CPCB Notice on Removal of Difficulties for Implementation of EPR Guidelines

Jan 21, 2026 | by TeamLease RegTech Legal Research Team

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EHS ComplianceThe Central Pollution Control Board (CPCB), on January 19, 2026, issued a notice on the “Removal of Difficulties” to facilitate effective implementation of the Extended Producer Responsibility (EPR) Guidelines for Plastic Packaging, in continuation of its earlier notice dated November 28, 2025 and amendments notified by the Ministry of Environment, Forest and Climate Change (MoEFCC) under the Plastic Waste Management Rules.

The notice reiterates the regulatory framework under Clause 8.2 and Clause 15A of the EPR Guidelines, clarifying that surplus EPR certificates can only be utilised within the same category, with limited cross-utilisation permitted only as specifically provided and valid up to the end of FY 2025–26. It further emphasises that exchange of EPR obligations across Recycling Categories I to III is not permitted, and surplus generated under End-of-Life (EOL) disposal cannot be adjusted against recycling targets.

In view of the above, CPCB has withdrawn its earlier dispensation allowing fulfilment of recycling obligations through EOL certificates with immediate effect, mandated the timely filing of Annual Returns by registered PIBOs on the EPR portal by 31 January 2026, and clarified the treatment of additional EOL certificates for subsequent returns. These provisions shall apply up to the Annual Return filing for FY 2024–25 and are binding on all registered PIBOs for effective implementation of the EPR regime. 

[Notification No. CP-20/80/2021-UPC-II-HO]


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