Who needs to register for EPR, and for what?
Under the Plastic Waste Management Rules, three categories of entity carry EPR obligations: producers who manufacture plastic packaging material, brand owners who use that packaging to sell goods under their own brand, and importers who bring packaged goods or raw packaging material into India. If your business falls into any of these roles and you handle plastic packaging above the minimal threshold set by the rules, registration on the CPCB's centralised EPR portal is mandatory, not optional.
Registration itself is the easy part. The harder, ongoing part is correctly classifying every packaging format you place on the market into the right EPR category, since the targets, the reporting format, and the fees all depend on getting that classification right the first time and keeping it consistent across filing cycles.
How are plastic packaging categories defined under EPR?
The rules split packaging into distinct categories. Category I covers rigid plastic packaging. Category II covers flexible plastic packaging of single layer or multilayer construction used for primary packaging. Category III covers multi-layered plastic packaging combining more than one layer of plastic with another material. Category IV is reserved for plastic packaging made of compostable plastic, and Category V covers plastic sheet or carry bags and other forms not covered elsewhere, including biodegradable plastic as a separate class from compostable.
Each category carries its own recycling or end-of-life target, and for Categories I to III those targets increasingly require a minimum share of recycled plastic input, verified against the relevant Indian standard. Category IV, compostable packaging, is assessed differently: its compliance basis is valid IS 17088 certification and CPCB registration of the product rather than a recycled-content percentage, since the material is designed to be composted rather than mechanically recycled.
What does the ongoing filing cycle look like?
Once registered, a brand owner files periodic returns on the CPCB portal declaring the quantity of plastic packaging placed on the market, broken down by category, and reconciles this against fulfilment of the applicable target for that year, whether that is a recycling obligation, a recycled-content percentage, or, for compostable packaging, certification evidence. Shortfalls against a target typically attract an environmental compensation fee, calculated on the uncovered quantity, so an inaccurate or incomplete filing is not a paperwork problem alone, it is a direct cost.
Brand owners also need to keep their supplier documentation current, since a packaging format can only be declared under Category IV if the specific product carries valid, traceable certification. A supplier who cannot produce an IS 17088 test report and an active CPCB certificate for the exact product you are buying is not a Category IV supplier in the eyes of an audit, whatever the packaging says on its own label.
How should a brand build an audit-ready EPR process?
Start with a packaging register that lists every format you use, its EPR category, its supplier, and the certification or recycled-content evidence behind it, updated whenever you change a supplier or a specification. Reconcile this register against your actual purchase volumes before every filing cycle, not after a notice arrives, since restating a past filing is far more disruptive than filing correctly the first time.
Anjaneya Bio Products supplies compostable bags and films first, along with compostable granules and masterbatch for converters, manufactured to IS 17088 and backed by CPCB registration, with the certification pack available on request so brand owners can declare these products under Category IV with a clean, defensible paper trail rather than a marketing claim they cannot support at audit.
Key takeaway
EPR compliance is an ongoing filing obligation, not a one-time registration. Producers, brand owners, and importers must classify every packaging format into the correct category, Categories I to III for conventional plastic against recycling and recycled-content targets, and Category IV for certified compostable packaging, then file accurate periodic returns backed by real supplier documentation. Getting the category or the certification wrong costs money through environmental compensation fees, not just compliance risk.