Plastic Waste Management Rules 2024 Amendment: What Changed and Who Needs to Worry

Updated: June 26, 2026 · 14 min read

When the Ministry of Environment, Forest and Climate Change (MoEFCC) notified the latest amendments to the Plastic Waste Management Rules, 2016 in 2024, most FMCG compliance teams filed it as a routine gazette update. It was not. The amendment raised EPR collection targets to 70% for FY 2025-26, reclassified several packaging sub-categories, and — most consequentially — extended the definition of “importer” to rope in thousands of entities that had quietly operated outside the EPR framework. With CPCB tightening scrutiny of registrations on the EPR Plastic portal and a growing queue of registration rejections citing category errors, the window for casual compliance has closed.

What the 2024 Amendment to the Plastic Waste Management Rules Actually Changed

The foundational framework remains the Plastic Waste Management Rules, 2016 (as amended), notified originally under the Environment (Protection) Act, 1986. The 2024 amendment — published in the Official Gazette as a further modification to those Rules — made targeted but high-impact changes across five areas: EPR target uplift, category definitions, the importer definition, Annual Return timelines, and the cost basis for EPR certificates traded on the CPCB plastic waste management portal.

The most operationally significant change is the EPR target uplift. The 2016 Rules had set a phased trajectory; the 2024 amendment crystallised the FY 2025-26 targets as binding obligations, not aspirational benchmarks. A producer, importer, or brand owner (PIBO) that falls short of its annual EPR target is now required to purchase EPR certificates from registered recyclers to make up the gap — and the certificate market has tightened considerably as demand has outpaced registered recycler capacity in states like Gujarat, Maharashtra, and Tamil Nadu.

The amendment also clarified the treatment of compostable plastics, which had occupied an ambiguous middle ground since the 2022 single-use plastic notification. Compostable packaging must now meet IS 17088:2008 (the Bureau of Indian Standards standard for compostable plastics) and must be registered separately under the EPR portal — a point that several food-sector brands in Pune and Chennai had missed entirely.

The Expanded Importer Definition: Why E-Commerce Brands Are Now in CPCB’s Crosshairs

Under the pre-2024 text of the Rules, “importer” was interpreted narrowly — applying principally to entities that cleared customs and held the Bill of Entry. The 2024 amendment broadened this to include any entity that causes plastic packaging to be imported, even where it does not itself execute the import. In practical terms, this sweeps in e-commerce marketplace operators and D2C brands that source finished goods from overseas suppliers and have those goods delivered into Indian fulfilment centres, even when the logistics partner formally holds the import documentation.

This is not a trivial reclassification. India’s e-commerce sector imported an estimated ₹1.4 lakh crore worth of consumer goods in FY 2023-24, a significant fraction of which arrived in plastic packaging. Under the earlier framework, only the customs-clearing agent or the logistics company had any EPR obligation. Under the 2024 amendment, the brand owner whose product name appears on the packaging is the responsible party — regardless of its position in the import chain.

CPCB’s enforcement desk has already begun issuing show-cause notices to e-commerce brands that had not registered on the EPR Plastic portal, particularly those operating out of Delhi-NCR and Karnataka. The notices cite Rule 9 of the Plastic Waste Management Rules, 2016, which requires PIBOs to register before placing plastic packaging into the market. Brands with an unregistered import history stretching back to FY 2022-23 face retrospective EPR certificate obligations that could run into several crore rupees.

EPR Targets by Category: The FY 2025-26 Numbers You Cannot Ignore

The plastic waste management rules amendment 2024 set binding EPR collection and recycling targets across four plastic packaging categories. These are not industry averages — they are minimum obligations for each individual PIBO, calculated on the weight of plastic packaging they place on the market in a financial year.

Plastic Category	Description	EPR Target FY 2024-25	EPR Target FY 2025-26	Indicative Certificate Cost (₹/tonne)
Category I	Rigid plastic packaging (PET, HDPE, PP bottles, jars, containers)	60%	70%	₹4,500–₹6,000
Category II	Flexible plastic packaging (pouches, films, wraps, sachets)	60%	70%	₹6,000–₹8,500
Category III	Multi-layered plastic (MLP) packaging — non-recyclable	50%	60%	₹10,000–₹14,000
Category IV	Plastic used in single-use items (cutlery, straws, plates)	Phased-out / restricted	Phased-out / restricted	N/A (production ban applies)

Category III — non-recyclable multilayer plastic — carries the highest certificate costs because there are fewer authorised co-processing and energy-recovery facilities able to accept it. In Maharashtra and Gujarat, the gap between demand for Category III certificates and registered co-processor capacity has pushed spot certificate prices above ₹13,000 per tonne in some months of FY 2025-26. PIBOs that did not lock in recycler agreements early in Q1 of FY 2026 found themselves paying significant premiums in Q3.

It is also worth being precise about what “EPR target” means operationally. The target percentage is applied to the total weight of plastic packaging placed on the market by the PIBO during the same financial year. A brand owner that introduces 1,000 tonnes of Category I rigid plastic packaging in FY 2025-26 must demonstrate — via valid EPR certificates — that 700 tonnes of equivalent plastic waste was collected and recycled. The certificates must originate from registered recyclers on the CPCB portal; certificates from unregistered entities are void and will be rejected at the Annual Return stage.

Packaging Category Reclassifications and the Mis-Registration Problem

The 2024 amendment tightened the definitions of each packaging category, and this is where a significant number of CPCB registration rejections are occurring. The single most common error auditors and CPCB officials are flagging: producers registering Category II flexible packaging (pouches, laminated films, multilayer sachets that are technically recyclable) as Category IV. This misclassification matters enormously — Category IV items are subject to the single-use plastic ban under the separate Plastic Waste Management (Amendment) Rules, 2021 and cannot be placed on the market at all, whereas Category II items carry a 70% EPR recovery obligation but remain lawful products.

The reverse error — registering Category III non-recyclable MLP as Category I rigid plastic — is also appearing in CPCB rejection logs, though less frequently. This error allows a producer to claim the lower, cheaper certificate regime for rigid plastic when it is actually obligated under the more expensive MLP category. CPCB’s technical verification team, which cross-references PIBO filings against GST HSN codes (specifically HSN 3923 for plastic packaging articles and HSN 3920 for plates, sheets, films, and strip), has been catching these discrepancies with increasing regularity since Q2 FY 2025-26.

Beyond category errors, CPCB has been rejecting registrations on the grounds of incomplete product-line declarations. Under Rule 9(1) of the Plastic Waste Management Rules, 2016, a PIBO must declare the plastic packaging it places on the market by category, type, and projected annual tonnage. Several mid-sized FMCG companies in Delhi-NCR and Tamil Nadu have received rejection notices because they declared only their primary packaging and omitted secondary and tertiary plastic packaging (stretch wrap, pallet film, transit packaging) from their EPR obligation calculation. The 2024 amendment explicitly confirms that secondary and tertiary plastic packaging is within scope.

How Brand Owners Should Re-Baseline Their EPR Obligation Right Now

Re-baselining is not an accounting exercise — it requires a physical audit of your product lines. The starting point is your plastic packaging inventory, mapped against the four categories in the amended Rules. For most FMCG companies with more than 50 SKUs, this means a structured data pull from procurement, manufacturing, and logistics, cross-referenced with supplier declarations on packaging composition.

The key calculation is your Plastic Packaging Placed on Market (PPOM) figure for the current financial year. This is the total weight, by category, of plastic packaging that left your factory or warehouse gate — not the weight sold to end consumers. Unsold stock that remains in your warehouse at year-end does not reduce your PPOM. This is a common misreading. Once you have your PPOM figure, apply the relevant FY 2025-26 target percentage (70% for Categories I and II, 60% for Category III) to arrive at your EPR certificate requirement in tonnes.

Then audit your existing certificate agreements. Cross-check that every recycler providing you certificates is currently active and registered on the CPCB EPR Plastic portal. Recycler registrations can lapse or be suspended — and certificates issued by a recycler whose registration is suspended during the certificate period are treated as invalid. At least two rounds of bulk certificate invalidations have occurred since 2022, affecting PIBOs who were otherwise compliant in good faith. Building in a verification step every quarter is now standard practice among larger producers.

You should also check whether your Annual Return for FY 2024-25 has been filed correctly. The 2024 amendment shifted the deadline for Annual Returns under Rule 13 to 30th June of the following financial year — meaning your FY 2024-25 return is due by 30 June 2025. Late filings attract penalties under the Environment (Protection) Act, 1986, and may trigger a scrutiny flag on your FY 2025-26 registration renewal.

The 7-Step Compliance Checklist for FMCG and Packaging Companies

Compliance under the plastic waste management rules amendment 2024 is not a one-time registration — it is a continuous obligation that runs through your procurement, production, and annual reporting cycles. The checklist below reflects what CPCB auditors and SPCBs (including the Maharashtra Pollution Control Board and Tamil Nadu Pollution Control Board) are actually examining during site inspections and portal verifications.

1. Conduct a full plastic packaging audit by category (I–III). Map every SKU’s primary, secondary, and tertiary plastic packaging to the correct category under the amended Rules. Include e-commerce packaging, transit packaging, and imported finished-goods packaging. Retain the audit report for a minimum of 3 years, as required under Rule 13 record-keeping obligations.
2. Calculate your PPOM figure for FY 2025-26 on a quarterly basis. Do not wait until year-end. Quarterly tracking allows you to course-correct certificate procurement before the 30 June 2026 Annual Return deadline.
3. Verify your CPCB registration is current and correctly categorised. Log into the EPR Plastic portal and confirm that all plastic packaging categories you place on the market are declared. If the 2024 reclassifications affect your product mix, file an amendment to your registration before the next Annual Return.
4. Audit your recycler panel for active portal registration. Every recycler providing you EPR certificates must hold a valid registration on the CPCB portal at the time of certificate generation. A recycler whose registration is suspended cannot issue valid certificates, even retrospectively.
5. Secure Category III (MLP) certificate agreements early in the financial year. Co-processor capacity for non-recyclable multilayer plastic is limited. Brands that wait until Q3 or Q4 face certificate costs above ₹13,000 per tonne and availability risk.
6. If you are an importer (including an e-commerce brand sourcing packaged goods overseas), confirm your EPR registration reflects the expanded importer definition. File an amended declaration if you were not previously registered as an importer under the pre-2024 definition.
7. File your FY 2024-25 Annual Return by 30 June 2025. Include certificate numbers, recycler registration IDs, and tonnage reconciliation by category. Ensure GST-compliant invoices from recyclers are attached — CPCB portal uploads require this documentation as supporting evidence.

Related Articles

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• E-Waste Rules 2022 Penalties: How Much It Actually Costs to Get Caught

Frequently Asked Questions

Who is required to register on the CPCB EPR Plastic portal under the 2024 amendment?

Under Rule 9 of the Plastic Waste Management Rules, 2016 (as amended in 2024), all producers, importers, and brand owners (PIBOs) who place plastic packaging on the Indian market must register. The 2024 amendment expanded “importer” to include e-commerce brands that cause plastic-packaged goods to be imported, even if a third party clears customs on their behalf. There is no minimum threshold — any PIBO placing plastic packaging on the market is obligated, regardless of scale.

What is the EPR target for plastic packaging in FY 2025-26?

The plastic waste management rules amendment 2024 set the EPR target at 70% for Category I (rigid) and Category II (flexible) plastic packaging, and 60% for Category III non-recyclable multilayer plastic, for FY 2025-26. These targets apply to the total weight of plastic packaging placed on the market by each PIBO in that financial year. EPR certificates from CPCB-registered recyclers must cover the equivalent tonnage.

What penalties apply if a PIBO fails to meet its EPR target?

Non-compliance with EPR targets under the Plastic Waste Management Rules, 2016 can attract action under the Environment (Protection) Act, 1986, including prosecution, fines, and directions to cease operations. CPCB may also suspend or cancel a PIBO’s EPR registration, which effectively prohibits the entity from placing plastic packaging on the market. Beyond statutory penalties, SEBI’s BRSR Core disclosure framework — applicable to the top 150 listed companies from FY 2024-25 — requires disclosure of EPR compliance status, meaning non-compliance carries a capital markets reputational risk as well.

What is the deadline for filing the Annual Return for FY 2024-25?

Under Rule 13 of the Plastic Waste Management Rules, 2016 as amended, PIBOs must file their Annual Return by 30 June of the year following the relevant financial year. For FY 2024-25, the deadline is 30 June 2025. The return must include EPR certificate numbers, registered recycler IDs, and tonnage reconciliation by plastic category. Late filing is treated as non-compliance and may result in a scrutiny flag on the following year’s registration renewal.

What are the most common reasons CPCB rejects EPR plastic registrations?

Based on recent CPCB enforcement activity, the most frequent grounds for registration rejection are: (1) misclassification of plastic packaging between Categories I, II, and III; (2) failure to declare secondary and tertiary plastic packaging in the PPOM calculation; (3) submission of certificates from recyclers whose CPCB registration has lapsed or been suspended; and (4) importers failing to register at all following the 2024 expansion of the importer definition. Ensuring your registration accurately reflects your full plastic packaging portfolio — verified against GST HSN codes 3920 and 3923 — is the first step to avoiding rejection.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered B2B recycling and scrap trading company with pan-India operations across Maharashtra, Gujarat, Delhi-NCR, Tamil Nadu, Karnataka, and Telangana. We work with FMCG producers, packaging manufacturers, importers, and brand owners to manage plastic waste obligations under the Plastic Waste Management Rules, 2016 (as amended in 2024) — from initial obligation baselining through to Annual Return-ready documentation.

Our services for plastic EPR compliance include on-site plastic waste audits, category mapping against the amended Rules, procurement of valid EPR certificates from CPCB-registered recyclers, and generation of BRSR-grade tonnage documentation. All transactions are supported by GST-compliant invoicing and a certificate of recycling traceable to a specific registered recycler and batch. For companies managing multiple waste streams, we also provide comprehensive industrial waste management services that integrate plastic, metal, and e-waste under a single compliance framework.

Whether you are re-baselining your EPR obligation following the 2024 amendment, resolving a CPCB registration rejection, or sourcing Category III certificate capacity before year-end, we have the network and the documentation rigour to close your compliance gap. Contact us to speak with a compliance specialist this week.

• Pan-India plastic waste pickup and logistics across 12+ states
• EPR certificates from verified, CPCB-registered recycling partners
• GST-compliant invoicing and tonnage reconciliation by plastic category
• Certificate of recycling and destruction for BRSR and SEBI disclosure
• Annual Return documentation support, including Category I–III segregation reports
• Specialist advice on the 2024 importer definition expansion for e-commerce brands
• Fair-market pricing on recoverable plastics (PET, HDPE, PP), indexed to prevailing market rates

Visit our EPR compliance services page for more detail, or contact us directly to schedule a consultation.

Sources and References

• Central Pollution Control Board — Plastic Waste Management portal (cpcb.nic.in)
• CPCB Extended Producer Responsibility — Plastic EPR Registration portal (eprplastic.cpcb.gov.in)
• Ministry of Environment, Forest and Climate Change — Notifications and Gazette Amendments (moef.gov.in)
• Bureau of Indian Standards — IS 17088:2008 Compostable Plastics Standard (bis.gov.in)
• Goods and Services Tax portal — HSN codes 3920 and 3923 for plastic packaging (gst.gov.in)
• NITI Aayog — Circular Economy and Plastic Waste Policy Framework (niti.gov.in)
• Central Pollution Control Board — Enforcement Notifications and Annual Reports (cpcb.nic.in)
• Press reports — Business Standard and Economic Times ESG Desk, FY 2024-25 coverage of CPCB EPR enforcement actions (referenced generically)