EPR Registration for Producers and Brand Owners
Extended Producer Responsibility (EPR) places environmental accountability on producers, importers and brand owners for the full lifecycle of their products — including collection, recycling and final disposal of post-consumer waste. EPR registration on the CPCB portal is mandatory for covered product categories (plastic, e-waste, batteries, tyres, etc.) and helps meet recovery targets, regulatory reporting and compliance obligations.
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What is EPR?
Extended Producer Responsibility (EPR) makes producers and brand owners responsible for managing the end-of-life stage of their products — collection, recycling and safe disposal — to reduce environmental harm and promote circularity.
Who can register on the CPCB portal?
Producers (P), Importers (I), Brand Owners (BO), and Plastic Waste Processors involved in recycling, waste-to-energy, waste-to-oil, or industrial composting can register on the CPCB centralised portal.
Producer vs Brand Owner
Producer: manufacturer or entity that places products on the market and is responsible for take-back/recycling. Brand Owner (BO): an entity that sells products under its own registered brand/trademark (including marketplaces and retailers) and is responsible for ensuring proper end-of-life management under EPR rules.
Environmental Protection
EPR promotes reduced hazardous content, improved collection and safer recycling practices that minimise pollution and health risks.
Cost Optimisation & Resource Conservation
Shared recycling infrastructure and recovered secondary materials lower production costs and reduce dependence on virgin resources.
Legal Compliance & Brand Value
Registration reduces regulatory risk, avoids penalties and demonstrates corporate responsibility, improving market and consumer trust.
1. Documents Required for EPR Registration
Company PAN, GST, CIN and IEC; PAN/Aadhaar of the authorised person; DIC registration (if applicable); manufacturing flow diagram (producers only); SPCB/PCC consents for production facilities; scanned signatures of authorised signatories; covering letter; supporting documents specific to the product category (EPR plan, waste estimates, etc.).
Application Processing & Practical Steps
1. Prepare documents: corporate IDs (PAN/GST/CIN/IEC), authorised signatory IDs, DIC (if applicable), process flow (producers), SPCB consents (production units), scanned signatures and a covering letter.
2. Choose the correct category and form on the CPCB centralised EPR portal (plastic/e-waste/battery/tyre-specific forms where applicable).
3. Submit application and supporting documents through the CPCB portal. DoStartup or similar consultants can assist with form-filling and documentation to avoid delays.
4. CPCB review & clarifications: CPCB examines applications and requests clarifications within 7 working days; relevant officers respond within 2 working days when clarifications are sought.
5. Response & timelines: Applicants must respond to clarifications within 30 days or the application may be deemed withdrawn. If CPCB delays processing beyond one month, rules provide for automatic registration in certain circumstances (confirm current portal/notification specifics at time of filing).
6. Post-registration obligations: Maintain records, file quarterly/annual returns on the CPCB portal, meet recovery targets and implement collection & recycling arrangements (tie-ups with authorised recyclers or collective systems).
Processing Timelines & Validity
Portal timelines are prescribed to ensure prompt processing; validity and renewals are specified per stream and regulatory updates.
CPCB initial scrutiny
7 working days (to request clarifications)
CPCB examines the application and may ask for clarifications or missing information within 7 working days.
CPCB officer response window
2 working days (internal response SLA)
Relevant CPCB officers respond to clarifications or escalate within 2 working days as per the stated internal process.
Applicant reply & withdrawal condition
30 days (applicant response window)
If the applicant fails to respond to CPCB queries within 30 days, the application may be deemed withdrawn.
Automatic grant condition
If CPCB delay > 1 month
If CPCB delays processing beyond one month, the application may be considered approved automatically — confirm this against current portal rules and notifications before relying on it.
Total Estimated Time
EPR registration validity is typically five years from issuance. Processing time from submission to registration varies depending on completeness of documentation and CPCB/SPCB review cycles — often a few weeks to a few months in practice.
Listicles
EPR by Waste Stream — Key Notes
- Plastic Waste: PIBOs must prepare Plastic Waste Management plans and coordinate with local bodies; register via Form I and submit Plastic Waste Action Plan on the CPCB/SPCB portal.
- E-Waste: EPR covers all Electrical & Electronic Equipment (EEE) — producers must promote formal collection and recycling under E-Waste Rules.
- Battery Waste: Batteries (primary/secondary/new/refurbished) are covered; register via CPCB portal using Form 1(A) and obtain Form 1(B) certification under Battery Waste Rules (2022).
- Tyres: Covered under Hazardous & Other Wastes Amendment Rules, 2022 (Schedule IX) — manufacturers, importers and OEMs must obtain EPR certificates and comply with portal returns.
Common Registration Challenges
- Stakeholder awareness gaps and fragmented collection channels
- Tracking and meeting recovery targets across geographies and product categories
- Financial constraints for MSMEs to invest in recycling infrastructure
- Inter-agency coordination and data reporting complexities
How DoStartup Supports EPR Registration
Advising the correct authorisation category and form for your product stream.
Fast-tracking registration through complete application packs and proactive liaison with CPCB/SPCB.
Monthly compliance maintenance post-registration and support to meet EPR targets across plastic, e-waste, battery and tyre streams.
End-to-end application and documentation support
EPR target strategy and tie-ups with authorised recyclers/collectors
Ongoing reporting and compliance assistance to avoid penalties
DoStartup provides tailored support for producers and brand owners to meet regulatory obligations and achieve circularity goals.
Who Must Register & Who is Covered
Producers, importers and brand owners who manufacture, import or sell covered products (plastic packaging, EEE, batteries, tyres, etc.) are required to register and meet EPR obligations. Plastic waste processors and authorised recyclers may also register for specific roles in the EPR ecosystem.
Brand owners include marketplaces and retailers that place products under their brand; they share legal responsibility for end-of-life management under EPR rules.
Producers / Importers — primary responsibility for EPR planning and target compliance
Brand Owners / Marketplaces — responsible for branded product lifecycle management
Recyclers / Dismantlers — authorised partners for collection and processing
Municipalities / Aggregators — collection partners and local coordination
Register on the CPCB portal in the applicable category and ensure ongoing reporting and operational arrangements to meet recovery targets.