Plastic Waste and EPR Guide: What India’s Plastic Rules Require and How Companies Go Beyond Compliance
Plastic EPR in plain language, updated for the March 2026 amendment: who is obligated, the targets, certificates, labelling and penalties. Plus the Huhtamäki-funded Mithi River case, ten years of Earth5R plastic data, and what six companies in the Above Average band of TERRA, Earth5R’s ESG intelligence platform, report. With a free EPR compliance tracker and plastic packaging policy.
What the guide covers
- Why plastic is now a business risk
- Plastic and EPR in India by numbers
- EPR in one page
- The targets
- Labelling, bans and penalties
- What changed, 2021 to 2026
- EPR is not CSR: comply, redesign, recover
- Case study: the Mithi River
- Ten years of Earth5R plastic data
- Best cases from TERRA
- Design it out
- A 12-step EPR compliance plan
- A community plastic recovery programme
- Claims: what you can and cannot say
- Measuring and reporting
- Checklist for boards and CXOs
- Glossary of plastic and EPR terms
Free templates
EPR Compliance Tracker (Excel)
An SKU register that totals plastic by category, the obligation for the year you choose (minimum recycling, maximum end-of-life, recycled content), a certificate log, a status sheet with indicative environmental compensation, and a filing calendar.
Plastic Packaging Policy (Word)
Ten sections with fill-in brackets: commitments, EPR compliance, processor due diligence, community recovery kept separate from EPR, claims rules, governance, reporting and review.
Plastic and EPR in India by numbers
India generated 41.4 lakh tonnes of plastic waste in 2022-23. 60,128 producers, importers and brand owners and 3,012 plastic waste processors are registered on the EPR portal, and about 207 lakh tonnes of plastic packaging waste have been recycled under EPR since 2022. In Earth5R’s ten-year field data, plastic’s share of city waste rose from 21.5% to 32.6%, and multilayer packaging grew 162.8%.
EPR targets for plastic packaging
The EPR target is 100% of Q1 from 2023-24. Within it, minimum recycling rises every year, and recycled content becomes mandatory from 2025-26.
| Minimum recycling | 2024-25 | 2025-26 | 2026-27 | 2027-28 on |
|---|---|---|---|---|
| Cat I rigid | 50% | 60% | 70% | 80% |
| Cat II flexible | 30% | 40% | 50% | 60% |
| Cat III multilayer | 30% | 40% | 50% | 60% |
| Cat IV compostable (industrial composting) | 50% | 60% | 70% | 80% |
| Recycled content | 2025-26 | 2026-27 | 2027-28 | 2028-29 on |
|---|---|---|---|---|
| Cat I rigid | 30% | 40% | 50% | 60% |
| Cat II flexible | 10% | 10% | 20% | 20% |
| Cat III multilayer | 5% | 5% | 10% | 10% |
EPR is not CSR: comply, redesign, recover
EPR is a statutory obligation, and CSR Rule 2(1)(d) excludes “activities carried out for fulfilment of any other statutory obligations”, so EPR cannot be paid for from CSR. CSR still has a role: community recovery of the plastic EPR does not reach, support for waste pickers, and river and coastal work. Redesign, the third job, is funded from product and packaging budgets.
Best cases from TERRA: plastic and waste
Each company below sits in the Above Average band of TERRA. We read their own reports for plastic and waste practices others can copy.
| Company | What their reports show | Worth copying |
|---|---|---|
| Hindustan Unilever | Plastic neutral since 2021; 8,37,000 t collected and processed cumulatively by 2025; meets EPR by buying credits from processors via the CPCB portal; 25 brands use recycled plastic; 7 material recovery facilities under Project Circular Bharat | Report compliance and reduction targets side by side |
| Dalmia Bharat | Co-processes municipal and industrial plastic waste in cement kilns, reporting recycling more than 11 times the plastic in its packaging (FY2024-25); 55 lakh PP bags from reprocessed plastic | Use your own industrial process as a recovery route |
| ABB India | 276.07 t plastic waste in 2024, 154.67 t recycled including EPR packaging; certified single-use-plastic-free premises | Disclose plastic separately, with the EPR share explained |
| HCLTech | All Indian campuses free of single-use plastics; TRUE Zero Waste certified campuses; work with RiverRecycle on the Yamuna prevents about 15 t of debris a month | Own operations first, then river recovery |
| Tata Steel | EPR registration as brand owner and importer; 81% reduction in waste sent to landfill in FY2024-25 | Register every role you play in the plastic chain |
| Infosys | 98% of waste diverted from landfill; TRUE zero waste certification for three campuses | Certified zero-waste sites as proof points |
Case study: the Mithi River
Huhtamäki, the global packaging company, funded a €0.6 million project delivered by Earth5R with United Nations Technology Innovation Labs, RiverRecycle and the Municipal Corporation of Greater Mumbai. It recovered 4,440 tonnes of plastic from the river between 2020 and 2024, sending high-value plastic to recycling and low-value plastic through pyrolysis, while 10,000 families were trained in the catchment. Read the Mithi case study.
12 steps to plastic EPR compliance
- Map every SKU: pack weight, category, polymer, units, states
- Register on the CPCB centralised EPR portal in every role you play
- Calculate the obligation by category: Q1, minimum recycling, maximum end-of-life, recycled content, reuse
- Choose processors carefully: registration, category, installed capacity, GST and transport records
- Buy or generate certificates through the year, not in March
- Plan recycled content by category, starting with rigid packaging
- Label packs with your EPR registration number (or the barcode/QR option)
- File returns by 30 June; confirm processors filed by 30 April
- Model environmental compensation on any shortfall and report it to the board
- Redesign: grams per pack, mono-material, refill and reuse
- Fund community recovery beyond compliance, kept separate from EPR
- Report in BRSR Principles 2 and 6, with claims backed by data
Cite or share this guide
Packaging, compliance, CSR and ESG teams, industry bodies, NGOs and universities are welcome to link to this page, add it to reading lists or training material, and embed the infographics. Please link to this page rather than the PDF, so readers always get the latest edition.
Questions
Is the Plastic Waste and EPR Guide free?
Yes. The guide, the EPR Compliance Tracker (Excel) and the Plastic Packaging Policy (Word) are free to download without a sign-up, and free to share or adapt with credit to Earth5R.
Who has to comply with plastic EPR in India?
Producers, importers and brand owners (PIBOs) of plastic packaging, and plastic waste processors, under Schedule II of the Plastic Waste Management Rules, 2016. Brand owners that are micro or small enterprises are excluded. All must register on the CPCB centralised EPR portal.
What are the EPR recycling targets for plastic packaging?
The EPR target is 100% of Q1 from 2023-24. Minimum recycling rises by category: for rigid packaging 50% in 2024-25, 60% in 2025-26, 70% in 2026-27 and 80% from 2027-28; for flexible and multilayer packaging 30%, 40%, 50% and 60%.
What is the penalty for not meeting EPR targets?
CPCB guidelines of April 2024 set environmental compensation at ₹5,000 per tonne of shortfall for the first instance, ₹10,000 for the second and ₹20,000 for the third. Paying compensation does not remove the obligation, and it is partly refunded if the shortfall is made up within three years.
Can CSR funds be used to meet EPR obligations?
No. CSR Rule 2(1)(d) excludes activities carried out to fulfil any other statutory obligation, and EPR is a statutory obligation. CSR can fund community plastic recovery beyond EPR, kept separately.
What changed in the 2026 amendment to the Plastic Waste Management Rules?
G.S.R. 237(E) of 31 March 2026 redefined end-of-life disposal, required IS 14534:2023 marking for recycled plastic, gave enforcement roles to local bodies and panchayats, exempted recycled-content and reuse targets where food and drug regulators prohibit them, and allowed a three-year carry-forward for 2025-26 shortfalls.
Can I use the infographics on my website?
Yes. Each infographic on this page has embed code. Please keep the credit link to this page.
Download the Plastic Waste and EPR GuidePlan plastic recovery with Earth5R