Renewal Condition for EPR Certificates Dropped

Ψ  Customs told not to Insist on Renewal Certificates

·         Reference: CBIC Instruction No. 14/2023-Customs dated 17.04.2023, CBIC Instruction No. 21/2025-Customs dated 02.07.2025, and TNPCB letter dated 15.08.2026.

·         Mandatory EPR Registration: Importers of:

o    Plastic packaging;

o    Commodities with plastic packaging;

o    Plastic raw materials; and

o    Intermediate materials used for manufacturing plastic packaging are required to register on the Common EPR Portal of CPCB.

·         No business without registration: Such importers are not permitted to carry out business activities without obtaining EPR registration.

·         Verification process: Applications on the Common EPR Portal are scrutinised by CPCB-I and/or SPCB, and EPR Registration Certificates are issued after verification of the details furnished by importers.

·         Problem reported by TNPCB: Importers were facing difficulties in obtaining Customs clearance because their EPR Registration Certificates showed a validity period of one year, leading to doubts regarding their continued validity.

·         Key clarification: EPR Registration Certificates issued with a one-year validity period are to be treated as “One-Time Registration Certificates.”

·         No renewal required: Following the amendment to the Plastic Waste Management Rules notified on 30.10.2023, such EPR registrations do not require renewal, despite the certificate displaying a one-year validity period.

·         Customs clearance: Customs officers are instructed to accept such one-year EPR certificates as valid proof of EPR registration and clear the import consignments accordingly, subject to verification of the EPR Registration Certificate.

·         Scope: The clarification applies to consignments involving plastic packaging, commodities with plastic packaging, plastic raw materials and intermediate materials for manufacturing plastic packaging.

·         Implementation: The instruction is to be circulated to all concerned officers for uniform implementation.

Effect: A one-year validity date printed on an EPR Registration Certificate should not by itself be a ground for withholding Customs clearance or requiring renewal. The certificate is to be treated as a one-time registration in accordance with the amended Plastic Waste Management Rules.

[CBIC Instruction No.15/2026-Customs dated 09.09.2026]

Subject: Registration of Importers under Centralized EPR Portal for Plastic Packaging as per Plastic Waste Management Rules, 2016 (as amended) and verification of registration.

Reference is invited to CBIC Instruction No. 14/2023-Customs dated 17.04.2023, CBIC Instruction No.21/2025-Customs dated 02.07.2025 and TNPCB letter dated 15.08.2026 (copy enclosed) on the above subject.

2. TNPCB in its  letter has stated that  all importers of plastic packaging, commodities with plastic packaging, plastic raw materials and intermediate materials are mandated to register on the Common EPR portal developed by Central Pollution Control Board (https://epr.cpcb.gov.in/home) and are not permitted to carry out any business activity without obtaining EPR registration.

3. It is also informed that the applications filed by importers in Common EPR portal is scrutinized by the CPCB I and or SPCB and EPR registration certificates are issued to the importers upon verification of correctness of the details furnished by importers in their EPR application.

TNPCB has further informed that it has been receiving grievances from various importers stating their difficulty in obtaining the consignments with due clearance from the Customs Department due to the invalid EPR certificate issued to importer specifying one year period as validity as mentioned in the certificate.

4. In view of this and in terms of TNPCB letter dated 15.08.2023, it is requested that necessary action may be taken to sensitise officers under your jurisdiction for the following:

a.   To clear the consignments of the importers those involved in importing of ay plastic packaging / any commodity with plastic packaging / plastic raw material I intermediate material for manufacturing plastic packaging material upon the verification of EPR registration certificates.

b.   To consider the EPR registration certificates issued to importers, indicating a validity period of one year, as "one-time Registration Certificates" which do not require renewal as per the amendment to the Plastic Waste Management Rules notified on 30.10.2023. Accordingly, such registration certificates may be accepted as valid proof of EPR registration for the purpose of import clearance, and the import consignments may be cleared accordingly.

5. The above instructions may be brought to the notice of all concerned officers for uniform implementation.

Difficulties, if any, in implementation of these instructions may be brought to the notice of the Board.

F.No. 401/11/2022-Cus.lll