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India Mandates EPR Registration for Plastic Raw Materials Importers for Customs Clearance

by Theory Wen Aug 04, 2025
India's CBIC now mandates EPR registration for plastic raw materials importers before customs clearance, aiming to strengthen plastic waste management and ensure accountability across the supply chain.

On July 2, 2025, India's Central Board of Indirect Taxes and Customs (CBIC) issued the Instruction No. 21/2025-Customs, mandating that importers of plastic raw materials must present proof of registration on the Centralized EPR Portal for Plastic Packaging before their consignments can clear customs.

The policy is referenced to the Central Pollution Control Board (CPCB) letter F. No. CP-20/10/2024-UPC-II-HO-CPCB-HO-Part(3) dated June 3, 2025.  As per the provisions of Plastic Waste Management (Amendment) Rules, 2024, the definition for "importer" is further expanded to include "importers of plastic raw material including in the form of resin or pellets, or intermediate material to be used for manufacturing plastic packaging such as films or preforms". Therefore, such importers are required to register on the centralized portal for plastic packaging.

This strategic move by the CBIC reflects a concerted effort to enhance compliance within India's existing PWM framework, which has historically faced challenges due to weak enforcement and fragmented implementation.

As per the PWM Rules, EPR holds producers, importers, and brand owners accountable for the entire life cycle of the plastic products they introduce to the market. EPR mandates explicit obligations for recycling, reuse, the use of recycled content, end-of-life disposal, and filing annual return.

For importers, regardless of their business scope entailing plastic packaging, any commodity with plastic packaging, or plastic raw materials or intermediate materials for the manufacturing of plastic packaging, they are subject to the following obligations:

  • Register with the Central Pollution Control Board (CPCB) on the centralized EPR portal.

  • Submit category-wise data on all imported plastic.

  • Adhere to annual EPR targets.

  • Keep records for annual returns filing.

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Theory Wen
ChemLinked Regulatory Analyst
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