Plastic EPR for brand owners can apply when a business sells a commodity under its own brand in plastic packaging, including D2C and e-commerce brands that use contract manufacturers. Requirements can include CPCB portal registration, category-wise EPR targets, recycled-content and reuse obligations, packaging information and annual returns. A narrow micro and small enterprise exemption is described in the rules, but eligibility and any producer or importer role should be checked before relying on it. Start with our Plastic Waste EPR Registration guide.
Who is a brand owner under plastic EPR?
A brand owner is a business that sells a commodity under its own brand name. If your products reach customers in plastic packaging, you are in scope even when someone else manufactures and packs them. Typical cases:
| Business | Why it can be a brand owner |
|---|---|
| FMCG, food and cosmetics brands | Products sold under the company's brand in plastic packs |
| D2C and e-commerce brands | Brand name on packaging, often made by contract manufacturers |
| Retailers with private labels | Own-brand goods packed in plastic |
| Pharma, agro and industrial brands | Branded products in plastic containers |
Micro and small enterprise exemption
Schedule II of the Plastic Waste Management Rules, 2016 includes an exemption for qualifying micro and small enterprise brand owners. The Maharashtra Pollution Control Board has also described the exemption in its published guidance. Check the current rule text and seek confirmation from CPCB or your State Pollution Control Board before relying on it, especially where your business has more than one regulated role.
- The carve-out is described for brand owners, not producers or importers.
- It depends on your current MSME classification; the MSME limits were revised from 1 April 2025, so check the present thresholds.
- Keep current MSME/Udyam evidence and documents showing the capacity in which the business operates.
- Do not assume the exemption automatically applies to every e-commerce seller or to a separate producer or importer activity.
Because the position has nuances, confirm your status with CPCB or your State Pollution Control Board before relying on the exemption.
When you hold more than one role
Many brands are also importers or producers for part of their packaging. A business that imports finished packaged goods may have importer obligations for that activity; the brand-owner exemption should not be assumed to cover another role. See our plastic EPR for importers guide and confirm the applicable registration and reporting treatment with CPCB.
Brand owner obligations
- Registration on the Common EPR Portal where required; follow the registration process and the document checklist.
- Category-wise targets, met by buying EPR certificates from registered Plastic Waste Processors.
- Recycled content in Categories I–III from FY 2025-26, subject to applicable provisions; see recycled content requirements.
- Reuse targets for brand owners using Category I rigid packaging, phased from FY 2025-26.
- Barcode, QR code or unique number on packaging from 1 July 2025.
- Annual return with category-wise data; see annual return filing.
- Dealing with registered parties. Use registered Plastic Waste Processors and keep certificate and invoice records.
Budget for certificates and compliance work, not just the government fee; see plastic EPR registration fees.
Common mistakes brand owners make
- Assuming a contract manufacturer's registration covers your brand
- Relying on the small-enterprise exemption without checking your current classification and other roles
- Counting only retail packaging and ignoring secondary or transit packaging; confirm scope with CPCB guidance
- Misclassifying packaging categories
- Missing label and QR code changes
Key takeaways
- Selling under your own brand in plastic packaging makes you a brand owner, even if others manufacture it.
- The micro and small carve-out is narrow and depends on your roles and current classification.
- Targets, recycled content, reuse, labelling and returns apply once you are in scope.
Not sure if your brand needs plastic EPR registration?
Ask our team to review your roles, packaging and applicable exemptions.
Request a brand owner reviewFrequently asked questions
Does a D2C brand need plastic EPR registration?
If its name is on plastic packaging, it is generally a brand owner, subject to the micro and small enterprise provisions. Confirm your classification and any importer or producer roles.
Does my contract manufacturer's EPR registration cover me?
No. The brand owner has its own obligations; confirm what your manufacturer handles under your agreement.
Are micro and small brand owners exempt?
Published guidance reports an exemption for qualifying micro and small enterprise brand owners. It may not cover producer or importer roles. Verify current eligibility with CPCB or your State Pollution Control Board.
Do brand owners need recycled content in packaging?
Recycled-content obligations apply to Categories I–III from FY 2025-26, subject to applicable provisions and exemptions. Check the current rules and category-specific targets.
Sources
- CPCB Common EPR Portal
- Plastic Waste Management (Amendment) Rules, 2026, G.S.R. 237(E) (official Gazette text hosted by MPCB)
- MPCB FAQs (published guidance on EPR exemptions)
- e-Gazette of India
Regulatory review: reviewed 30 October 2026. Verify current exemption conditions, portal instructions and notices with CPCB or your State Pollution Control Board before relying on them. Informational only, not legal advice.