Plastic EPR for importers applies to anyone who imports plastic packaging, goods in plastic packaging, carry bags or plastic sheets for commercial use, and, since the 2024 amendment, plastic raw material such as resin, pellets, films or preforms used to make packaging. Importers must register on CPCB's EPR portal, and CBIC instructions direct customs officers to verify that registration at clearance. Importers also face EPR targets, annual returns and special recycled-content rules. Part of our Plastic Waste EPR Registration guide.
Who counts as an importer under plastic EPR?
The Plastic Waste Management (Amendment) Rules, 2024, notified on 14 March 2024, broadened the importer definition. It now covers a person importing for commercial use any of the following:
| What you import | Examples |
|---|---|
| Plastic packaging | Bottles, pouches, containers, films sold as packaging |
| Goods with plastic packaging | Packaged consumer products brought into India |
| Carry bags and plastic sheets | Bags, sheets and similar material |
| Plastic raw material and intermediates for packaging | Resin, pellets, films, preforms |
CBIC customs verification of plastic EPR registration
CBIC Instruction No. 21/2025-Customs (2 July 2025) addressed verification of EPR registration for importers of plastic raw material. A later Instruction No. 15/2026-Customs (9 September 2026), as reproduced by TaxGuru, asks customs formations to verify importer registration certificates for plastic packaging, goods with plastic packaging, plastic raw material and intermediates. It also says certificates showing a one-year validity are to be treated as one-time registrations that do not require renewal for import clearance. Confirm your certificate status with CPCB and your customs broker before shipping.
Check the latest official direction. The 2026 instruction text cited here is reproduced by a secondary source; verify it and any later updates with CBIC, CPCB and your customs broker before relying on it for clearance.
How to register for plastic EPR as an importer
- Apply as an Importer on CPCB's Common EPR Portal; see our Common EPR Portal guide.
- Follow the steps in the plastic EPR registration process.
- Prepare an Import-Export Code (IEC), invoices or bills of entry for imported quantities and category-wise data; see the document checklist.
- Register before the shipment arrives, since customs may ask for proof at clearance.
Plastic EPR compliance requirements for importers
- Category-wise data on all imported plastic, classified into Categories I–IV.
- Annual EPR targets, met by purchasing EPR certificates from registered Plastic Waste Processors.
- Barcode, QR code or unique number information on packaging, required from 1 July 2025.
- Annual return on the portal; see our annual return filing guide.
Recycled-content rule for importers
Under the 2026 amendment, recycled content already present in imported plastic packaging does not count toward an importer's obligation. Importers meet it by purchasing certificates from surplus PIBOs through a CPCB mechanism. Read the targets in our recycled content requirements guide.
Pre-import checklist
- Confirm whether your product falls within the importer definition
- Obtain EPR registration before shipment
- Classify imported packaging by category and quantity
- Check labelling and QR or barcode requirements
- Plan certificate procurement for annual targets
- Confirm current customs documentation with your broker
Key takeaways
- The importer definition now includes plastic raw material and intermediates.
- Customs may ask for EPR registration proof at clearance.
- Imported recycled content does not count; certificates are the route.
Importing plastic packaging or raw material?
Ask our team to check your EPR registration needs before your next shipment.
Request an importer reviewFrequently asked questions
Do importers of plastic raw material need EPR registration?
Yes. The 2024 amendment extended the importer definition to resin, pellets and intermediate material used to make packaging.
Will customs check plastic EPR registration?
CBIC Instruction No. 15/2026-Customs (9 September 2026), as reproduced by a secondary source, asks customs formations to verify registration certificates for importers of plastic packaging, goods with plastic packaging, raw material and intermediates. Confirm current instructions with CBIC and your customs broker.
Can imported recycled content count toward my target?
No. Importers must purchase certificates from surplus PIBOs.
Is an IEC required?
An Import-Export Code is typically requested in the registration documents for importers.
Sources
- CPCB Common EPR Portal
- CBIC official website (check current customs instructions)
- Secondary reproduction of CBIC Instruction No. 15/2026-Customs
- e-Gazette of India
- MoEFCC
Regulatory review: reviewed 30 October 2026. Customs instructions and portal rules change; verify current requirements before shipping. Informational only, not legal advice.