For producers, importers, brand owners & plastic waste processors (PIBOS & PWPS)
The Central Pollution Control Board has confirmed that the Annual Return module for Plastic Waste under the Centralised EPR Portal is not operational for FY 2025–26, and that no Environmental Compensation will apply until it is restored. The obligation to file, however, remains in force.
AT A GLANCE Who this affects: Producers, Importers and Brand Owners (PIBOs), and Plastic Waste Processors (PWPs) registered under the Plastic Waste Management Rules, 2016, in respect of their FY 2025–26 Annual Return. What has changed: The Annual Return module for Plastic Waste, previously unavailable during CPCB’s transition to the Common EPR Portal, is now operational. CPCB and the Ministry of Environment, Forest and Climate Change (MoEFCC) have notified a revised filing timeline for FY 2025–26. Revised Deadlines : Plastic Waste Processors (PWPs): 31 October 2026. Producers, Importers & Brand Owners (PIBOs): 31 December 2026. Filling Portal: Common EPR Portal (epr.cpcb.gov.in/home) , which has replaced the earlier stand-alone Plastic Waste EPR Portal (eprplastic.cpcb.gov.in), discontinued on 28 June 2026. What has not changed: The underlying obligation to file for FY 2025–26: category-wise packaging quantities, recycled-content data, and reconciliation of EPR certificates – remains exactly as it was. Immediate Action: Log in on the Common EPR Portal with your migrated Common EPR ID (CEPR ID), verify your migrated data, reconcile your FY 2025–26 figures, and file before the applicable deadline above. |
- INTRODUCTION
Extended Producer Responsibility (EPR) for plastic packaging places a continuing, statutory obligation on Producers, Importers and Brand Owners (PIBOs), and on registered Plastic Waste Processors (PWPs), to report every financial year, how much plastic packaging they placed on the Indian market or processed, and how that packaging was collected, recycled, or otherwise managed. The Annual Return (AR) filed on CPCB’s centralised portal is the primary instrument through which this reporting happens, and it is the record against which CPCB assesses whether an entity has met its EPR targets.
- What is the update about?
This update explains what changed, sets out the revised deadlines now in effect, and translates the wider set of FY 2025–26 regulatory developments i.e. the portal migration, category-specific certificate rules, recycled-content mandates, and the Environmental Compensation framework into a practical action plan for PIBOs and PWPs.
- Why CPCB Suspended Annual Return Filing for Plastic Waste EPR ?
The disruption to Annual Return filing for FY 2025–26 was a consequence of a broader, structural change to how CPCB administers EPR across waste streams, rather than any change to the underlying law. CPCB has been consolidating the separate portals it previously ran for plastic packaging, e-waste, battery waste, waste tyres and used oil into a single Common EPR Single Sign-On (SSO) system, under which every registered entity is issued one Common EPR ID (CEPR ID) that provides access to every applicable waste stream through a single login.
- What were the results of this Consolidation?
As part of this consolidation, the stand-alone Plastic Waste EPR Portal at eprplastic.cpcb.gov.in was discontinued on 28 June 2026, with registered users’ company details, EPR targets, historical returns and certificate records migrated to the new Common EPR Portal. Because this cut-over fell close to the start of the FY 2025–26 filing cycle, the Annual Return module for plastic packaging was temporarily unavailable on the new system while the migration was completed and tested. CPCB accordingly confirmed that no Environmental Compensation would be imposed for FY 2025–26 until the module was restored and a revised filing timeline was separately notified -while making clear that the underlying obligation to file continued to apply. That was the position captured in our earlier note.
- The Update: Filling Window now Opens and Revised Deadlines Notifies by CPCB
The Annual Return module for Plastic Waste is now live on the Common EPR Portal. Registered PIBOs and PWPs can access it using their migrated Common EPR ID at the Common EPR Portal (epr.cpcb.gov.in/home), which has replaced the earlier eprplastic.cpcb.gov.in address for plastic packaging filings.
Alongside the restoration of the module, MoEFCC has issued a revised Annual Return filing timeline for FY 2025–26, extending the deadline as a special case to give PIBOs and PWPs adequate time to file following the portal transition. As tracked by Kar Parivartan’s EPR advisory desk, the revised timeline is:
- Plastic Waste Processors (PWPs): last date for filing the FY 2025–26 Annual Return is 31 October 2026.
- Producers, Importers & Brand Owners (PIBOs): last date for filing the FY 2025–26 Annual Return is 31 December 2026.
- Why Compliance Teams Must Double-Check Official Notices?
- This mirrors the language CPCB and MoEFCC’s Hazardous Substances Management (HSM) Division have used for previous plastic AR extensions – an extension “issued as a special case to facilitate filing of annual returns and address difficulties faced by entities, while ensuring environmentally sound management of plastic packaging waste under the EPR framework.”
- Because CPCB has revised plastic AR deadlines several times over the past two financial year, entities should treat 31 October 2026 (PWP) and 31 December 2026 (PIBO) as the current confirmed dates, and independently cross-check the exact Office Memorandum reference and issue date against the notice published on the Common EPR Portal or cpcb.nic.in before relying on it for statutory purposes – a five-minute check that is good practice for any compliance-critical deadline, extended or not.
- Why Should This Be Read as a Deferral, Not a Waiver?
- The core message of our earlier advisory still holds, and matters more now that a concrete deadline is on the table: the temporary unavailability of the AR module was always a deferral of the filing timeline, never a waiver of the reporting obligation itself. Every quantity of plastic packaging placed on the market in FY 2025–26, every EPR certificate procured, and every recycled-content declaration due for that year must still be reported -the only thing that moved was the date by which that reporting must happen.
- With a firm deadline now notified, the practical risk profile has changed. During the module outage, no EC could be levied because no return could be filed and no revised date existed against which a default could be measured. That protection ends once a notified deadline is in force.
- From the perspective of Environmental Compensation exposure, 31 October 2026 (PWP) and 31 December 2026 (PIBO) should now be treated the same way the original 30 June deadline would have been treated: as the operative date after which non-filing or a shortfall in the underlying targets can trigger compensation and other consequences.
- Regulatory Pattern Behind these Extensions.
- Extensions to plastic EPR Annual Return deadlines are not new. CPCB and MoEFCC’s Hazardous Substances Management Division have granted a series of extensions for the FY 2024–25 Annual Return alone, each issued as a “special case” under the removal-of-difficulties mechanism available in the Plastic Waste Management Rules framework.
- The pattern is instructive: it shows that CPCB treats these deadlines as capable of further revision when stakeholders or the portal encounter difficulties, and that entities should not assume a notified date is necessarily the last word.
| S.No. | Milestone | Date |
| 1) | Old Plastic Waste EPR Portal (eprplastic.cpcb.gov.in) discontinued | 28 June 2026 |
| 2) | Migration to Common EPR Portal (epr.cpcb.gov.in) and CEPR ID rollout | From late June 2026 |
| 3) | PWM (Amendment) Rules, 2026 (G.S.R. 237(E)) in force | 31 March 2026 |
| 4) | Category-specific certificate matching enforced | From January 2026 |
| 5) | FY 2025–26 Annual Return module restored on Common EPR Portal | 2026 (current) |
| 6) | FY 2025–26 Annual Return -PWP deadline (extended) | 31 October 2026 |
- Consequences of the missing Deadlines
Once the notified deadline lapses without a compliant filing, the consequences CPCB has applied in prior years become available again, and entities should plan on the basis that they will be applied:
- Environmental Compensation for any shortfall against category-wise recycling, EOL disposal or recycled-content targets, assessed on an escalating basis for repeated shortfalls, with the underlying obligation carried forward rather than extinguished.
- Show-cause notices -CPCB has previously issued these to non-filing PIBOs and PWPs, and in past cycles has auto-filed returns for persistent non-filers and increased their EPR target for the following year by a fixed percentage as a consequence.
- Suspension of EPR registration for persistent non-compliance, which in practice halts an entity’s ability to lawfully place plastic-packaged products on the Indian market.
- Customs holds on future consignments for importers who cannot evidence valid, current EPR registration at the point of clearance, under the CBIC verification mandate.
- In cases of wilful non-compliance, potential prosecution under Section 15 of the Environment (Protection) Act, 1986, which carries a maximum term of five years’ imprisonment or a fine of up to ₹1 lakh per day of continuing violation.
- How Kar Parivartan LLP Can Support Your Compliance
Kar Parivartan LLP is monitoring the notifications of MOEFCC and CPCB regarding the AR module and the revised filing timeline on an ongoing basis. In the interim, we assist PIBOs and PWPs with the reconciliation of plastic packaging data, verification of EPR certificates against registered processors, and preparation of audit-ready records – so that filing, once the module is restored, can proceed without avoidable delay.
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