EPR for plastic packaging: what brand owners must file before 30 June

If your company puts a product on the Indian market in plastic packaging, you are a Producer, Importer or Brand Owner (PIBO) under the Plastic Waste Management Rules, and the financial year that ended on 31 March has to be reported on the CPCB centralised EPR portal by 30 June. The return is not a formality: it is where your packaging quantities, your targets and the EPR certificates you bought are reconciled, and it is where environmental compensation is calculated if the numbers do not add up.

What the annual return asks for

• Plastic packaging placed on the market during the year, split by category (rigid, flexible, multi-layered, and compostable or biodegradable where applicable) and by state of sale.
• Pre-consumer plastic waste generated at your own facilities and how it was handled.
• The EPR certificates you purchased from registered plastic waste processors against each category target, including the quantities, certificate IDs and the processor's registration.
• Recycled-content and reuse figures where targets for those have begun to apply to your category, as currently notified.
• Supporting documents the portal may request, such as sales summaries, import data and the certificates themselves.

Where filings go wrong

Most of the problems we see are not about the rules but about data. The quantity declared at registration or in the previous return is often an estimate; the annual return has to be built from actual ERP, GST and import records, and a large gap between the two invites questions. The second common issue is certificates bought from processors whose own returns are incomplete or whose registration has lapsed, which can leave the certificate unavailable for offset. The third is treating the return as a once-a-year job: if the portal shows a shortfall against target, there is very little time to procure genuine certificates before the deadline.

Treat 30 June as the end of a process that starts in April with a packaging reconciliation, not as the day you log in to the portal.

A simple sequence that works

• April: pull packaging data by SKU and state from your ERP, convert to tonnes by category and compare it with what was declared at registration.
• May: calculate the target for each category, check the certificates already in your account, and close the gap with registered processors well before prices rise in June.
• Early June: upload the return, keep the acknowledgement and the certificate ledger together, and update your registration if the quantities have changed materially.

We prepare and file plastic EPR annual returns for brand owners and importers, and we run the certificate procurement so you are buying from processors whose paperwork will hold up. If you are not sure whether your packaging categories or targets are correct, that is the conversation to have now rather than in the last week of June.