Understanding EPR Targets — What Percentage You Must Recycle
Every year, your business is given a specific recycling target. This target is a percentage of the electronic products you have sold in previous years, and it increases gradually over time. As per the official CPCB schedule:
- FY 2023-24 and FY 2024-25: Target is 60% of your waste generation obligation
- FY 2025-26 and FY 2026-27: Target rises to 70%
- FY 2027-28 and FY 2028-29 onwards: Target rises further to 80%
If your business has only recently started selling electronic products, a separate and slightly different target schedule applies to you, based on how long you have been in operation.
There is also a special case for imported used or second-hand electronic equipment — in this situation, the target is 100% of the quantity imported, meaning the full quantity must eventually be accounted for through recycling.
Meeting this target is not something you do by guesswork. It is tracked and verified through a document called an EPR Certificate.
What Is an EPR Certificate?
An EPR Certificate is proof that a certain quantity of e-waste has actually been collected and recycled by a CPCB-registered recycler. Since most producers do not recycle their own products directly, they buy these certificates from authorised recyclers who have genuinely processed that quantity of e-waste.
These certificates are bought and sold on the CPCB's online EPR portal, almost like a trading system. If you fall short of your target, you can purchase EPR certificates to cover the gap. If you have surplus certificates, in some cases these can be carried forward, though they usually have a limited validity period, so planning ahead matters.
Simply put — you cannot claim compliance just by stating a number. You need actual, verifiable EPR certificates from registered recyclers to prove your target was met.
Filing Your Returns — Quarterly and Annual
Compliance is not just about registration. It is an ongoing yearly responsibility that includes regular reporting to the CPCB. There are two types of returns you need to file:
- Quarterly Returns: These are filed after every three months and report your sales and collection data for that quarter. These must be filed in sequence — meaning Quarter 1 must be filed before Quarter 2, and so on.
- Annual Return (Form 3): This is the yearly summary of your entire compliance performance — how much you sold, how much e-waste you were obligated to recycle, and how much you actually recycled through verified EPR certificates. This annual return is typically due by June 30 of the following financial year, though it is always wise to check the CPCB portal for the latest notified date, since deadlines have been extended in the past.
Even if your business had zero sales or zero activity in a particular period, you are still required to file a return — usually called a NIL return. Skipping this step, even when you have nothing to report, is treated as non-compliance.
All returns must now be filed digitally through the CPCB's EPR portal. Physical or offline submissions are no longer accepted.
What Happens If You Don't Comply?
Non-compliance with E-Waste rules is treated seriously, and the consequences go beyond just a warning letter. Here is what businesses risk if they ignore this responsibility:
- Financial penalties: Under the Environment (Protection) Act, 1986, non-compliance can attract monetary penalties, and continuing violations can add further daily charges until the issue is resolved.
- Show-cause notices: The CPCB has been increasing scrutiny on non-compliant businesses and regularly issues formal notices demanding an explanation.
- Import and customs issues: The CPCB is now linking EPR registration data with Customs and BIS databases. This means products without a valid EPR registration may face clearance delays or rejections at the port.
- Reputational damage: With ESG (Environmental, Social, Governance) reporting becoming more important to investors and business partners, a poor or missing e-waste compliance record can hurt your company's credibility and future business opportunities.
- Loss of business continuity: In serious or repeated cases of non-compliance, businesses risk having their registration suspended, which can directly stop their ability to legally sell or import electronic products in India.
In short, this is not a rule you can afford to ignore, no matter how small your business currently is.