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  • Assistance in EPR Target Fulfilment in accordance with the EPR Action Plan.
  • Documentation for all stages in target completion and submission of the EPR Annual Report
  • Legal Assistance in any issue during the Authorisation or Consent process.
  • Coordinating with environmental agencies for any queries on behalf of the PIBO.

EPR Target Fulfilment for Plastic Packaging, E-Waste, Waste Battery and Old Tyres

India's EPR-related legislation identifies the entities that introduce a commodity into the market as a producer. EPR Regime makes them responsible for end-of-life waste management of their products based on the “Polluter Pays principle”. These entities include the producers, importers, and brand owners that indirectly are responsible for waste generation in the form of plastic packaging, e-waste, waste tyres and old batteries. EPR has created a legal responsibility for registration, return submission and EPR Target Fulfilment. The responsibility also covers environmentally sound management of co-processing/ recycling and disposal as per the principles enshrined under the Environmental (P) Act as a part of the extended legal responsibility. The EPR Targets are generated after successful registration on CPCBs dedicated EPR portals and take into account overall waste management activities, namely, the amount of waste collected, recycled, reprocessed, refurbished or disposed of as per the nature and the condition of the waste. After registration with the CPCB through the centralised EPR portal, the producers must ensure some EPR compliance. Similarly, at the same time, the waste recyclers are also obligated to follow the SOP and compliance requirements at the time of generating EPR certificates and have to ensure that the waste recycled/ disposed of is done with clear and auditable documentary proof.

Guidelines w.r.t EPR Target Fulfilment for Applicable Sectors

EPR guidelines have become a check mechanism for businesses to ensure that the different recycling entities, such as co-processors/ recyclers/ WTE plants, perform eco-friendly recycling and disposal methods. The E-Waste Management Rules, 2022, Plastic Waste Management Rules, 2016, , Hazardous Waste Management Rules, 2016 and the Battery Waste Management Rules, 2022 lay down the modalities of EPR in plastic packaging, e-waste, used tyres and battery manufacturing and recycling sectors respectively.

All identified entities under these rules must fulfil their respective EPR obligations w.r.t EPR Target fulfilment in order to keep operating in the country. The dedicated EPR portals have been designed by CPCB to function as a single-point data repository for registration, submission of data related to their operation/ trading of EPR certificates and submission of annual returns. The respective waste management rules also include the provision of heavy environmental compensation, surprise inspection by agencies, and cancellation of their CTO/ closure of the facility.


EPR Target Fulfilment for Plastic Packaging Business

The PWM Guidelines announced in 2022 stipulate mandatory EPR registration of Producers, importers and Brand Owners (PIBO) on a centralised CPCB portal (eprplastic.cpcb.gov.in/). The PIBOs, as well as the Plastic Waste processors (PWP), are required to register on the portal, while the PIBOs, in addition to the above, also need to submit an EPR Action Plan for plastic waste management through any of the following means.

  • Own Waste Collection/Distribution Channels
  • Through Urban Local Bodies (ULBs)
  • Through Waste Management Agencies (WMAs), which in turn channel waste through a ULB.

For EPR Target Fulfilment, these quantities must be recycled under their respective category only, i.e. I, II, III, IV. If you are a business that introduces a product in plastic packaging in the market in the four plastic categories (rigid, flexible, multi-layered or compostable plastic), you will need to register for EPR and work towards your EPR Target fulfilment. In case of a shortfall from the target, the PIBOs can also purchase the EPR credits from registered recyclers. However, it is important to note that PIBOs can only collaborate with registered recyclers/co-processors/ and PWPs who can recycle proportionate plastic waste on your behalf. The following table shows the EPR Targets for identified entities under the Plastic Waste Management Rules, 2016, for the year 2023-24.


Target for 2023-2024 (as a percentage of Eligible Quantity)





Brand Owner


Trading of EPR Plastic Certificates: There are certain legal requirements that the PIBO has to ensure to trade in EPR certificates safely. It is also important to note that PIBOs which are operational in one or two states/UTs are also required to register with the concerned SPCB/PCC. In case of EPR registration, you will need a copy of the certificate such as valid consent from SPCB, Company’s PAN, GST (the combined GST invoices if PIBO is operating in different States/UTs), PAN & Aadhar, details of Authorised person and details of the quantities of plastic packaging, etc. Enterclimate’s network of experienced consultants ensures EPR Target fulfilment through auditable documents along with assistance in trading EPR credits.

EPR Target Fulfilment in Case of E-waste


As per Schedule III and Schedule IV of the E-Waste Management Rules, 2022, businesses falling under the definition of producer, e-waste refurbisher, or recycler of EEE will have to ensure their EPR Target Fulfilment through the assistance of agencies like collection centres, refurbishers and recyclers and assist the process through buyback/takeback schemes in order to promote circularity in e-waste management.

Entities that manufacture and offer to sell EEE and their components under your own brand or offer to sell under your own brand any assembled EEE or components produced by other manufacturers/suppliers. In that case, you will be categorised as a producer. In addition to this, if you offer to sell imported EEE or components, irrespective of the selling mode such as dealer, retailer, e-retailer, etc.), you will fall under the definition of a producer.

The target is based on the estimated generation of E-Waste and is calculated for each Electrical and Electronic code for a particular financial year. The E-Waste Collection Target from 2023 onwards is 70% of the quantity of waste that is generated and indicated in the EPR Plan submitted by the entity. The following table shows the E-Waste Recycling Target as per the E-Waste Management Rules, 2022 for producers based on the


Category of Producer

E-Waste Recycling Target (by weight )

For producers who have started sales operations recently

15% of the sales figure for the financial year 2021-22

For the rest of the producers

60% of the quantity of EEE placed in the market in the year Y-X, where 'X' is average life of the product

EPR Target Fulfilment for Battery Business


EPR for batteries applies to used batteries, their components or spares (which may or may not be hazardous), pre-consumer off-spec batteries, and those batteries whose date for appropriate use has expired and batteries discarded by the user. The Battery Waste Management Rules 2022 now cover all types of batteries i.e. portable batteries, Electric Vehicle batteries, automotive batteries and industrial batteries.

If your business includes the manufacturing and sale of new batteries, refurbished batteries, and battery equipment under your brand name, then you are classified as a producer who needs to achieve EPR Target Fulfilment as per the targets generated by CPCB's EPR portal (http://www.eprbatterycpcb.in/).

Category of Producer

Mandatory Waste Battery collection target and 100% of refurbishment or recycling of the collection target for 2023-24

For portable batteries used in consumer electronics which are rechargeable

Minimum 60% of the quantity of battery placed in the market in 2018-19.

For portable batteries except those used in consumer electronics which are rechargeable:

The compliance cycle will start from 2025-26

For automotive battery

Minimum 50% of the quantity of batteries placed in the market in 2020-21.

For Industrial Battery:

Minimum 50% of the quantity of batteries placed in the market in 2020-21.

For Electric Vehicles (EV) Battery of E-rickshaw (three-wheelers)

Compliance cycle starts from 2024-25

For Electric Vehicles (EV) Battery of two-wheelers:

Compliance cycle starts from 2026-27

For Electric Vehicles (EV), battery comprising four wheelers

Compliance cycle starts from 2029-30

EPR Target Fulfilment for Tyre Business


Apart from producers of new tyres, businesses that import used tyres into the country will be categorised as producers and will have to fulfil their EPR targets. Moreover, importing waste tyres for recycling will put you under the definition of a producer.

As per Rule 7 of the HWM Amendment Rules, the producer is required to fulfil his EPR obligation as per the recycling targets that are auto-generated once the application is submitted. Recycling targets are calculated based on the Battery Collection Targets data and the Percentage of Battery Material in different Battery Types and Compositions by purchasing EPR certificate from recyclers and submitting it online on the portal by filing quarterly returns.


Although the producers have been provided with the flexibility to engage any other entity for recycling or refurbishment to meet its EPR obligations, that entity engaged must be registered and eligible to provide EPR certificates and auditable documentation. Producers and recyclers who do not comply with the provisions of this newly added schedule shall be liable to pay environmental compensation as determined in accordance with the guidelines laid down by CPCB.

If your business involves manufacturing and selling new tyres in India, selling new tyres under your brand name, or if your business sells new tyres manufactured by other manufacturers or suppliers, you will be classified as a producer. If you import and sell new tyres or vehicles fitted with new tyres, or if you are an automobile manufacturer who imports new tyres for use in new vehicles sold in India, you will need to register yourself as a producer on CPCB’s online portal (https://www.eprtyrescpcb.in/). For manufacturers or importers of new tyres, the EPR obligations have been tabulated below.


Waste Tyre Recycling Target in Weight (Kilogram or Tons)

for 2023-24

70% of the quantity of new manufactured or imported in the year 2021-2022

For 2024- 2025

100% of the quantity of manufactured or imported in the year 2022-2023.
After the year 2024-2025 (year Y), the EPR obligation will be 100% of the quantity of tyres manufactured/ imported in the year (Y-2).
For units established after the 1st of April 2022, the EPR obligation will start after two years (Y) and will be 100% of the tyres manufactured/ imported in the year (Y-2).

How will Enterclimate Assist You?

Overall Assistance in EPR Target fulfilment

Enterclimate provides complete assistance in EPR Target fulfilment for Producers, importers, brand owners and any other entity.

Comprehensive EPR Solutions Under one roof

Our experienced team of licencing and compliance environmental experts ensure seamless EPR registration, compliance and EPR certificate trading assistance in any part of the country.


Precise and Prompt customer support

Our experience of more than ten years has made us a market in EPR-related service providers backed by unmatchable client experience.


The CPCB, which is the nodal pollution control authority, is supervising the implementation of EPR in the entire country, along with the assistance of SPCBs/PCC. CPCB is managing dedicated centralised EPR portals for the registration of businesses that fall under the ambit of EPR.

The EPR regime has shifted the financial burden for waste management from municipalities and taxpayers to those producers and indirectly to the consumers who use these products. The producers, however, can include the added cost arising out of the waste management in the product's price so that the consumers of that product contribute to the recycling cost.

To reduce the public costs of waste management and promote a circular economy, the government has made clear guidelines and monitoring mechanisms to implement EPR.

The Plastic Waste (Management and Handling) Rules 2011 were applicable only to municipal areas. In contrast, the jurisdiction under the 2016 rules extends beyond the municipal areas to include outgrowths in urban agglomerations and rural regions. The 2016 Rules apply to every waste generator, local body, gram panchayat, manufacturer, importer, producer and brand owner.

Plastic packaging waste is generated by the end-use consumer after the intended use of packaging is completed and is no longer being used for its intended purpose.

If you procure the battery from other manufacturers or suppliers or import a battery or any equipment containing a battery, you will be classified as a producer and are required to register on the CPCB portal in form (A) and fulfil your EPR Targets. However, if you import batteries to supply them to other manufacturers/dealers and the manufacturers/dealers are selling those batteries in the market under their brand name, then you don't require EPR registration.

For the registration under EPR for battery, the producer will need a copy of the consent NOC company's PAN, CIN & GST of the Producer/Manufacturers, etc.

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