturer who packs goods for a brand. Micro and small producers register too. Whoever sells them the plastic raw material takes on their recycling target. They still meet the target for recycled plastic in their packaging. We add your plant's consent from the pollution control board to the application.
You need e-waste EPR
It covers the electrical and electronic goods on the e-waste list. You are a producer if you sell them under your brand, whoever manufactures them. You are one too if you import them to sell. The rule's words also reach a trader who sells imported goods from the list. A plant that manufactures listed goods registers as a manufacturer too. Importers of used equipment register as well. CPCB registers every producer.
You need battery EPR
Anyone who imports batteries or goods with batteries inside is a producer. Batteries you import for your own use count too. Brands that sell batteries under their own name register as well, on their own or inside equipment. So does a firm that manufactures or assembles batteries for a brand to sell under the brand's name. A dealer who sells a brand's batteries under that brand needs no registration.
Tyres and oils have rules of their own
Tyres and oils have rules of their own. For tyres they cover manufacturers, brands and sellers of imported new tyres. Importers of vehicles fitted with new tyres and of waste tyres register too. For oils they cover the brands of base oil and lubricating oil, sellers of imported oil and importers of used oil. Talk to us about your case.
Every applicant needs these. Importers also give their IEC.
PAN
GST registrationGST
An authorised personSignatory
Your figures by productFigures
EPR registrationEPR
The papers the board asks for
Business papers
Your PAN and GST certificate. A company adds its CIN.
The person who signs
Your authorised person's PAN and Aadhaar, and a scan of their signature.
For importers
Your IEC. It links the registration to your imports.
For plastic
The packaging you put on the market by category, with your past figures.
For electronics
Each product matched to the e-waste list. Your sales and a declaration on hazardous substances.
For batteries
Each type you sell and the brand it goes under. Importers give their own brand, not the foreign one.
For a plant
Its consent from the pollution control board where it needs one. Packaging producers add a chart of the process.
A covering letter
It goes in with the application. We draft it for you.
How we get your EPR registration
We prepare the file and deal with the board. You sign where the law asks you to.
We match what you do to each rule. Then we list each role you hold under it: importer, producer or brand owner.
We gather your figures by product and by kind of packaging. Then we fill in the form on CPCB's portal. We attach each paper to it.
Your authorised person signs the declarations. Then we file the application from your account.
CPCB or your state board may ask for more. We draft each reply. Your authorised person sends it from your account.
The board grants your registration on the portal. We keep a copy on file for your imports.
We upload your registration with each bill of entry. Customs checks it before it releases your goods.
How we keep your EPR registration in order
Plastic and battery registrations no longer run out. The returns still fall due every year.
Yearly return
Every year
We prepare your return from your records. It shows what you put on the market and how you met your target. We file it from your account.
E-waste returns
Every quarter
E-waste producers file a return each quarter as well as each year. We prepare and file your yearly return.
Your target
Every year
Each rule sets yearly targets from what you put on the market. Most are met with certificates from registered recyclers and processors. The plastic and battery rules also ask for recycled material in what you sell. Brand owners with rigid plastic packs have reuse targets too. Your return shows how you met each one.
Changes to the registration
When things change
We file the change when you add a product, a brand, a state or a new address.
Your number on the pack
On every pack
Brand owners and producers show their plastic registration number on their packaging. It can be printed, carried in a QR code or barcode, or given in the product brochure. You tell CPCB which way you use. Battery producers do the same on the battery, the equipment or its packaging. We tell you which of your packs need it.
Authorised person
When your signatory changes
The portal links your account to your authorised person's PAN. We update it when that person changes.
Where EPR registrations go wrong
Most trouble starts with a role or a category the registration leaves out.
What goes wrongWhat we do
What goes wrong: Your goods are not plastic so nobody registers you. Customs then holds your bill of entry for the plastic packaging.
What we do: We register you as an importer before your first shipment.
What goes wrong: A brand that also imports holds only its brand owner registration.
What we do: We register each role you hold: importer, producer and brand owner.
What goes wrong: A new kind of packaging falls in a category your registration does not show.
What we do: We sort each kind of packaging into its category before we file.
What goes wrong: Nobody files the yearly return. The board sends a notice and can levy environmental compensation.
What we do: We prepare your return from your records and file it in good time.
What goes wrong: A battery importer enters the foreign brand on the form.
What we do: We enter your own brand, as CPCB asks.
What goes wrong: Your old account is not linked to CPCB's common EPR portal. The PAN details do not match.
What we do: We link it with the same company PAN and authorised person's PAN as before.
How our customs team and warehouses fit in
Your registration belongs to your business. We show it to customs at the port.
Checked at the port
Our customs team files your bill of entry. We upload your EPR registration with it so customs can check it straight away.
One team for your product approvals
The same team files your EPR, BIS and other product approvals. So your papers agree when your goods reach the port.
Stock in new states
Plastic registration sits with CPCB or with the board of each state you work in. It depends on how many states you work in. We check where yours belongs as your stock moves into new states.
EPR stands for Extended Producer Responsibility. Whoever puts a product or its packaging on the Indian market answers for it once it becomes waste. You register with CPCB or your state pollution control board. Then you file a return each year. Most businesses also meet a yearly target.
Is EPR registration mandatory for importers?
Yes, for most. The plastic rules count anyone who imports goods in plastic packaging for business as an importer. The same goes for plastic raw material, film and preforms. Customs checks that registration before it releases the goods. Importers of listed electronics, batteries and goods with batteries register under their own rules too.
Why does customs ask for plastic EPR when my goods are not plastic?
Because the packaging counts. Film, bubble wrap and plastic bags round your goods are plastic packaging. So the plastic rules count you as an importer of it. Customs checks that registration before it releases your goods.
What is a PIBO?
PIBO stands for producer, importer or brand owner. These are the roles in the plastic rules. A producer manufactures plastic packaging or the film and preforms that go into it, or packs goods for a brand. An importer brings in plastic packaging, goods packed in it, carry bags, sheets or plastic raw material for business. A brand owner sells goods under its registered brand or trade mark. Online marketplaces and retail chains count as brand owners too. You register separately for each role you hold.
How do I get EPR registration for plastic packaging?
You apply on CPCB's common EPR portal. You give your PAN and GST, your IEC if you import and your figures by kind of packaging. CPCB or the board of each state you work in registers you, depending on how many states you work in. We prepare and file it from your account. Your authorised person signs.
Is EPR registration valid for one year or for life?
Plastic registration no longer needs renewing. Customs accepts older plastic certificates that still show an end date. A battery registration also stays valid until it is cancelled. For e-waste we check the terms on your certificate.
Do I need e-waste EPR to import electronics?
Yes, if your goods are on the e-waste list and you import them to sell. The rules count you as a producer. Brands that sell listed goods under their own name count too. So do importers of used equipment. CPCB registers every producer. The rule's words also reach a trader who sells imported goods from the list. We check where you stand.
Do I need battery EPR for goods with batteries?
If you import them, yes. An importer of goods with batteries inside is a producer, even for goods you use yourself. CPCB registers you. You give your own brand on the form, not the foreign brand. If you manufacture the goods in India with another producer's batteries under that producer's brand, that producer carries the duty.
Is EPR required for MSME?
It depends on the rule and your role. An importer needs plastic registration whatever its size. Micro and small producers of packaging register too. Their recycling target passes to whoever sells them the raw material. They still meet the recycled plastic target. Micro and small brand owners carry no plastic target. Micro enterprises fall outside the e-waste rules. The battery rules give no relief for size. We check where you stand.
When is the EPR annual return due?
Soon after the financial year ends. It covers the year just gone. Plastic and battery returns are yearly. E-waste producers also file each quarter. We prepare and file your yearly returns in good time.
What is the common EPR portal?
CPCB has moved plastic EPR to one common portal. You sign in to its other EPR portals through the same login. To link your old account you register with the same company PAN and authorised person's PAN. We link it with you and check the data that moved.
What is the penalty for not having EPR registration?
You may not carry on the business without it. Customs can hold your goods at the port. The board can also levy environmental compensation. It can act under the Environment (Protection) Act as well.
