Contents
- Introduction: Annual Return Filing for PIBOs and PWPs
- Overview of FY 2024-25 Compliance Requirements
- Latest Deadline Updates and Extensions
- Understanding PIBOs and PWPs
- Annual Return Filing Requirements FY 2024-25
- Legal Framework - Plastic Waste Management Rules
- EPR Targets for FY 2025-26
- Categories of Entities Impacted
- Pre-Filing Compliance Checklist
- Penalties and Environmental Compensation
- Exemptions and Relief Provisions
- Timeline: Evolution of EPR in India
- You may also like
- Frequently Asked Questions (FAQs)
- Conclusion
Introduction: Annual Return Filing for PIBOs and PWPs
The annual return filing for Producer, Importer, and Brand Owners (PIBOs) and Plastic Waste Processors (PWPs) is a critical compliance requirement under India's Plastic Waste Management Rules, 2016. For the financial year 2024-25, all registered entities must file their annual returns demonstrating compliance with Extended Producer Responsibility (EPR) obligations on the Central Pollution Control Board (CPCB) portal.
Annual return filing is not just a regulatory formality—it is the primary mechanism through which PIBOs and PWPs demonstrate their contribution to environmentally sound plastic waste management and India's circular economy goals.
This comprehensive guide covers everything you need to know about the annual return filing process, including the latest deadline updates, required documentation, step-by-step filing procedures, and compliance strategies to avoid penalties. Whether you are a first-time filer or an experienced compliance professional, this guide will help you navigate the complexities of EPR compliance for FY 2024-25.
Click to reveal a quick tip!
Start your annual return preparation at least 30 days before the deadline. Early preparation allows time to gather EPR certificates, verify data accuracy, resolve technical issues on the portal, and avoid the last-minute rush that can lead to errors or missed deadlines.
Overview of FY 2024-25 Compliance Requirements
The financial year 2024-25 marks a significant phase in India's journey toward comprehensive plastic waste management. PIBOs and PWPs registered on the CPCB portal are required to file annual returns that provide detailed information about plastic packaging introduced into the market, waste collected and processed, and EPR compliance achievement.
Note: The annual return for FY 2024-25 covers the period from April 1, 2024, to March 31, 2025. All data, EPR certificates, and compliance documentation must pertain to activities conducted during this specific period.
Important Regulatory Update: The Ministry of Environment, Forest and Climate Change (MoEFCC) has implemented several amendments to the Plastic Waste Management Rules through 2022-2025, including enhanced labelling requirements, stricter criteria for compostable plastics, and revised EPR targets. Ensure your filing reflects these latest regulatory changes.
Key Compliance Highlights for FY 2024-25
| Compliance Aspect | PIBOs | PWPs | Filing Platform |
|---|---|---|---|
| Annual Return Filing | Mandatory | Mandatory | CPCB EPR Portal |
| EPR Target Achievement | Category-wise targets must be met | Processing capacity utilization | Verified through certificates |
| Documentation Period | April 1, 2024 - March 31, 2025 | April 1, 2024 - March 31, 2025 | 12-month reporting period |
| Registration Requirement | Valid EPR registration on CPCB portal | Valid PWP authorization | 5-year validity, renewal required |
The compliance requirements for FY 2024-25 reflect the government's intensified focus on achieving circular economy targets for plastic packaging. PIBOs must demonstrate that they have collected and ensured recycling of plastic waste equivalent to their packaging introduction, while PWPs must show the quantity and quality of plastic waste they have processed through environmentally approved methods.
Latest Deadline Updates and Extensions
Understanding the official deadline and any extensions granted is crucial for timely compliance. The Ministry of Environment, Forest and Climate Change (MoEFCC) periodically reviews compliance timelines and may grant extensions to facilitate better compliance and address operational challenges faced by registered entities.
Current Filing Deadline
As per the Office Memorandum (F.No.:12/64/2023-HSM Part(1)) dated June 27, 2025, issued by the Ministry of Environment, Forest and Climate Change through the Hazardous Substances Management Division, the deadline for filing annual returns by registered PIBOs and PWPs for the financial year 2024-25 has been extended.
Official Deadline: The final date for filing annual returns for FY 2024-25 is July 31, 2025. This extension was granted as a special case to ease compliance challenges and address practical difficulties faced by stakeholders while ensuring continued adherence to environmentally sound plastic waste management principles.
Authority and Legal Basis
The extension has been issued under the Plastic Waste Management (Second Amendment) Rules, 2023, with approval from the Competent Authority. The decision was made in reference to communication from the Central Pollution Control Board (CPCB) dated May 29, 2025, recognizing the need for additional time to ensure accurate and complete filing of annual returns.
Timeline of Extensions for FY 2024-25
The filing deadline for FY 2024-25 annual returns has undergone the following changes:
- Original Deadline: June 30, 2025 - As per standard EPR guidelines, annual returns for all waste categories (plastic, e-waste, batteries, tyres) are due by June 30 following the end of the financial year
- First Extension: July 31, 2025 - Announced through Office Memorandum dated June 27, 2025, providing an additional month for compliance
- Current Status: July 31, 2025 remains the final deadline with no further extensions announced as of September 2025
The extension was granted considering several factors including the complexity of data compilation across multiple states and categories, challenges in obtaining verified EPR certificates from authorized PWPs, technical difficulties reported by users on the CPCB portal, and the need for comprehensive verification of compliance documentation.
Planning Tip: While the deadline is July 31, 2025, it is advisable to complete your filing by mid-July to account for any last-minute technical issues, verification requirements, or additional documentation requests from the CPCB. Do not wait for potential further extensions—plan for the current official deadline.
Understanding PIBOs and PWPs
The Extended Producer Responsibility framework in India operates through two primary stakeholder categories: PIBOs (those who introduce plastic packaging into the market) and PWPs (those who collect and process plastic waste). Understanding the roles, responsibilities, and obligations of each category is essential for effective compliance.
Who are PIBOs - Producers, Importers, Brand Owners?
PIBO is an acronym that encompasses three distinct but related categories of entities that share responsibility for the plastic packaging they introduce into the Indian market. Under the Plastic Waste Management Rules, 2016 (as amended), these entities bear primary responsibility for ensuring that plastic packaging waste generated from their products is collected and recycled.
Producers (P)
A Producer is defined as any person engaged in the manufacture of plastic products or packaging. This category includes manufacturers who create plastic packaging materials (such as bottles, containers, films, and bags), companies that use plastic packaging for their own manufactured products, and entities that commission third parties to manufacture plastic packaging on their behalf.
Producers are directly responsible for the plastic packaging they manufacture or use, regardless of whether the manufacturing is done in-house or outsourced. Even if a company contracts with a packaging supplier, the producer remains responsible for EPR compliance related to that packaging.
Importers (I)
An Importer is defined as any person who imports plastic products or commodities packaged in plastic into India. This includes businesses that import finished goods in plastic packaging, entities that import plastic packaging materials for domestic use, and companies that import plastic raw materials or commodities.
Importers bear the same level of EPR responsibility as domestic producers for all plastic packaging associated with their imported goods. The Ministry has explicitly directed the Central Board of Indirect Taxes and Customs (CBIC) to ensure that customs authorities verify EPR registration during import clearance procedures.
Brand Owners (BO)
A Brand Owner is defined as any person who owns or is the licensor of a trademark under which the commodity is sold in the market, irrespective of whether the manufacturer of such commodity is a separate entity. This definition is particularly important because it captures companies that may not directly manufacture products but control the brand under which packaged products are sold.
Brand owners are responsible for EPR compliance even if they outsource all manufacturing and packaging to third parties. This provision ensures that large brands cannot escape responsibility by using contract manufacturers. However, micro and small category brand owners are exempted from fulfilling EPR obligations under current provisions.
Who are PWPs - Plastic Waste Processors?
Plastic Waste Processors (PWPs) are the entities that collect, segregate, and process plastic waste in an environmentally sound manner. They are registered and authorized by State Pollution Control Boards (SPCBs) or Pollution Control Committees (PCCs) to handle plastic waste according to prescribed standards and guidelines.
Types of Plastic Waste Processors
PWPs operate through various processing methodologies, each serving a distinct role in the plastic waste management value chain:
- Recyclers: Entities that collect and process plastic waste to manufacture recycled plastic products or raw materials. Recyclers may specialize in specific categories of plastic (PET, HDPE, LDPE, PP, etc.) and must maintain authorized processing facilities with appropriate technology and environmental safeguards.
- Co-processors: Facilities that use plastic waste as alternative fuel or raw material in industrial processes, primarily in cement kilns. Co-processing must comply with specific guidelines to ensure complete combustion and minimal environmental impact.
- Waste-to-Energy Plants: Facilities that recover energy from plastic waste through approved technologies such as pyrolysis, gasification, or plasma arc. These plants must operate within strict emission norms and obtain necessary environmental clearances.
- Composting Units: Specialized facilities that handle compostable plastic packaging, ensuring proper industrial composting under controlled conditions as per IS/ISO 17088:2021 standards.
PWP Responsibilities
PWPs play a critical role in the EPR ecosystem by providing the actual waste management services that enable PIBOs to fulfill their obligations. Their responsibilities include maintaining authorized and compliant processing facilities, accurately recording the quantity and source of plastic waste received, processing waste according to prescribed environmental norms, issuing EPR certificates to PIBOs for waste processed, and filing annual returns detailing their processing activities.
EPR Framework and Obligations
Extended Producer Responsibility is a policy approach that makes producers responsible for the entire lifecycle of their products, particularly for take-back, recycling, and final disposal. In the context of plastic packaging in India, EPR is implemented through a certificate-based system.
The EPR framework shifts the financial and operational burden of post-consumer waste management from municipalities and taxpayers back to the entities that profit from introducing plastic packaging into the market—creating powerful incentives for sustainable product design and waste reduction.
How EPR Works in Practice
The EPR system for plastic packaging operates through the following mechanism. PIBOs calculate their EPR obligation based on the quantity of plastic packaging they introduce into the market, categorized by type (rigid, flexible, multi-layered, compostable) and distributed by state/UT. PIBOs must then arrange for collection and recycling of plastic waste equal to their obligation quantity, either directly or through Producer Responsibility Organizations (PROs).
PWPs collect, segregate, and process plastic waste, then issue EPR certificates to PIBOs for the quantity processed. PIBOs purchase or obtain these EPR certificates to demonstrate compliance with their obligations. Both PIBOs and PWPs file annual returns on the CPCB portal showing their EPR activities and compliance status. The CPCB and SPCBs monitor compliance and can impose environmental compensation for shortfalls.
Annual Return Filing Requirements FY 2024-25
Filing the annual return is the primary mechanism through which registered entities demonstrate their compliance with EPR obligations. The return must be comprehensive, accurate, and supported by proper documentation. Understanding exactly what needs to be filed is essential for successful compliance.
Who Must File Annual Returns?
The following entities are mandated to file annual returns for FY 2024-25:
Mandatory Filers - PIBOs
- All registered producers of plastic products or packaging materials
- All registered importers of packaged commodities or plastic packaging
- All registered brand owners (except micro and small brand owners who are exempted from EPR obligations)
- Medium and large brand owners, regardless of whether they directly manufacture products
- Export-oriented units that sell any portion of products in the domestic market
Mandatory Filers - PWPs
- All authorized recyclers handling plastic waste
- Co-processing facilities using plastic waste
- Waste-to-energy plants processing plastic waste
- Composting units handling compostable plastic packaging
- All entities registered as PWPs who have issued EPR certificates during FY 2024-25
Exemption Clarification: Export-oriented units are generally exempted from EPR obligations for products that are actually exported. However, if any portion of production is sold domestically, EPR compliance is required for that domestic portion. Micro and small brand owners are exempted from EPR obligations, but if they are also producers or importers, they must comply under those categories.
Required Documents and Data
Proper preparation requires gathering comprehensive documentation and data well in advance of the filing deadline. The following information and documents must be compiled:
For PIBOs - Basic Registration Information
- Valid EPR registration number and certificate from CPCB portal
- GST registration number and certificate
- PAN card of the entity
- Authorized signatory details with valid Digital Signature Certificate (DSC)
- Complete contact information including registered office address, email, and phone numbers
- Details of all manufacturing units, branches, or facilities (if applicable)
For PIBOs - Plastic Packaging Data
- Total quantity of plastic packaging material used or introduced during FY 2024-25 (in metric tons)
- Category-wise breakdown:
- Category I: Rigid plastic packaging
- Category II: Flexible single-layer plastic packaging
- Category III: Multi-layered plastic (MLP) packaging
- Category IV: Compostable plastic packaging
- State/UT-wise distribution of plastic packaging introduction
- Product details including commodity names and packaging types
- For importers: Bill of entry, customs documents, import invoices
- Manufacturing records, purchase orders, or sale invoices showing plastic packaging quantities
For PIBOs - EPR Compliance Documentation
- EPR certificates purchased from authorized PWPs, showing:
- Certificate number and date of issuance
- PWP registration number and details
- Quantity of plastic waste (category-wise and state-wise)
- Processing method (recycling, co-processing, etc.)
- Agreements or contracts with PWPs or PROs
- Payment records for EPR certificate purchases
- Details of any direct collection or recycling initiatives undertaken
- Buyback or deposit refund scheme documentation (if applicable)
For PWPs - Waste Collection and Processing Data
- Total quantity of plastic waste received during FY 2024-25 (in metric tons)
- Source-wise details: waste collected from municipalities, authorized collectors, PIBOs, etc.
- Category-wise breakdown of plastic waste received
- Processing method employed and processing capacity utilization
- Quantity of plastic waste actually processed with category-wise breakup
- Details of EPR certificates issued to PIBOs including certificate numbers, quantities, and categories
- End products manufactured from recycled plastic (for recyclers)
- Valid consent/authorization from SPCB/PCC
- Facility details including address, GPS coordinates, and processing technology
Step-by-Step Filing Process on CPCB Portal
The annual return must be filed electronically through the Centralized EPR Portal for Plastic Packaging maintained by CPCB. Follow this detailed step-by-step process to complete your filing successfully:
- Step 1: Portal Access and Login - Visit the official CPCB EPR Portal at https://eprplastic.cpcb.gov.in/. Use your registered EPR login credentials (username and password) to access your account. Ensure you are using a compatible web browser (Chrome, Firefox, or Edge latest versions recommended). If you have forgotten your password, use the "Forgot Password" option to reset it using your registered email or mobile number.
- Step 2: Navigate to Annual Return Section - Once logged in, you will see your dashboard. Look for the "Annual Return" or "File Annual Return" option in the main menu. Select the financial year "2024-2025" from the dropdown menu. The system will display your registration details and any previous returns filed.
- Step 3: Verify Pre-Filled Information - The portal will pre-populate certain information from your registration profile, including company name, registration number, address, and authorized signatory details. Carefully verify all pre-filled information for accuracy. Update any changes through the appropriate update mechanism if needed before proceeding.
- Step 4: Enter Plastic Packaging/Waste Data - For PIBOs: Enter the total quantity of plastic packaging introduced, broken down by category (Rigid, Flexible, MLP, Compostable) and state/UT. Provide product-wise details if required. For PWPs: Enter the total quantity of plastic waste received and processed, categorized appropriately. Use the state-wise distribution tabs to allocate quantities correctly.
- Step 5: Enter EPR Compliance Details - For PIBOs: Upload details of EPR certificates purchased, including certificate numbers, PWP details, quantities, and categories. The system may allow bulk upload via Excel template—download the template, fill it carefully, and upload. For PWPs: Provide details of certificates issued to PIBOs during the year.
- Step 6: Upload Supporting Documents - Attach all required supporting documents in PDF format (generally). Common uploads include: invoices, purchase orders, EPR certificates, consent/authorization documents, and customs documents for importers. Ensure file sizes are within prescribed limits (typically 5MB per file). Name files clearly for easy identification (e.g., "EPR_Certificates_FY2024-25.pdf").
- Step 7: Data Validation and Error Checking - Use the built-in validation feature to check for errors or missing information. The portal will highlight issues such as mismatched totals, missing mandatory fields, invalid certificate numbers, or category mismatches. Correct all errors before proceeding. The validation feature helps prevent rejection of your return.
- Step 8: Review Summary - The portal will generate a summary of your annual return showing all entered data. Review this summary carefully as it represents your compliance declaration. Check that all quantities, categories, and states are correctly reflected. Verify that EPR compliance percentage is correctly calculated.
- Step 9: Apply Digital Signature - The annual return must be digitally signed by an authorized signatory of the company. Ensure your Digital Signature Certificate (DSC) is installed on your computer and is valid. Click "Sign and Submit" and follow the prompts to apply your DSC. The DSC must belong to an authorized person as per your company registration.
- Step 10: Final Submission - After successful digital signing, click "Submit" to file your annual return. The portal will generate an acknowledgment receipt with a unique submission ID. Download and save this acknowledgment immediately—it is your proof of filing. The submission timestamp is critical for demonstrating timely filing.
- Step 11: Download Filed Return Copy - After submission, download a complete copy of your filed annual return for your records. This document should be maintained in your compliance files for at least 5 years. The filed return copy will show all submitted data along with the submission ID and timestamp.
- Step 12: Payment (if applicable) - If there is any environmental compensation due for shortfall in EPR compliance, the portal will generate a payment challan. Complete the payment through the designated payment gateway. Retain payment receipts and challan copies. The environmental compensation mechanism is discussed in detail in the penalties section below.
Technical Support: If you encounter technical difficulties during the filing process, immediately contact the CPCB helpdesk at the numbers provided on the portal or through the grievance redressal mechanism. Keep your EPR registration number ready when seeking assistance. Document all technical issues with screenshots in case you need to demonstrate attempted compliance. Do not wait until July 31 to start filing—begin at least 2-3 weeks early to allow time for technical troubleshooting.
Common Filing Mistakes to Avoid
- Unit confusion: Always use metric tons as the standard unit. Converting from kilograms or other units incorrectly is a common error.
- State-wise mismatch: EPR certificates must match the state-wise distribution of your plastic packaging introduction. Cross-state certificates may not be accepted.
- Category errors: Ensure rigid, flexible, MLP, and compostable categories are correctly classified according to IS standards.
- Expired certificates: EPR certificates have validity periods. Using expired certificates will lead to compliance shortfall.
- Unauthorized PWPs: Verify that all PWPs from whom you have purchased certificates are registered and authorized on the CPCB portal.
- Incomplete documentation: Missing even one required document can lead to return rejection or show-cause notices.
- Last-minute filing: Portal traffic is highest near deadlines, leading to slowdowns and technical issues. Early filing is strongly recommended.
Legal Framework - Plastic Waste Management Rules
Understanding the legal and regulatory foundation of EPR compliance helps entities appreciate the serious nature of these obligations and ensures comprehensive compliance. The plastic waste management framework in India has evolved significantly over the past decade, reflecting the country's growing commitment to addressing plastic pollution and transitioning to a circular economy.
PWM Rules 2016 - Foundation
The Plastic Waste Management Rules, 2016, notified by the Ministry of Environment, Forest and Climate Change on March 18, 2016, form the foundational legal framework governing plastic waste management in India. These rules replaced the earlier Plastic Waste (Management and Handling) Rules, 2011, introducing more comprehensive and stringent provisions.