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CBIC Tightens Customs Norms: EPR Registration Now Mandatory for Plastic Importers

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New Delhi, July 04, 2025: In a significant step towards strengthening India’s plastic waste management ecosystem, the Central Board of Indirect Taxes and Customs (CBIC) has directed all importers of plastic and plastic packaging materials to obtain mandatory registration under the Extended Producer Responsibility (EPR) framework before customs clearance. The directive, issued in line with the Plastic Waste Management Rules (PWM), 2016 (as amended), marks a turning point in India's efforts to curb the environmental impact of plastic consumption at the source.

New Customs Compliance: What’s Required?

According to CBIC’s recent circular, importers must now register on the centralized EPR portal managed by the Central Pollution Control Board (CPCB)  — before their plastic consignments can be cleared at ports. This requirement applies across the spectrum: from raw plastic resins to processed plastic packaging material.

Customs officers have been instructed to verify EPR registration details at the time of clearance, ensuring that no unregistered importer is able to bring plastic material into the country without a traceable sustainability commitment.

Why This Matters: From Policy to Practice

This move reflects a tightening of enforcement around India’s existing PWM framework, which has often suffered from weak compliance and fragmented implementation. The revised guidelines expand the definition of plastic packaging and plug critical gaps in accountability—particularly for importers who have, until now, operated outside the domestic producer registration regime.

The directive ensures alignment between environmental and trade authorities, strengthening the “Polluter Pays” principle embedded in the EPR system. It’s a concrete step to bring global plastic flows under the ambit of India's national waste management goals.

EPR in Focus: Driving Sustainable Stewardship

Extended Producer Responsibility holds producers, importers, and brand owners accountable for the life cycle of the plastic they place on the market. Under the updated PWM Rules, EPR mandates include collection targets, recycling obligations, and annual reporting.

While Indian manufacturers and FMCG companies have slowly begun aligning with these norms, the compliance of importers—particularly those bringing in high-volume plastic raw materials or finished packaging—has remained a grey area. CBIC’s latest mandate aims to close this enforcement gap.

Implications for Business: A Compliance-First Era

For importers, the directive introduces both urgency and responsibility. Firms must now:

  • Register with the CPCB on the centralized EPR portal.
  • Submit category-wise data on imported plastic.
  • Adhere to annual collection and recycling targets.
  • Maintain transaction records for audit and reporting purposes.

Failure to comply could lead to delays in customs clearance, monetary penalties, or seizure of goods. For businesses that have yet to align their procurement and logistics with environmental norms, this could mean disruptions.

Sectoral Impact: From FMCG to Manufacturing

Sectors like FMCG, pharmaceuticals, and retail—heavy consumers of imported plastic packaging—will feel the immediate impact. Importers of virgin plastic resin, preforms, bottles, wrappers, and flexible packaging will now be brought into India’s sustainability compliance regime, creating a more level playing field for domestic producers already subject to EPR.

While some industry stakeholders have welcomed the move as a step towards fairness and ecological accountability, others have raised concerns over a lack of transition time and the need for clearer implementation guidelines from CPCB.

Editorial Analysis: Aligning Trade with Environmental Accountability

At TheCSRUniverse, we view this directive as a long-overdue reform that brings critical regulatory coherence between environmental sustainability and cross-border trade. For too long, the import side of India’s plastic consumption story has remained under-regulated. This policy ensures that environmental accountability doesn't end at the shoreline.

However, the success of this measure hinges on robust digital infrastructure, responsive support systems on the CPCB portal, and capacity-building among customs officials. Small and medium enterprises (SMEs) involved in plastic imports will also need hand-holding to navigate the complex compliance landscape.

Can India Lead by Example?

Globally, few countries have integrated customs compliance with environmental EPR frameworks at this scale. India’s move can set a precedent—if followed through with consistency and transparency. As the country prepares to host key global sustainability dialogues, such policy steps signal a maturing commitment to lifecycle-based environmental governance.

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