Extended Producer Responsibility (EPR) has become an important compliance requirement for businesses that manufacture, import or sell plastic packaging in India. For Producers, Importers and Brand Owners (PIBOs), filing the annual return is an important part of demonstrating compliance with plastic waste management obligations.
For 2026, PIBOs also need to pay attention to an important portal transition. The earlier Centralized EPR Portal for Plastic Packaging was discontinued from 28 June 2026, with registered-user data migrated to the new Common EPR Portal.
This guide explains the Plastic EPR Annual Return 2026, applicable deadlines, important documents, filing process and common compliance mistakes.
What Is a Plastic EPR Annual Return?
A Plastic EPR Annual Return is a yearly compliance filing through which eligible stakeholders report information related to plastic packaging placed on the Indian market and the management of corresponding plastic waste.
Under the EPR Guidelines for plastic packaging, PIBOs are required to submit annual returns covering plastic packaging waste collected and processed towards their EPR obligations. The return also includes information related to reuse and recycled content used for packaging and details of registered recyclers from whom recycled plastic has been procured.
In simple terms, the annual return helps regulators compare:
- Plastic packaging introduced into the market
- Applicable EPR obligations
- Plastic waste processing and recycling
- EPR certificates obtained
- Reuse and recycled-content information
- Compliance achieved during the financial year
Who Needs to File the Plastic EPR Annual Return?
The EPR framework applies to relevant Producers, Importers and Brand Owners (PIBOs) covered under the Plastic Waste Management Rules and applicable EPR Guidelines.
PIBOs should maintain accurate records throughout the financial year rather than waiting until the annual return window opens.
The requirement can involve businesses that:
- Manufacture plastic packaging
- Import products packaged in plastic
- Sell products under their own brand
- Use plastic packaging as part of their product distribution
- Have EPR obligations under the applicable plastic packaging framework
Businesses should assess their specific applicability based on the latest regulatory requirements and their registration status.
Plastic EPR Annual Return 2026 Deadline
The EPR Guidelines provide that PIBOs should file their annual returns by 30 June of the following financial year. The annual return covers plastic packaging waste collected and processed towards EPR obligations, along with other prescribed information.
For example:
| Financial Year | Normal Annual Return Deadline |
|---|---|
| FY 2024–25 | 30 June 2025 |
| FY 2025–26 | 30 June 2026 |
| FY 2026–27 | 30 June 2027 |
However, PIBOs should not assume that a deadline has been extended simply because the portal has undergone technical or administrative changes.
The EPR Guidelines also provide that the Central Government may permit filing for a period of up to nine months beyond the prescribed period for recorded reasons. Any extension should therefore be treated as dependent on an official notification or direction rather than an automatic extension.
Important 2026 Change: New Common EPR Portal
One of the biggest practical changes for PIBOs in 2026 is the transition from the earlier Plastic EPR Portal to the Common EPR Portal.
CPCB states that operations of the old Plastic EPR Portal were discontinued from 28 June 2026. Data of registered units was migrated to the new Common EPR Portal. Existing users have been instructed to verify their migrated information and report discrepancies through the new portal.
This makes data verification particularly important for PIBOs preparing their compliance records.
Businesses should check:
- Company details
- PAN details
- Authorised-person information
- Registration information
- Historical EPR data
- Packaging information
- EPR obligation data
- Available certificate information
CPCB has also stated that existing accounts should be linked using the same Authorised Person PAN and Company PAN used on the earlier portal.
Documents Required for Plastic EPR Annual Return
The exact information requested by the portal may depend on the stakeholder profile and applicable compliance requirements. PIBOs should keep their supporting records organised before starting the filing process.
Important records may include:
1. Company and Registration Details
Keep updated information such as:
- Legal company name
- Registered address
- PAN
- GST details
- CIN, where applicable
- EPR registration details
- Authorised person’s details
CPCB’s portal guidance identifies company and authorised-person information as part of the PIBO registration framework.
2. Plastic Packaging Data
PIBOs should maintain records of the quantity and category of plastic packaging introduced into the market.
Depending on the applicable packaging category, businesses may need information relating to:
- Packaging material
- Packaging category
- Quantity purchased
- Quantity manufactured
- Quantity imported
- Quantity sold
- Reusable packaging
- Recycled plastic content
Accurate category-wise data is essential because EPR obligations are linked to the applicable packaging information.
3. EPR Certificate Records
PIBOs should maintain records of EPR certificates obtained for fulfilling their obligations.
The CPCB framework provides for generation and transfer of EPR certificates between registered plastic waste processors and PIBOs.
Companies should reconcile:
EPR obligation → certificates available/procured → compliance achieved → remaining shortfall
before submitting the annual return.
4. Recycling and Waste Processing Records
Businesses should maintain supporting information related to the processing of plastic packaging waste.
This can include:
- Plastic waste quantity processed
- Registered plastic waste processor details
- Recycling records
- Certificates
- Transaction records
- Supporting invoices and documentation
5. Recycled Content Information
The EPR annual-return framework also requires information concerning recycled plastic content used for packaging purposes.
PIBOs should therefore maintain reliable records showing the quantity of recycled plastic incorporated into applicable packaging.
6. Reuse Information
Where packaging is reused, relevant reuse quantities and supporting records should be maintained.
A clear internal reconciliation can help prevent inconsistencies between packaging procurement, sales and EPR reporting.
How to File the Plastic EPR Annual Return in 2026
The filing process can be approached in a structured manner.
Step 1: Verify Your EPR Registration
Before filing, confirm that your PIBO registration details are correct.
For users migrated from the previous portal, verify the information available on the Common EPR Portal.
Step 2: Reconcile Your Packaging Data
Prepare your annual packaging data before entering information into the portal.
Your internal records should reconcile with:
- Procurement
- Production
- Imports
- Sales
- Packaging consumption
- Reuse
- Recycled content
Step 3: Calculate Your EPR Obligation
Determine the applicable EPR obligation based on your packaging categories and quantities.
Do not rely only on an internal estimate. Reconcile the figures with the information available in your EPR account.
Step 4: Reconcile EPR Certificates
Review certificates generated, transferred or procured during the relevant compliance period.
Check for:
- Correct quantity
- Correct category
- Correct transaction details
- Valid registered processor information
- Any outstanding shortfall
Step 5: Complete the Annual Return
Enter the required information in the applicable annual-return module of the portal.
The CPCB guidance manual explains that the annual-report framework includes sections for procurement/sales information and compliance status.
Step 6: Review Before Submission
Before submitting, compare the portal data with your internal compliance records.
Look for differences in:
- Packaging quantities
- Category classification
- EPR targets
- Certificates
- Recycled content
- Reuse quantities
Step 7: Keep the Filing Records
After filing, retain the acknowledgement and supporting records with your compliance documentation.
A well-organised audit trail can make future regulatory reviews much easier.
What Happens If PIBOs Do Not File the Annual Return?
Failure to meet EPR requirements can create compliance risks.
CPCB has previously taken action against PIBOs for non-filing of annual returns. In past notices, CPCB referred to auto-filing of annual returns and consequences involving EPR targets and environmental compensation for certain cases of non-compliance.
Environmental compensation can also be linked to non-fulfilment of EPR targets under the applicable framework.
Therefore, PIBOs should not treat the annual return as a simple administrative formality.
It is part of the broader EPR compliance process.
Common Plastic EPR Filing Mistakes
Businesses can reduce compliance problems by avoiding these common mistakes:
Incorrect Packaging Quantities
Differences between sales, procurement and EPR records can create reconciliation problems.
Last-Minute Filing
Waiting until the deadline can leave little time to correct missing certificates or data discrepancies.
Incorrect Packaging Category
Plastic packaging should be reported under the appropriate applicable category.
Missing Certificate Reconciliation
The number and quantity of EPR certificates should be checked against the actual EPR obligation.
Ignoring Portal Migration
Businesses that previously used the old portal should verify migrated information rather than assuming all data transferred correctly.
Incomplete Supporting Records
Invoices, transaction records, recycler information and other supporting documents should be retained systematically.
How Businesses Can Prepare for the Next EPR Filing Cycle
A strong EPR compliance system should operate throughout the year.
Instead of collecting information only before the annual return deadline, businesses can maintain a monthly EPR compliance tracker.
A useful tracker can include:
| Compliance Area | Data to Track |
|---|---|
| Packaging | Category and quantity |
| Procurement | Plastic packaging/raw material purchased |
| Sales | Packaging placed on market |
| Imports | Imported plastic packaging |
| Reuse | Reusable packaging quantity |
| Recycling | Waste processed |
| Certificates | EPR certificates obtained |
| Recycled Content | Recycled plastic used |
| Compliance | Target vs achievement |
This approach makes the annual return process faster and reduces the possibility of data gaps.
Final Checklist for Plastic EPR Annual Return 2026
Before submitting the annual return, PIBOs should verify:
☐ EPR registration is active and accurate
☐ Common EPR Portal account details are verified
☐ Company and PAN details are correct
☐ Plastic packaging quantities are reconciled
☐ Packaging categories are correctly identified
☐ EPR obligations are calculated correctly
☐ EPR certificates are reconciled
☐ Recycler/PWP records are available
☐ Recycled-content information is supported
☐ Reuse information is supported
☐ Annual-return information is reviewed before submission
☐ Filing acknowledgement and supporting records are retained
Conclusion
The Plastic EPR Annual Return 2026 is an important compliance requirement for PIBOs operating under India’s plastic packaging EPR framework. While the prescribed annual-return timeline remains based on the 30 June deadline for the following financial year, businesses should always check the latest CPCB notifications for any officially announced extension or procedural change.
The 2026 transition to the Common EPR Portal also makes data verification an important step for existing PIBOs. CPCB has confirmed that the earlier Plastic EPR Portal was discontinued from 28 June 2026 and that registered-user data was migrated to the new system.
For PIBOs, the best approach is simple: maintain accurate packaging records throughout the year, reconcile EPR certificates regularly, verify portal data and prepare the annual return well before the deadline.
Proper preparation can help businesses reduce compliance errors and build a stronger, more transparent plastic waste management system by Gem Enviro.