Extended Producer Responsibility (EPR) is a mandatory environmental compliance framework introduced by the Government of India to manage waste generated from products and packaging. For FMCG (Fast-Moving Consumer Goods) companies, EPR compliance is especially important because these businesses generate large volumes of packaging waste, including plastic, paper, glass, and multilayer materials.
Under India’s environmental laws, FMCG companies are responsible not only for manufacturing and selling products but also for ensuring environmentally sound management of post-consumer waste.
1. Mandatory EPR Registration
All FMCG companies that manufacture, import, or brand packaged products must register under the EPR framework.
This includes:
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Brand owners
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Manufacturers
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Importers
Registration is done on the Central Pollution Control Board (CPCB) portal or relevant State Pollution Control Board (SPCB) platforms. Without registration, FMCG companies are not legally allowed to place packaged products in the Indian market.
2. Identification of Packaging Material
FMCG companies must clearly identify the type and quantity of packaging material they introduce into the market.
Packaging categories include:
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Plastic packaging
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Paper and cardboard
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Glass packaging
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Metal packaging
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Multilayer packaging
Accurate identification is essential because EPR targets and obligations differ based on the material type.
3. Fulfilment of Waste Collection and Recycling Targets
One of the core EPR requirements is meeting annual waste collection and recycling targets.
FMCG companies must:
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Collect a specified percentage of packaging waste
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Ensure recycling, reuse, or environmentally safe disposal
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Meet targets set by CPCB for each financial year
These targets gradually increase to promote a circular economy and reduce landfill dependency.
4. Engagement with Authorized Recyclers or PROs
FMCG companies are required to work with:
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Authorized recyclers, or
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Producer Responsibility Organizations (PROs)
These entities handle collection, recycling, and processing of waste on behalf of the company. Only CPCB-authorized recyclers and PROs are allowed under EPR regulations.
5. Maintenance of Records and Documentation
Proper documentation is a critical EPR compliance requirement.
Companies must maintain:
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Quantity of packaging introduced
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Waste collected and recycled
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Agreements with recyclers or PROs
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Recycling certificates and transaction records
These records must be preserved for audits and regulatory inspections.
6. Regular EPR Returns and Reporting
FMCG companies must file periodic EPR returns on the CPCB/SPCB portal.
These returns include:
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Packaging data
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Waste management details
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Recycling proof
Timely and accurate reporting ensures transparency and prevents compliance violations.
7. Use of Recyclable and Sustainable Packaging
EPR regulations encourage FMCG companies to:
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Reduce plastic usage
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Shift to recyclable or biodegradable materials
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Minimize multilayer packaging
Eco-friendly packaging supports long-term compliance and helps companies meet recycling targets more easily.
8. Compliance with Plastic Waste Management Rules
FMCG companies using plastic packaging must follow the Plastic Waste Management Rules, including:
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Restrictions on certain single-use plastics
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Marking and labeling requirements
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Waste take-back obligations
Non-compliance can result in severe penalties.
9. Payment of Environmental Compensation (If Applicable)
Failure to meet EPR targets may lead to:
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Environmental compensation charges
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Additional compliance conditions
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Regulatory scrutiny
Meeting obligations on time helps avoid financial losses.
10. Continuous Monitoring and Renewal
EPR compliance is an ongoing responsibility, not a one-time activity.
FMCG companies must:
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Monitor targets regularly
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Update registrations when business details change
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Renew approvals as required
Conclusion
EPR compliance for FMCG companies in India is essential to manage packaging waste responsibly and protect the environment. By registering under EPR, meeting recycling targets, working with authorized recyclers, maintaining records, and submitting timely reports, FMCG businesses can ensure legal compliance, avoid penalties, and contribute to sustainable growth. In 2026 and beyond, EPR will continue to be a key regulatory requirement for FMCG companies operating in India.