12 May 2026
A working operator's guide to calculating plastic EPR obligation under PWM Rules 2022 — categories, weights, recycling targets, certificate cost, and the common mistakes that show up in audits.
What CPCB actually does when you miss an EPR target or file a return late — Environmental Compensation math, real penalty cases, and the cumulative cost of doing nothing.
How to buy genuine EPR certificates from CPCB-registered recyclers in India — typical 2026 pricing, the certificate-fraud problem, and a verification checklist that keeps you out of audit trouble.
The exact registration flow on the CPCB EPR portal for plastic packaging, e-waste, and batteries — documents required, common rejection reasons, and how long each step actually takes.
The Plastic Waste Management Rules 2022 (PWM 2022) are the most common EPR exposure a small Indian D2C brand faces. The calculation itself is straightforward arithmetic once you have your weights and the right rule numbers. The hard part is getting the weights right, putting them in the right categories, and not lighting money on fire on unverifiable recycler certificates. This is the walk-through we hand to every founder we onboard.
Three identities, any one of which makes you liable under PWM 2022:
There is no minimum-weight exemption you can realistically operate behind. If you ship physical product, assume you're in scope.
PWM 2022 Schedule II splits plastic packaging into four categories. Get this wrong and your obligation is wrong.
Most D2C brands are dominated by Cat I (bottles, jars) and Cat II (pouches, mailers). FMCG brands shipping anything moisture-sensitive are usually Cat III. Cat IV is rare and almost always a marketing choice rather than a default.
Common mistake. Treating bubble wrap and air pillows as "not packaging." They are Cat II flexible plastic. They count.
Pull 12 months of packaging spend, multiply by per-unit grammage, and aggregate by category. If you have multiple SKUs:
A solo founder shipping 50,000 jar units a year at 30g per jar puts 1,500 kg of Cat I plastic on the market. Add 80,000 poly mailers at 12g each for another 960 kg of Cat II. That brand has 2,460 kg of plastic packaging annually — a small but non-zero EPR footprint.
Common mistake. Counting filled product weight instead of empty packaging weight. You're liable for the packaging, not what's inside.
Each category has a recycling target percentage that ramps year on year per PWM Rules 2022 Schedule II. Targets are FY-specific:
The numbers move. Always pull the target for the FY you're filing, not last year's. Our free calculator handles the FY lookup automatically — pick the year, the target is applied.
For each category:
certificates_required_kg = annual_weight_kg × recycling_target_pct / 100
For the example brand above, if the Cat I target is 70% and Cat II is 70%, that's:
Total certificate requirement: 1,722 kg, of which 1,050 kg must be Cat I and 672 kg must be Cat II. Categories don't fungibly substitute — you cannot buy Cat II certificates to cover a Cat I shortfall.
EPR certificate market prices vary by category, region, and recycler. As a rough working estimate for FY 2025-26:
Using a ₹30/kg working assumption, the example brand's annual certificate spend is ~₹51,660. Add a small buffer for procurement delay and quarterly true-ups; budget ~₹60,000 for the year.
Common mistake. Buying certificates from the cheapest recycler without verifying CPCB registration and remaining authorised capacity. A ₹10/kg certificate that turns out to be invalid costs you the cost of the certificate twice — first when you paid for it, then again when you have to re-procure.
If your filing software (CPCB portal or otherwise) shows your obligation as zero, double-check — it usually means a category got missed in mapping.
Or skip step 1–4 and use our calculator — paste your weights, pick the FY, get a clean obligation number with a category-wise breakdown. Then come back and do step 5.