Extended Producer Responsibility in India: Notes for Foreign Manufacturers

Extended producer responsibility (EPR) is a key sustainability policy in several markets, including India, and aligns with developing a circular economy, climate action commitments, waste management, and ESG corporate objectives. For foreign manufacturers, importers, and brand owners entering the Indian market, EPR can be a regulatory requirement, depending on the sector. However, it is also increasingly becoming a strategic imperative that shapes market access, supply chain resilience, brand credibility, and long-term competitiveness.

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EPR mandates shift the responsibility for end-of-life product management – from collection and recycling to environmentally safe disposal – onto producers. These obligations now extend across key sectors, including plastics, electronic waste, batteries, packaging, and tires, with stringent compliance expectations, digitized reporting systems, and escalating penalties for non-compliance.

For companies that act early, however, EPR compliance can do more than mitigate regulatory risks – it can unlock access to green capital, business-to-business (B2B) procurement opportunities, consumer trust, and ESG-linked growth incentives in one of the world’s fastest-growing consumer and industrial markets.

Understanding extended producer responsibility in India

Extended producer responsibility is a policy approach where producers are made responsible for the entire lifecycle of the products they introduce into the market, including post-consumer waste management. The principle is rooted in the “polluter pays” concept and aims to reduce the environmental impact of products by integrating their end-of-life management into the production and distribution process.

Evolution of India’s EPR framework

• 2016: India introduced EPR mandates under the Plastic Waste Management (PWM) Rules and E-Waste (Management) Rules, making producers responsible for collection and recycling.
• 2022: The central government expanded and tightened EPR obligations, launching digital compliance portals, setting quantitative recycling targets, and introducing credit trading mechanisms.
• 2023-2025: New frameworks for batteries, packaging materials, tires, and multi-layered plastics are being rolled out, with additional sectors – including textiles – under policy consideration.

These changes align with India’s commitments under the UN Sustainable Development Goals (SDGs) and its national strategies on circular economy, climate action, and resource efficiency.

Why EPR matters for foreign businesses

Manufacturers and producers are at the core of the ERP framework. For foreign manufacturers, EPR is a key compliance checklist and a strategic determinant of market entry, competitive positioning, and investor confidence.

Regulatory and legal risks

• Market access: Non-compliance with EPR mandates can lead to denial of market entry or suspension of product licenses.
• Penalties: Companies may face substantial fines, revocation of registration, or legal action under environmental laws.
• Reputational damage: Violations can trigger negative publicity and ESG downgrades – critical risks for listed companies and global brands.

ESG and investor expectations

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Global investors increasingly assess EPR performance as part of ESG due diligence. Companies demonstrating robust end-of-life product management are better positioned to attract green financing, sustainability-linked loans, and preferential procurement contracts.

Supply chain and B2B pressures

Major Indian corporations, especially in FMCG, automotive, and electronics, now require their suppliers to demonstrate EPR compliance. Early adoption can open doors to lucrative B2B partnerships and long-term contracts.

Sector-wise EPR compliance framework in India

Plastics: Plastic Waste Management (PWM) Rules, 2016, and its amendments

Scope: Producers, Importers, and Brand Owners (PIBOs) dealing in plastic packaging; plastic waste processors engaged in (a) recycling, (b) waste to energy, (c) waste to oil, and (iv) industrial composting.

Key obligations:

• Register on the CPCB’s EPR portal before selling or importing products in India.
• Meet annual recycling targets based on the quantity and type of plastic placed on the market.
• Submit annual EPR returns demonstrating compliance.
• Ensure environmentally sound disposal of residual waste.

Plastic packaging categories under EPR

• Category I: Rigid plastic packaging.
• Category II: Flexible plastics (single or multilayer), including plastic sheets, covers, carry bags, sachets, or pouches.
• Category III: Multilayered packaging that combines plastic with other materials.
• Category IV: Plastic sheets and carry bags made from compostable plastics.

Note: The EPR target for plastic packaging made from compostable plastic is 100 percent from 2023-24, as per the Ministry of Environment, Forest and Climate Change (MoEFCC).

Multinationals like Unilever have successfully integrated EPR into their India operations by developing collection networks and partnering with recycling startups. Unilever’s “Waste No More” initiative recovers over 60,000 tonnes of plastic annually – positioning the company as a sustainability leader and improving its procurement eligibility with major retail chains.

E-Waste: E-Waste (Management Rules), 2022

Scope: Under the E-Waste (Management) Rules, 2022, ‘Electrical and Electronic Equipment’ (EEE) means equipment which are dependent on electric current or electro-magnetic field in order to become functional and also the equipment for the generation, transfer and measurements of the electricity.

The following entities are required to register on the CPCB portal to fulfill their EPR obligations:

1. Manufacturer;
2. Producer;
3. Refurbisher; and
4. Recycler.

Key obligations:

• Register with the CPCB’s online EPR system.
• Collect e-waste generated during the manufacture of any electrical and electronic equipment and ensure its recycling or disposal.
• File annual and quarterly returns in the available form on the portal on or before end of the month succeeding the quarter or year, as the case may be, to which the return relates.

E-waste collection targets:

1. General EPR obligations for producers

Producers must achieve recycling of e-waste generated, in a phased manner as follows:

2. EPR obligations for new producers

For producers who have only recently started sales (i.e., their years in operation are fewer than the average product life defined by CPCB guidelines), the following e-waste recycling targets apply:

• 2023-24: Recycle 15 percent of sales made in FY 2021–22.
• 2024-25: Recycle 20 percent of sales made in FY 2022–23.
• 2025-26 onwards: Recycle 20 percent of sales made two years prior.

Apple, which runs a robust global product take-back program, has extended similar initiatives in India, working with authorized recyclers for iPhone and Mac components. This has helped Apple expedite regulatory approvals for new product launches and enhance its ESG ratings with institutional investors.

Batteries: Battery Waste Management Rules, 2022

Scope: Manufacturers and importers of portable, automotive, industrial, and EV batteries.

Key obligations:

• Register as a producer and ensure collection and recycling of used batteries.
• Meet annual collection and recycling targets (e.g., 70 percent by 2025, 90 percent by 2027).
• Use authorized recyclers and obtain EPR recycling certificates.
• Submit annual compliance reports.

India’s EPR framework for battery waste management sets phased recovery targets, as shown in the table below.

The framework includes an EPR credit trading system – producers that exceed recycling targets (such as refurbishers) can sell credits to others, creating a secondary compliance market.

Increasingly, companies are aiming to recover resources from spent batteries to reduce waste and meet the demand for materials like lithium, cobalt, and nickel:

• Tata Motors and Ola Electric are investing heavily in battery recycling partnerships.
• Tata Chemicals is actively engaged in lithium-ion battery recycling, focusing on recovering valuable materials and establishing pilot programs to develop scaled-up operations.
• Gravita India is a significant player in battery recycling, planning to set up a lithium-ion battery recycling unit in Mundra and having tie-ups with other battery companies for raw material sourcing.

Tires and packaging: Emerging EPR regulations

India’s Extended Producer Responsibility (EPR) for tires mandates that tire producers and importers are responsible for the environmentally sound management of waste tires, including collection, recycling, and proper disposal. The regulations came into effect in 2022, setting phased-in targets for the quantity of tires producers must manage annually. All entities, including manufacturers, importers, recyclers, and retreaders, must register on the CPCB portal [EPR Portal for Management of Waste Tyre] to comply with these rules and can face penalties for non-compliance.

Reliance Industries has pioneered chemical recycling technologies to convert end-of-life plastic and tire waste into petrochemical feedstock like pyrolysis oil to produce ISCC-Plus certified circular polymers such as CircuRepol™ (polypropylene) and CircuRelene™ (polyethylene). This process transforms end-of-life plastics, including difficult-to-recycle materials, into high-quality products, and RIL is the first company in India to do so. This approach could transform compliance costs into new revenue streams.

Compliance roadmap for foreign companies

Successfully navigating India’s EPR regime requires a strategic, structured approach. Here’s a step-by-step roadmap:

Step 1: Assess applicability

Determine which EPR regulations apply to your products (plastics, electronics, batteries, etc.).

Step 2: Register on CPCB EPR Portal

Registration is mandatory before import or sale. Include company details, product types, and projected volumes.

Step 3: Develop an EPR Plan

Outline how you will collect, recycle, and dispose of post-consumer waste. Partnering with authorized recyclers or PROs (Producer Responsibility Organizations) is common practice.

Step 4: Execute collection and recycling

Set up take-back mechanisms, retail drop-off points, or reverse logistics solutions. Many companies partner with local startups or logistics firms to optimize this step.

Step 5: Documentation and reporting

Submit annual returns with data on waste collected, recycled, and disposed of. Obtain EPR certificates from recyclers to validate compliance.

Step 6: Continuous monitoring and ESG integration

Integrate EPR reporting with your global sustainability reports and ESG disclosures to enhance transparency and attract investors.

Non-compliance with EPR mandates in India: Penalties, enforcement, and legal risks

Non-compliance with EPR mandates can have serious consequences:

• Monetary penalties: CPCB can impose fines up to INR 10 million (~US$120,000) or more, depending on the violation’s scale.
• License revocation: Registration can be suspended or cancelled, blocking market access.
• Product seizure: Non-compliant products may be seized at ports or withdrawn from retail channels.
• Reputational damage: ESG rating agencies and procurement platforms increasingly blacklist non-compliant companies.

Strategic opportunities: Beyond compliance

While compliance is mandatory, forward-looking companies are turning EPR into a competitive advantage:

• ESG-linked capital and procurement

Meeting or exceeding EPR targets strengthens sustainability credentials, improving access to green financing and ESG-linked investment.

• Consumer trust and market differentiation

EPR-backed recycling programs enhance brand image and appeal to India’s environmentally conscious consumers.

• Innovation and new revenue streams

Closed-loop recycling, reverse logistics, and circular supply chain models can reduce raw material costs and open new business verticals.

Key takeaway: Circular economy as a business strategy

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India’s EPR framework will continue to evolve, expanding into textiles, construction materials, and packaging substrates. Over the next five years, EPR is expected to integrate with carbon credit systems, ESG disclosure mandates, and sustainability-linked tax incentives – positioning it as a central pillar of India’s industrial policy.

Companies that invest early in EPR capabilities will not only avoid regulatory risks but also shape the competitive landscape in sectors as diverse as FMCG, EVs, consumer electronics, and packaging.

(With inputs from Archana Rao.)

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