EPR Registration Now a Customs Gate for Plastic Importers: What CBIC Instruction 15/2026 Means at Clearance

Importers who bring in plastic packaging, plastic raw materials, or products sold in plastic packaging now face an added check at the border. The Central Board of Indirect Taxes and Customs (CBIC) has told field formations to verify that such importers hold a valid Extended Producer Responsibility (EPR) registration on the Central Pollution Control Board (CPCB) portal before goods are cleared. In short: no valid EPR registration, and your consignment can be held up.

What Happened

CBIC issued Instruction No. 15/2026-Customs, dated 9 September 2026, on the registration of importers on the Centralised EPR Portal for Plastic Packaging under the Plastic Waste Management Rules, 2016 (as amended), and the verification of that registration at the time of customs clearance.

Under the Plastic Waste Management Rules, importers dealing in plastic packaging, in commodities packaged in plastic, and in plastic raw materials and intermediates used to make plastic packaging are treated as "Producers/Importers" and must register on the Common EPR Portal run by CPCB. Such importers are not permitted to carry on the relevant business activity without an EPR registration. The instruction operationalises that requirement at the customs stage, asking officers to confirm registration before facilitating clearance.

Applications filed on the Common EPR Portal are scrutinised by CPCB and/or the concerned State Pollution Control Board (SPCB), and an EPR Registration Certificate is issued after the details are verified. Trade guidance indicates the registration certificate carries a defined validity (reported as one year in several practitioner notes), after which it must be renewed to remain valid for clearance.

Why This Matters

EPR shifts the cost and responsibility for end-of-life plastic waste onto those who put plastic into the market — including importers. India has been steadily tightening enforcement of the Plastic Waste Management framework, and linking it to customs clearance closes a long-standing gap where importers could bring in plastic-packaged goods without being enrolled in the waste-management regime.

For customs officers, the change gives a clear documentary checkpoint. For importers, it converts an environmental-compliance obligation into a trade-facilitation issue: a lapse that used to invite a pollution-board notice can now stall a bill of entry.

Who's Affected

The measure reaches a broad set of importers, not just plastics traders. It covers importers of plastic packaging material itself; importers of goods that arrive in plastic packaging (a very wide category across FMCG, electronics, cosmetics and more); and importers of plastic raw materials and intermediates. Customs House Agents (CHAs) filing on behalf of these importers will need to confirm the client's EPR status before filing, or risk queries and held consignments.

What Importers and CHAs Should Do Now

• Check whether your product profile makes you a "Producer/Importer" under the Plastic Waste Management Rules — this includes goods merely packaged in plastic, not only plastics as such.
• Register on the CPCB Centralised EPR Portal and obtain the EPR Registration Certificate before your next import, if you have not already.
• Verify the validity window on your certificate and diarise renewal well ahead of expiry, so it does not lapse mid-shipment.
• Keep the registration number and certificate handy in your import documentation set, alongside IEC and other clearance papers.
• CHAs: add an EPR-registration check to your pre-filing checklist for any client importing plastic packaging, plastic raw material, or plastic-packaged goods.
• Reconcile the product categories on your EPR registration with the HS codes you actually import, so a category mismatch does not trigger a query.

The Bigger Picture

This is part of a wider hardening of non-tariff, compliance-linked controls at Indian borders — sitting alongside tighter food-import checks, quality control orders and pre-shipment inspection rules. The direction of travel is consistent: registrations and certifications that were once enforced separately are increasingly being wired into the customs clearance workflow itself. Importers who treat regulatory registrations as a one-time formality, rather than a live compliance status to be maintained, are the most exposed to disruption.

Frequently Asked Questions

Does this apply if I only import goods that happen to be packaged in plastic? Potentially yes. The Plastic Waste Management Rules treat importers of commodities packaged in plastic as producers/importers for EPR purposes. Check your specific category against the rules and CPCB guidance.

Is EPR registration a one-time process? No. The registration certificate has a validity period (reported as one year in trade guidance) and must be renewed. An expired registration can create the same clearance problem as no registration at all.

Where do I register? On the Central Pollution Control Board's Centralised EPR Portal for Plastic Packaging. CPCB and/or the State Pollution Control Board scrutinise applications before issuing the certificate.

What happens if I don't have a valid registration at clearance? Customs officers have been instructed to verify EPR registration before facilitating clearance, so consignments risk queries and delays until valid registration is produced.

Conclusion

CBIC has effectively made EPR registration a precondition for smooth customs clearance of plastic-linked imports. The compliance itself is not new, but its enforcement point has moved to the border. Importers and CHAs should confirm registration status and renewal timelines now, well before their next plastic-linked consignment arrives.

This summary is for general guidance only. Importers should verify the exact scope and obligations against CBIC Instruction No. 15/2026-Customs, the Plastic Waste Management Rules, 2016 (as amended), and CPCB's EPR portal guidance before acting.