CBIC Clarifies EPR Registration Checks for Plastic-Packaging Importers — One-Year Certificates Are One-Time, No Annual Renewal

What changed: On 9 September 2026, the Central Board of Indirect Taxes and Customs (CBIC) issued Instruction No. 15/2026-Customs on how Customs field formations should verify Extended Producer Responsibility (EPR) registration when clearing imports of plastic packaging and related materials. The headline clarification is that an EPR Registration Certificate showing a one-year validity period is to be treated as a "one-time" registration certificate and does not require annual renewal — resolving a dispute that had been holding up consignments at some ports.

If you import plastic packaging, goods sold in plastic packaging, plastic raw materials, or intermediate materials used to make plastic packaging, this directly affects how quickly your Bills of Entry clear.

What Happened

CBIC has reiterated the existing rule under the Plastic Waste Management Rules, 2016 (as amended): importers dealing in plastic packaging, commodities packed in plastic, plastic raw materials, and intermediates for manufacturing plastic packaging must register on the Centralized EPR Portal developed by the Central Pollution Control Board (CPCB). Such importers are not permitted to carry on the relevant business without EPR registration, and applications are scrutinised by CPCB and/or the concerned State Pollution Control Board (SPCB) before a certificate is issued.

The Instruction then addresses a practical problem. Some EPR Registration Certificates were being issued with a stated validity of one year, and Customs officers at certain ports were treating them as expired or requiring fresh registration — delaying clearance. The matter was flagged by the Tamil Nadu Pollution Control Board (TNPCB) in relation to consignments covered by the plastic-packaging EPR framework.

CBIC's resolution: certificates showing a one-year validity are to be accepted as one-time registration certificates that do not require annual renewal, in line with the amendment to the Plastic Waste Management Rules notified on 30 October 2023. Customs formations are directed to clear eligible consignments after verifying the importer's EPR Registration Certificate, subject to normal verification.

Why This Matters

EPR compliance sits at the intersection of environmental law and Customs clearance. Because Customs verifies EPR registration at the border, any ambiguity about certificate validity translates directly into detained cargo, demurrage, and missed delivery windows. By confirming that a one-year-validity certificate is effectively a standing registration, CBIC removes a recurring reason for holds and gives both officers and importers a single, uniform rule to apply.

Who's Affected

The Instruction affects a wide base of importers, not just plastics manufacturers. Anyone importing finished goods that arrive in plastic packaging, plastic raw materials (resins, granules), or intermediate materials for making plastic packaging falls within the EPR framework — spanning FMCG, electronics, consumer goods, and industrial supplies. Customs House Agents (CHAs) handling these consignments should update their checklists so that a one-year certificate is not mistaken for an expiring document.

What Importers and CHAs Should Do Now

• Confirm you hold a valid EPR Registration Certificate on the CPCB Common EPR Portal before filing the Bill of Entry for any plastic-packaging-linked consignment.
• Do not assume a one-year certificate has lapsed — under this Instruction it is treated as a one-time registration and needs no annual renewal, provided it was issued consistent with the 30 October 2023 amendment.
• Keep the certificate readily retrievable for Customs verification; attach it or reference it in your clearance documentation to pre-empt queries.
• CHAs: brief clearance teams that a one-year-validity EPR certificate is acceptable, and escalate through the proper officer if a consignment is held on validity grounds contrary to this Instruction.
• Verify certificate particulars are correct, since registrations are issued after CPCB/SPCB scrutiny and Customs clearance remains subject to verification.

The Bigger Picture

India is steadily wiring environmental-compliance checks into the Customs clearance chain, alongside BIS Quality Control Orders, FSSAI food registration, and similar gates. For importers, the operational lesson is consistent: registrations held with the relevant regulator (here CPCB) increasingly determine whether cargo moves at the border. This Instruction is facilitative — it reduces friction rather than adding an obligation — but it also underlines that EPR registration is now a standard clearance prerequisite for plastic-linked imports.

Frequently Asked Questions

Does a one-year EPR certificate need to be renewed every year for Customs clearance? No. Under this Instruction, a certificate showing one-year validity is treated as a one-time registration and does not require annual renewal, consistent with the 30 October 2023 amendment to the Plastic Waste Management Rules.

Who needs EPR registration for imports? Importers of plastic packaging, commodities packed in plastic, plastic raw materials, and intermediate materials used to manufacture plastic packaging must register on the CPCB Common EPR Portal.

Will Customs still verify my registration? Yes. Clearance is granted after verification of the EPR Registration Certificate, and remains subject to normal checks.

Which authority issues the certificate? Applications are filed on the CPCB Common EPR Portal and scrutinised by CPCB and/or the relevant State Pollution Control Board before issuance.

Conclusion

CBIC's Instruction No. 15/2026-Customs is a welcome clarification for plastic-packaging importers: a one-year EPR certificate is a one-time registration, and eligible consignments should clear on verification without a fresh registration demand. Update your import checklists accordingly and keep the certificate on hand.

This summary is for general guidance only. Importers should rely on the official text of Instruction No. 15/2026-Customs and the CPCB Common EPR Portal for authoritative requirements.