India’s EPR Failure: How “Polluter Pays” Became a Certificate Market Instead of a Circular Economy
- harshas2883
- 2 hours ago
- 7 min read
India has built one of the world’s most ambitious Extended Producer Responsibility systems. But fake certificates, underpriced recycling, weak collection systems and poor traceability raise a troubling question: are producers actually taking responsibility—or simply purchasing compliance?
India does not lack environmental regulation.
Over the past decade, the country has expanded Extended Producer Responsibility (EPR) across plastic packaging, electronic waste, batteries and waste tyres. Producers, importers and brand owners are increasingly expected to manage the waste created by the products they place on the market.
The principle is simple:
If a company profits from putting a product into the economy, it should also pay for managing that product when it becomes waste.
This is the globally recognised “polluter pays” principle.
Yet India’s EPR system is exposing a fundamental weakness:
A company can demonstrate compliance without proving that the waste associated with its products was actually collected and recycled.
The result is a growing gap between EPR on a digital portal and waste on the ground.
In August 2026, the Centre for Science and Environment (CSE) estimated that Indian cities generate about 158,619 tonnes of municipal solid waste every day, with plastic accounting for roughly 10–12%, or nearly 19,000 tonnes daily.
That amounts to nearly 6.9 million tonnes of plastic waste a year if the daily estimate is annualised.
India therefore faces two parallel realities:
On the computer screen: registrations, targets, certificates and compliance.
On the street: plastic leakage, informal collection, municipal expenditure, landfills and difficult-to-recycle packaging.
The question is whether these two realities are actually connected.
1. EPR Was Supposed to Change Who Pays
Traditionally, a manufacturer produces a product, a brand sells it and a consumer buys it. But after the packaging is discarded, municipalities and taxpayers often pay to collect and manage it.
EPR was meant to reverse this arrangement.
The producer would finance the post-consumer lifecycle:
Producer → Consumer → Collection → Recycling → Secondary Raw Material → Manufacturing
The financial loop should mirror the physical one:
Producer pays → collection → sorting → transport → recycling → recovery
If this works, EPR can encourage companies to:
use fewer materials;
design recyclable packaging;
increase recycled content;
introduce reusable products;
finance reverse logistics;
invest in collection infrastructure.
But India’s implementation has increasingly focused on the certificate at the end of the process, without adequately financing the collection and sorting required before recycling can occur.
2. India’s Waste Numbers Explain Why the Problem Matters
CPCB’s 2022–23 annual report recorded approximately 3.90 million tonnes per annum of plastic waste generation for 2021–22.
Against this, reported plastic recycling capacity was approximately 0.94 million tonnes per annum, while co-processing capacity was about 0.24 million tonnes.
Graph 1: India’s Plastic Waste Challenge — Reported Waste vs Recycling Infrastructure
Plastic waste generated ████████████████████████████████████████ 3.90 million tonnes
Recycling capacity ██████████ 0.94 million tonnes
Co-processing capacity ███ 0.24 million tonnes
Source: CPCB Annual Report 2022–23. Capacity is not the same as actual recycling.
The problem may be larger than official estimates suggest.
CSE’s analysis of the plastic EPR portal found that producers, importers and brand owners had introduced approximately 23.9 million tonnes of plastic packaging into the Indian market since April 2022, equivalent to roughly 8 million tonnes annually.
This suggests that India’s conventional estimate of approximately 4.1 million tonnes of annual plastic waste may be an underestimate.
We cannot manage what we cannot accurately measure.
3. The 700,000 Fake Certificate Warning
One of the clearest signs of weakness emerged from the plastic recycling certificate market.
A 2024 investigation highlighted by CSE reported that CPCB and State Pollution Control Boards had detected approximately:
700,000 fraudulent EPR certificates
According to CSE, these certificates represented quantities around 38 times the certificate-generation capacity of the recyclers involved.
CPCB reportedly imposed cumulative environmental compensation of approximately:
₹355 crore
on violators.
This raises a basic question:
Did the physical recycling corresponding to those certificates actually occur?
CSE also reported that certain co-processing facilities claimed to have processed 335.4 million tonnes per annum of plastic packaging waste despite registered capacity of only 11.4 million tonnes per annum.
Graph 2: When Reported Processing Exceeds Physical Capacity
Claimed processing capacity ████████████████████████████████████████ 335.4 million tonnes
Registered capacity █ 11.4 million tonnes
The claimed quantity was nearly 29 times the registered capacity.
This is more than an accounting problem. It shows what happens when digital environmental assets become detached from physical material flows.
4. The Cheapest Certificate Can Defeat the Purpose of EPR
Environmental compliance has become a marketplace.
Producers need certificates. Processors generate certificates. Competition pushes certificate prices downward.
But waste management is not a normal commodity market.
Collection costs money.
Segregation costs money.
Transportation costs money.
Worker safety costs money.
Recycling costs money.
If certificate prices are too low, someone else must absorb those costs—or the work does not happen properly.
CSE’s 2024 assessment estimated certificate prices of approximately:
Plastic category | Estimated certificate price |
Rigid plastic | ₹0.50–₹0.75/kg |
Flexible plastic | ₹0.75–₹1.00/kg |
Multi-layered packaging | Around ₹1.25/kg |
Total EPR compliance expenditure was estimated at roughly ₹1–₹2.2 per kg of plastic packaging.
But actual waste-management costs can be much higher.
5. Dharamshala Shows Why the Economics Do Not Work
CSE studied plastic waste-management costs across five Indian cities.
In Dharamshala, managing difficult Category III multi-layered plastic packaging was estimated to cost as much as:
₹9.15 per kilogram
Yet prevailing EPR credit rates were approximately:
₹1–₹1.25 per kilogram
This means the EPR mechanism was recovering only around:
13–14% of the real cost
Graph 3: Dharamshala’s Plastic Management Financing Gap
Actual waste-management cost ████████████████████████████████████████ ₹9.15/kg
EPR credit — upper rate █████ ₹1.25/kg
The remaining ₹7–₹8 per kilogram is frequently absorbed by:
municipalities, waste workers, taxpayers and the environment.
Instead of:
Polluter Pays
the system risks becoming:
Polluter Buys Certificate → Municipality Pays the Difference
CSE found major geographical differences as well. Managing Category III packaging was estimated at approximately ₹2.35–₹3.67/kg in Indore, compared with ₹9.87–₹11.83/kg in Sri Vijaya Puram.
A uniform national certificate price cannot reflect these radically different collection and transport costs.
6. 66% of Registered Packaging Is Exactly the Hard Kind
The waste that is hardest to recycle is not marginal.
CSE reports that roughly:
66% of registered plastic packaging is flexible plastic
Flexible packaging includes wrappers, pouches, sachets and films. These materials are often lightweight, contaminated, geographically dispersed and economically unattractive to collect.
Yet India’s plastic recycling targets are moving toward 50–70% by 2026–27, depending on the packaging category.
The regulatory ambition is rising faster than the economics of collection.
India has created demand for recycling certificates without creating equally strong economics for collecting difficult waste.
7. The People Who Collect the Waste Are Barely Inside the System
India already has one of the world’s largest reverse-logistics networks: the informal waste sector.
Waste pickers, kabadiwalas, scrap dealers, aggregators and material sorters recover large quantities of valuable material before it reaches formal recyclers.
Yet India’s EPR framework does not adequately integrate informal collectors, waste-management agencies, urban local bodies and other actors responsible for collection and segregation.
This creates a serious imbalance:
The person who produces the certificate receives EPR value.
The person who collects the discarded bottle may receive none.
Without collection, there is no recycling.
The financial value of EPR must therefore reach the entire chain:
Waste Picker → Collector → Aggregator → Material Recovery Facility → Recycler
not merely:
Producer → Certificate → Recycler
8. E-Waste Demonstrates Another Problem: Capacity Is Not Collection
India’s E-Waste Management Rules, 2022 came into force on 1 April 2023.
By the government’s 2024–25 annual report, India had:
6,685 registered producers
276 registered recyclers
approximately 1.91 million tonnes per annum of registered recycling capacity
During FY2023–24, recyclers transferred approximately 254,607 tonnes of EPR certificates against producer obligations of approximately 276,771 tonnes.
From a compliance perspective, this may look encouraging.
But registered recycling capacity does not prove that discarded televisions, phones, laptops, refrigerators and appliances are reaching authorised recyclers.
Collection remains the missing bridge.
India must distinguish between:
Recycling Capacity
and
Verified Waste Capture
9. Batteries Could Repeat the Same Mistake
India’s Battery Waste Management Rules, 2022 are increasingly important as electric mobility expands.
For portable and EV batteries, minimum recovery targets rise from:
70% in 2024–25
80% in 2025–26
90% from 2026–27 onward
For automotive and industrial batteries, recovery targets rise from 55% to 60%.
These are ambitious targets. But the certificate market faces familiar problems.
CSE warned in January 2026 that undervalued battery EPR certificates could encourage “paper compliance” rather than investment in advanced recycling infrastructure. It also warned that exporting battery black mass could drain valuable materials from India’s domestic circular economy.
Certificate trading must not become a substitute for physical resource recovery.
10. India’s EPR Has a Design Problem, Not Just an Enforcement Problem
Even if every certificate were genuine tomorrow, India’s EPR system would still be incomplete.
EPR is supposed to influence product design.
A recyclable bottle and an impossible-to-recycle multilayer sachet should not create similar financial obligations for producers.
A repairable electronic device should not carry the same end-of-life economics as a sealed device designed for replacement.
The cost to producers should increasingly reflect:
EPR Liability = Quantity × Collection Difficulty × Recycling Difficulty × Environmental Impact
The harder a product is to collect, repair or recycle, the more its producer should pay.
The Real Failure of EPR
India’s failure is not that it lacks EPR regulation.
It has created portals, registered companies, established recycling targets, created certificate markets and imposed penalties.
The failure is more fundamental:
The economic signal has not consistently reached the physical waste.
When a ₹1 certificate is expected to solve a ₹9 waste-management problem, something is wrong.
When 700,000 fake certificates enter an environmental market, something is wrong.
When processing claims vastly exceed registered capacity, something is wrong.
When the people collecting waste remain outside EPR financing, something is wrong.
And when municipalities continue funding the consequences of products designed, packaged and sold by private businesses, the polluter is still not fully paying.
EPR should not be judged by registrations, certificates or recycling capacity alone.
It should be judged by four questions:
How much waste was generated?
How much was physically collected?
How much material was genuinely recovered?
How much did producers redesign to prevent waste?
Until India can answer those questions product by product and producer by producer, its EPR system risks becoming an extraordinary contradiction:
A system designed to make the polluter pay—while society continues paying for the pollution.
Key Numbers to Remember
Indicator | Figure |
Municipal solid waste generated in India | 158,619 tonnes/day |
Estimated plastic share | 10–12% |
Estimated plastic in MSW | ~19,000 tonnes/day |
Plastic packaging introduced through EPR portal since April 2022 | 23.9 million tonnes |
Fake plastic EPR certificates detected | ~700,000 |
CPCB environmental compensation reported against violators | ₹355 crore |
Flexible plastic share of registered packaging | ~66% |
Dharamshala Category III management cost | Up to ₹9.15/kg |
Prevailing EPR credit rate for the same category | ~₹1–₹1.25/kg |
Cost recovery in Dharamshala example | ~13–14% |
Registered e-waste recycler capacity | ~1.91 million tonnes/year |
Registered e-waste producers | 6,685 |
EV/portable battery recovery target from 2026–27 | 90% |
Sources
Central Pollution Control Board (CPCB) — Annual Report 2022–23; Battery Waste Management Rules and EPR framework.
Ministry of Environment, Forest and Climate Change (MoEFCC) — Annual Reports 2023–24 and 2024–25; E-Waste Management Rules, 2022.
Centre for Science and Environment (CSE) — Unpacking EPR for Plastic Packaging in India; Is the Polluter Really Paying?; Policy, Practice and Plastic: Cost of Managing Plastic Waste in Indian Cities; EV Battery Recycling and EPR assessments.
Down To Earth — Reporting on plastic EPR registrations, fraudulent certificates and processing-capacity discrepancies.
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