EPR Registration for Producers and Brand Owners

Key Eligibility Criteria for EPR Registration for Producers and Brand Owners

The key eligibility criteria to obtain EPR registration for producers and brand owners in India are as follows:

• The entity must be involved in the manufacturing of plastic waste.
• The entity must produce or supply plastic raw materials intended for use in the packaging manufacturing.
• The entity must be legally registered under the Companies Act, 2013.
• The entity must possess an import export code certificate for regulating raw materials or finished goods.
• The entity must verify the manufacturing footprint and operational capacity.

Who Needs to Apply for EPR Registration for Producers and Brand Owners?

The following is the list of applicants eligible to apply for EPR registration for producers and brand owners:

• Any company or manufacturer of plastic packaging, EEE, batteries, or tyres in India.
• Any entity whose brand, trademark, or logo appears on a product or packaging under EPR categories.
• Any entity importing plastic-packaged goods, EEE, batteries, or tyres into India.
• E-commerce platforms selling products under a private label or brand.
• Entities involved in the refurbishment and reselling of EEE and above prescribed volumes.

Step-by-Step Procedure to Obtain EPR Registration for Producers and Brand Owners

The entities applying for EPR registration for producers and brand owners must comply with the step-by-step procedure, as discussed below:

1. Step: Determine EPR Category
   The first step requires the applicant to identify and determine the EPR category, including plastic waste, e-waste, battery, or tyre.


2. Step: Obtain DSC for Authorized Signatory
   The next step requires the applicant to obtain a class 2 or class 3 DSC from a licensed certifying authority before proceeding.


3. Step: Compile & Verify Necessary Documents
   The next step requires the applicant to compile and verify the necessary documents to avoid delays in processing EPR registration for producers and brand owners.


4. Step: Register on the Relevant CPCB EPR Portal
   The next step requires the applicant to file an online application and submit the necessary documents on the official CPCB EPR portal.


5. Step: CPCB/SPCB Scrutiny
   In the next step, the CPCB or the State Board reviews the submitted application and may seek clarification regarding their accuracy and completeness.


6. Step: Issuance of EPR Registration Certificate
   Upon successful scrutiny of the application and resolution of the query, the CPCB or the State Board authorizes the issuance of the EPR registration certificate.

Mandatory EPR Compliance Requirements for Producers and Brand Owners

The producers and brand owners must comply with the following EPR compliance requirements for producers and brand owners:

• File Annual Returns: It is important for the producers and brand owners to comply with strict filing schedules to meet annual & quarterly EPR return requirements and demonstrate target fulfilment.
• Track Product Volume: The producers and brand owners are required to accurately declare the total weight of products or packaging materials introduced into the domestic market.
• Collect & Recycle Quotas: The producers and brand owners must ensure compliance with the specific escalating annual targets set for the collection, recycling, and recovery of generated waste.
• Authorize Partner Tie-Ups: For Port-EPR registration, producers and brand owners must partner with CPCB-authorized recyclers, refurbishers, or producer responsibility organisations to ensure seamless processing of waste.
• Formulate EPR Action Plan: The PIBOs must formulate and submit an actionable EPR plan detailing the entire process for the collection, transportation, and processing of post-consumer waste.
• Timely Renewal: It is important for producers and brand owners to apply for the timely renewal of EPR registration to avoid compliance gaps before the registration expires.