Frequently Asked Questions

Everything you need to know about EPR Registration, filing, compliance, and our process.

1. Can I claim GST input on EPR credit purchases?

Yes. GST input credit is generally claimable on purchases of EPR credits, subject to prevailing tax laws and conditions. Entities should ensure that EPR credit purchases are supported by proper GST-compliant invoices and recorded accurately in their books of accounts.

2. What data and documents are required for filing annual EPR returns?

Typical requirements include:

  • Sales data (with packaging details and quantities).
  • Procurement details for plastic packaging.
  • EPR credit purchase and usage records.
  • Stock records (opening, closing and in-transit, if applicable).
  • For exports: bulk export data and invoice/shipping documentation.

3. Are contract manufacturers liable for EPR?

Yes. Following the March 2024 amendment to the PWM Rules, contract manufacturers can be liable as Producers and must register on the CPCB EPR portal.

  • If a contract manufacturer sells to a registered Brand Owner, EPR liability may be contractually passed to the Brand Owner. They have to fulfil the pre-consumer target obligations.
  • If sales are to an unregistered Brand Owner, the contract manufacturer remains responsible for the EPR liability.
  • EPR liability is calculated using the prescribed Producer formula.
  • If the contract manufacturer is a micro or small enterprise under the MSME Act, it is exempt from EPR liability but must register under SIMP and file returns for record and compliance purposes.

4. Can a proprietor use his/her own PAN for registration?

Yes. A sole proprietor can use their personal PAN for CPCB EPR registration, since the business is legally in the proprietor’s name. It is important to ensure that the name on the PAN and the GSTIN matches.

5. Do proprietors need a CIN?

No. CIN (Corporate Identification Number) applies to companies; it is not applicable to proprietorships.

6. When can we expect a Pollution Control Board audit?

From FY 2024–25 onwards, statutory return filing fees include an audit component. Accordingly, audits can be expected to commence from FY 2025–26, with entities selected based on CPCB/SPCB criteria.

7. What can I do if a vendor uploaded incorrect data under the wrong category (for example, importer instead of brand owner)?

Recommended steps:

  1. Contact the vendor: Request them to correct and re-upload the data under the correct category, if their return is not yet finalized.
  2. If vendor correction is not possible:
  • Raise a correction request with CPCB via email, explaining the issue and enclosing supporting documents.
  • Log a ticket on the CPCB portal (if available) describing the discrepancy.
  1. Document in your annual return: Briefly mention the issue and steps taken to rectify it in the “Remarks” section (e.g., S. No. 9 – Enter Remark) while filing your annual return.

8. How do I report sales to registered persons so that my EPR liability is transferred?

To transfer EPR liability for sales to registered entities (e.g., registered PIBOs):

  1. Report sales details:
  • Issue a GST-compliant invoice with quantity, category of plastic packaging and buyer details.
  • Ensure the buyer’s EPR registration details are correctly captured.
  1. Update the EPR portal:
  • Use the relevant transaction or trade section on the CPCB portal.
  • Declare the sale and transfer of liability to the registered buyer, referencing the invoice.
  1. Confirm transfer:
  • Check that the portal reflects the transfer and updates both parties’ ledgers.
  • Ensure the buyer accepts/acknowledges the transaction where required.
  1. Maintain records:
  • Keep invoices, portal acknowledgements and correspondence for audit.

9. Do I need to renew my EPR registration every year?

No, EPR registration is typically not renewed annually as long as returns are filed on time and in compliance with CPCB requirements.

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