EPR (Extended Producer Responsibility) Registration & Compliance
Extended Producer Responsibility (EPR) places the onus on producers, importers and brand-owners to ensure environmentally sound management of products at their end-of-life. We provide registration support, policy drafting, PRO (Producer Responsibility Organisation) engagement, reporting and auditing services to help you meet regulatory obligations.
Scope & Applicability
EPR applies to categories such as plastic packaging, electronic waste (e-waste), batteries, used oil and more. Applicability depends on product type, turnover and whether the company imports regulated products.
Key EPR Categories
Plastic Packaging
Registration, PRO coordination, recycling targets, and annual reports.
Batteries
Take-back schemes, collection targets and compliance reports.
E-waste
Producer registration, authorised dismantlers, and recycling flows.
Used Oil & Other
Special rules for hazardous streams and extended compliance obligations.
EPR Registration Process
- Determine applicable product category and whether exemption applies.
- Prepare company details, product volumes and import/export data.
- Register on the relevant EPR portal and file necessary declarations.
- Engage a PRO if required for collection, recycling and reporting targets.
- Submit annual reports and comply with audits or spot-checks by regulators.
Documentation & Reporting
- Production/import records and sales data
- Material composition and weight breakdown per SKU
- Evidence of collection and recycling (PRO agreements, invoices)
- Transport & storage records for waste consignments
Targets, Calculations & Examples
EPR targets are usually specified as a percentage of the product placed on market. Example calculation:
Example: If you place 100 tonnes of plastic packaging in a year and the recycling target is 50%, you must ensure 50 tonnes are collected and recycled or accounted for via PRO credits.
PRO (Producer Responsibility Organisation) Engagement
PROs act on behalf of producers to organise collection, transport, recycling and reporting. We help you evaluate and contract with reputable PROs and structure agreements to allocate liabilities clearly.
Penalties & Non-compliance
Non-compliance can lead to financial penalties, public notices and enforcement actions. We assist with notice responses, remediation plans and negotiation with authorities to minimise exposure.
Audit & Verification
Audits may verify quantities placed on market, recycling certificates and PRO invoices. We conduct pre-audit checks, maintain traceable records and represent clients during verifications.
Pricing & Service Packages
| Service | Indicative Fee (INR) |
|---|---|
| EPR Registration & initial filing | ₹9,999 — ₹29,999 |
| Annual compliance & reporting | ₹14,999 — ₹69,999 |
| PRO evaluation & contracting | ₹19,999 — ₹79,999 |
| Audit support & notice response | ₹9,999 — ₹59,999 |
Special Considerations for Imports & Exports
Imported products that fall under EPR must be declared and accounted for; exporters must maintain export documentation to avoid double-counting obligations. We coordinate customs documentation and help with cross-border reporting nuances.
Dispute Resolution & Contract Clauses
We draft clear contract clauses allocating EPR liabilities in supplier and distribution agreements, including arbitration-ready dispute resolution language and indemnities to protect brand owners.
Case Studies & Outcomes
Packaging Brand: Engaged with a PRO and restructured supplier contracts — achieved 60% collection coverage within the first reporting year. Electronics Importer: Completed e-waste registration and linked with authorised dismantlers to certify recycling.
FAQs
Who is a Producer under EPR?
Usually the manufacturer, importer, brand owner or seller who places the product in the market within the jurisdiction. Definitions vary by product category.
Can a PRO fully absolve producers?
No — producers retain statutory responsibility; PROs act as service providers but contracts must clearly manage liabilities and evidence.