New Delhi – The Central Pollution Control Board has moved from persuasion to penalty on plastic packaging, and the companies most exposed are the ones that registered on the portal and then stopped.
Extended Producer Responsibility sits inside the Plastic Waste Management Rules, 2016, amended repeatedly since, most recently in 2026. It makes producers, importers and brand owners legally answerable for the packaging they put into the market, measured against annual recycling and reuse targets that tighten each year.
Registration is the floor, not the obligation
Every producer, importer and brand owner must register on the CPCB portal before selling plastic packaging in India. Registration is straightforward and widely completed. It is also the part that carries the least risk.
The substantive duty is to collect, recycle or properly dispose of a volume of plastic waste matching what the entity introduced into the market, and to evidence that against rising annual targets. Meeting the target, and being able to prove it with certificates that survive scrutiny, is where compliance actually fails.
Labelling moved the burden onto the pack
The Ministry of Environment, Forest and Climate Change amended the rules to require packaging information to be carried on the pack itself, through a barcode, a QR code or a unique identifying number. Those marking and labelling obligations under Rule 11 have applied since July 2025.
This changes the nature of the exposure. A reporting failure lives in a file. A labelling failure is on every unit in every store, visible to any inspector and any competitor.
What non-compliance costs
Penalties fall under Section 15 of the Environment (Protection) Act, 1986 and run from ten thousand rupees to fifteen lakh, with a further ten thousand rupees for each day a violation continues.
The daily accrual is the provision worth modelling. A modest headline penalty compounds quickly where a company disputes a finding and the underlying breach stays unremedied through the dispute.
The BRSR overlap
Listed companies report waste generated, recycled and safely disposed under the circularity attribute of BRSR Core, and those figures now carry external assessment or assurance.
A company filing healthy circularity numbers to SEBI while falling short of its EPR targets with CPCB has produced two official accounts that do not reconcile. Assurance providers are increasingly asked to look at both.
Source: Plastic Waste Management Rules, 2016 and subsequent amendments, Central Pollution Control Board EPR framework, and Section 15 of the Environment (Protection) Act, 1986.
