EPR Compliance in India 2025–26: What plastic packaging manufacturers must know
What is EPR, and who does it apply to?
Extended Producer Responsibility for plastic packaging in India — formalised as EPR under the Plastic Waste Management Rules, 2016, and the subsequent amendments to the PWM Rules — makes producers, importers, and brand owners (PIBOs) responsible for the plastic packaging they place on the market. It applies to every PIBO, except micro and small enterprises as defined under the MSME framework, introducing plastic packaging into India, and to plastic waste processors and recyclers, all of whom must register on the applicable EPR portal. For businesses dealing with flexible packaging, CPCB EPR registration for flexible packaging is an essential part of regulatory compliance. The EPR framework applies across all five plastic packaging categories: rigid (Category I), flexible (Category II), multilayered (Category III), compostable (Category IV), and biodegradable (Category V). Registration is a fundamental compliance requirement for entities covered under the EPR framework, making it the first step toward meeting their plastic waste management obligations.
Recycled content mandates: what’s now mandatory in 2025-26
Since 2025-26, the EPR framework introduces a mandatory minimum recycled-content threshold on top of the collection and recycling obligation. Rigid packaging (Category I) needs 30% recycled content in 2025-26, rising to 40% in 2026-27, 50% in 2027-28, and 60% from 2028-29. Flexible packaging (Category II) needs 10% through 2026-27, stepping up to 20% from 2027-28. Multi-layered packaging (Category III) needs 5% through 2026-27, rising to 10% from 2027-28. For PIBOs, this is the single biggest formulation change EPR has introduced: recycled plastic used to meet these thresholds must conform to IS 14534:2023, while food-contact applications must also comply with the applicable requirements of the Food Safety and Standards Authority of India.
The 2026 amendment also provides a limited carry-forward mechanism for an unfulfilled 2025-26 recycled-content obligation in food-contact applications. Such shortfalls may be carried forward for up to three consecutive years from 2026-27, subject to the requirement that at least one-third of the carried-forward obligation is fulfilled in each year.
EPR targets by packaging category (rigid, flexible, multilayered)
Recycled content targets are separate from the recycling obligation, which measures how much of a PIBO’s plastic packaging obligation must actually be collected and recycled. Collection has stood at 100% of the eligible quantity since 2023-24. Recycling targets are phased by category: Category I (rigid packaging) must hit 60% in 2025-26, 70% in 2026-27, and 80% from 2027-28; Category II (flexible packaging) and Category III (multilayered packaging), the target is 40% in 2025-26, 50% in 2026-27 and 60% from 2027-28 onwards. For the flexible packaging industry specifically, that means the recycling target climbs to 60% by 2027-28 even though the recycled-content obligation tops out at 20% over the same period — two separate numbers that are easy to conflate. Rigid packaging also carries a reuse target rising through 2028-29, and misclassifying packaging into the wrong category remains one of the most common compliance errors flagged by CPCB.
What happens if you miss EPR targets?
A shortfall against any target draws environmental compensation: ₹5,000 per tonne for the first year, ₹10,000 per tonne for a second consecutive year, and ₹20,000 per tonne for a third, under CPCB’s environmental compensation guidelines. The obligation itself doesn’t disappear — it carries forward for three years, and a large share of the compensation is refunded once the shortfall is cleared. That makes environmental compensation a financing cost rather than a way to settle the obligation permanently. CPCB audits have also stepped up scrutiny of EPR certificates themselves, so working with registered, verifiable processors matters as much as hitting the numeric target.
How recycled granule suppliers help you stay compliant?
Meeting the recycled-content mandate depends on a steady, tested supply of recycled plastic granulesBB that match the packaging category and process a converter is running. A manufacturer of plastic granules that documents MFI, density, and PCR percentage per batch, and can show conformance to IS 14534:2023, gives a PIBO’s compliance team something concrete to point to when a return is reviewed. Since importers cannot count recycled content built into imported packaging toward their own obligation, brands sourcing packaging domestically have a more direct route to the recycled-content threshold through their granule supplier’s traceability.
Lucro’s role in EPR compliance
Lucro, a flexible packaging company in India and flexible packaging manufacturer, supplies Post-Consumer Recycled (PCR) polyolefin granules — rHDPE, rLDPE, and rPP — and PCR-based flexible and retail packaging with 30% to 100% PCR content, with each batch tested and backed by a technical data sheet before it reaches a converter’s line. That combination gives PIBOs sourcing through Lucro a documented recycled-content trail to support EPR compliance in India, whether they’re buying granules to run their own packaging lines or PCR-based packaging ready to fill.
Steps to take before your next annual return
Before filing, re-map your packaging portfolio against the correct category, since rigid, flexible, and multi-layered packaging carry different recycling and recycled-content targets. Confirm your recycled-content supply meets IS 14534:2023 and is documented per batch, not just claimed in aggregate. Reconcile declared quantities against actual invoices and processor certificates well before the 30 June filing deadline, and keep records that would hold up under a registered environment auditor’s review. This overview reflects publicly available CPCB guidelines; given how frequently thresholds and procedures are amended, confirm current requirements directly on the CPCB EPR portal or with your compliance advisor before filing.
