EPR Registration Now Verified at Customs: A Compliance Alert for Importers of Plastic Packaging and Plastic Raw Materials

If you import plastic packaging, goods sold in plastic packaging, or plastic raw materials such as resin, granules, pellets, films or preforms, Customs can now hold your consignment until you show valid Extended Producer Responsibility (EPR) registration. The Central Board of Indirect Taxes and Customs (CBIC) has instructed field formations to verify EPR registration on the Central Pollution Control Board (CPCB) portal at the time of clearance. In plain terms: no EPR registration on record can mean no clearance. This note explains what changed, who is caught, and what to do before your next Bill of Entry.

What Happened

CBIC issued Instruction No. 15/2026-Customs, dated 9 September 2026, on registration of importers on the Centralised EPR Portal for Plastic Packaging under the Plastic Waste Management Rules, 2016 (as amended), and verification of that registration for Customs clearance. It builds on an earlier direction (Instruction No. 21/2025-Customs of July 2025) that first told Customs to check EPR registration before releasing plastic raw material consignments.

The effect is procedural but real: at the assessment or examination stage, the system and officers are expected to confirm that the importer holds a valid EPR registration on the CPCB Common EPR Portal. Where registration cannot be evidenced, clearance can be queried or held pending compliance.

Why This Matters / Background

EPR makes the producer, importer or brand-owner responsible for the environmentally sound management of plastic packaging once it reaches end-of-life. The obligation sits in the Plastic Waste Management Rules and is administered through the CPCB's Common EPR Portal, where obligated entities register, file annual returns and meet recycling and end-of-life targets.

The scope has been read broadly. The relevant "importer" definition has been expanded to include importers of plastic raw material — including resin or pellets — and intermediate material used to manufacture plastic packaging, such as films or preforms. This pulls in not just brand-owners shipping finished packaged goods, but upstream importers of polymer inputs who may not have thought of themselves as "packaging" businesses.

Linking the obligation to the border is a familiar enforcement pattern in India — the same approach already applies to BIS quality-control checks and to several product registrations. Once a compliance requirement is wired into the clearance workflow, it stops being optional in practice.

Who's Affected

• Importers of plastic packaging and of commodities supplied in plastic packaging.
• Importers of plastic raw materials — resin, granules, pellets — and intermediates such as films and preforms used to make packaging.
• Customs House Agents (CHAs) filing Bills of Entry for any of the above, who will field the queries if registration is missing.

Operational Detail

Registration is done on the CPCB Common EPR Portal for Plastic Packaging. Applicants typically need their company and IEC details, GST registration, factory/premises information and category of plastic handled. Processing generally takes on the order of a couple of weeks from a complete, discrepancy-free submission, so this is not something to leave to the day the vessel berths.

Practically, the proof of registration should be available to present with the import documents, and the registration should be live (not lapsed) for the goods in question. Because the raw-material definition is wide, importers of polymer inputs should not assume they are outside the net simply because they do not sell a shelf-ready packaged product.

What Importers and CHAs Should Do Now

• Confirm whether you are obligated. If you import plastic packaging, packaged goods, or plastic resin/pellets/films/preforms, assume you are in scope until you have checked the rules for your category.
• Register on the CPCB Common EPR Portal now if you have not already, and keep the registration certificate where your clearance team and CHA can reach it.
• Check the status of any existing registration — that it is current, covers the correct category, and matches the IEC and GSTIN on your import documents.
• Brief your CHA to carry EPR registration proof in the clearance file for affected HS lines, so a query does not stall the container.
• Diarise annual EPR return filing and target compliance to avoid a registration falling out of good standing.
• Map your plastic inputs against the packaging definition so procurement and imports teams know which purchase orders trigger the requirement.

The Bigger Picture

This is part of a steady tightening of environmental and quality compliance at the Indian border — EPR for plastics and e-waste, BIS quality-control orders, and product-specific registrations are increasingly checked at clearance rather than after the fact. For importers, the lesson is that environmental registrations now carry the same shipment-stopping weight as classic customs paperwork. Building EPR into standard import readiness — alongside IEC, GST and BIS checks — is the cheapest way to keep cargo moving.

Frequently Asked Questions

Does this apply only to finished plastic packaging? No. The obligation has been read to include importers of plastic raw material such as resin or pellets and intermediates like films or preforms, not just finished packaging or packaged goods.

Will Customs actually hold my goods? The instruction directs verification of EPR registration before clearance of the relevant consignments. Where registration cannot be shown, expect a query or hold until compliance is evidenced. Treat it as a clearance-blocking requirement.

How long does EPR registration take? As a rule of thumb, roughly a couple of weeks from a complete submission on the CPCB portal, assuming no discrepancies. Apply well ahead of shipments.

Is this a new obligation or new enforcement? The EPR obligation already existed under the Plastic Waste Management Rules. What has tightened is the border-level verification of it at Customs.

Conclusion

The compliance itself is not new, but the place it now bites — the clearance line — is. Importers of plastic packaging and plastic raw materials should treat EPR registration as core import documentation, register on the CPCB portal if they have not, and make sure the proof travels with every affected Bill of Entry.

This article is a plain-language summary for traders and does not replace professional advice. Verify the current requirements against CBIC Instruction No. 15/2026-Customs and the CPCB Centralised EPR Portal for Plastic Packaging before acting.