India Extended Producer Responsibility (EPR) system for plastic packaging is facing questions over the accuracy of recycling claims and the lack of transparency surrounding the data used to measure compliance.
According to the latest Central Pollution Control Board (CPCB) data, India has recycled 17 million tonnes of plastic packaging waste since the EPR regime came into force in 2022. Based on an average EPR certificate value of about ₹1,500 per tonne, the recycling activity represents an estimated ₹2,500 crore market.
The figures appear significant when compared with CPCB estimate that India generates about 3.8 million tonnes of plastic waste annually. However, the continued presence of plastic waste in cities, villages, drains and waterways raises questions about whether the official system is accurately capturing the amount of waste actually collected and recycled.
EPR places responsibility for collecting and recycling plastic waste on producers, importers and brand owners (PIBOs). Since 2023-24 PIBOs have been required to collect 100 per cent of the plastic packaging they generate, while recycling targets apply to a portion of the collected material.
For 2026-27 recycling targets range from 50 to 70 per cent depending on the category of plastic. For Category 2 plastics which include flexible packaging such as food wrappers and shampoo sachets, companies are required to collect all their packaging waste and recycle 50 per cent of it.
Questions over collection data
Under the EPR system PIBOs contract registered plastic waste processors (PWPs) to handle recycling. There are more than 1,000 registered processors, according to official data.
Each tonne of plastic recycled generates an EPR certificate. Companies that fail to meet their recycling obligations can face environmental compensation with penalties set at 2.5 times the estimated compliance cost.
However, questions remain over whether companies’ reported waste generation figures accurately reflect the amount of plastic they put into the market.
An analysis of the official EPR portal in 2024 found that 41,544 PIBOs had registered and received recycling targets based on self reported data. The process used to validate those figures has not been clearly established.
Evidence from the ground has also raised concerns. An audit of plastic waste in drains in Agra reportedly found that branded plastic packaging accounted for about 70 per cent of the waste, raising questions about how companies could simultaneously report 100 per cent collection.
Verification of recycling certificates
Another concern involves verification of the volume of plastic that processors actually recycle.
CPCB says it uses audits and ground-level checks to verify processing activity. On June 26, the regulator directed states to take action against non compliant plastic waste processors.
According to the report, audits have indicated that some processors were generating EPR certificates beyond their registered processing capacity and committing other violations.
CPCB requires processors to upload GST invoices as evidence that recycled products have been sold. However, the recycled material is often converted into plastic pellets that are sold to industries, including businesses operating in the informal sector, making the recycling chain difficult to independently verify.
The 18 per cent GST rate on such transactions may also make formal transactions economically difficult in some cases. The economics of EPR could present another problem.
While CPCB estimates the cost of recycling plastic waste at around ₹4,000 per tonne, the rates prescribed for processors can be significantly lower. For Category 2 plastic, for example, the mandated rate is around ₹1,500 per tonne.
Research cited in the article estimates that the actual cost of recycling this type of plastic can range between ₹4,000 and ₹6,000 per tonne.
This gap could make genuine recycling financially unattractive while creating an incentive for companies to obtain EPR certificates without ensuring that equivalent quantities of plastic are physically recycled.
Although companies face higher penalties for failing to meet their targets, the system could therefore encourage certificate based compliance if actual recycling costs remain above the prescribed rates.
The concerns have renewed calls for greater public scrutiny of India’s EPR system.
As of June 28, 2026, access to the EPR portal was reportedly restricted to a closed group of users. Supporters of restricted access may argue that commercial information needs protection, but critics say limited public access makes it harder to independently verify collection, recycling and certificate claims.
The central question is whether the impressive recycling figures reported through the EPR system accurately reflect what is happening on the ground.
With plastic waste continuing to accumulate in drains, waterways and public spaces, greater transparency over the amount of plastic generated, collected, processed and actually recycled could be crucial to determining whether the EPR regime is delivering the results reflected in official data.