1. Is there any exemption from EPR registration for importers?
No. All importers, including micro and small enterprises, must register and fulfil EPR obligations for plastic packaging associated with imported goods with plastic packaging as well as import of Raw materials that are used for manufacture of plastic packaging.
2. Is there a template for uploading import purchase data?
Yes. CPCB provides an Excel template on the EPR portal for bulk upload of import purchase data. This is typically available under the “Material Procurement” or equivalent section for importers.
3. If I import grip sheets, does that count as plastic packaging?
Grip sheets used purely for securing loads and not as packaging generally do not fall within the definition of plastic packaging for EPR purposes. Accordingly, such grip sheets would normally not be included in the EPR liability calculation, subject to CPCB’s definitions and clarifications.
4. How should importers of plastic raw material register for EPR?
Importers of plastic raw material are obligated entities under the PWM Rules, 2016. They must register under the SIMP category on the CPCB EPR portal.
5. Are HSN codes mandatory when uploading import data?
Yes. HSN codes are mandatory while uploading import purchase details. HSN (Harmonized System of Nomenclature) codes are standard classification codes for goods and help CPCB cross-check packaging details against tax and customs records, reducing the risk of misreporting.