CBIC Clarifies EPR Registration for Plastic Packaging Imports: One-Time EPR Certificates to Be Accepted for Customs Clearance

“Indirect Tax I Indirect Tax Litigation I Customs & FTP I Central Licensing I Arbitration I Advisory”

Dated: 10.09.2026

CBIC Clarifies EPR Registration for Plastic Packaging Imports: One-Time EPR Certificates to Be Accepted for Customs Clearance

The Central Board of Indirect Taxes and Customs (CBIC) has issued an important clarification concerning Extended Producer Responsibility (EPR) registration for importers of plastic packaging, commodities packed in plastic, plastic raw materials and intermediate materials used for manufacturing plastic packaging.

Through Instruction No. 15/2026-Customs dated 9 September 2026, CBIC has directed Customs formations to accept EPR Registration Certificates issued to importers showing a validity period of one year as “one-time Registration Certificates” that do not require renewal, in accordance with the amendment to the Plastic Waste Management Rules notified on 30 October 2023.

Accordingly, such certificates may be accepted as valid proof of EPR registration for import clearance, and consignments may be cleared after verification of the EPR registration certificate.

The clarification addresses a practical problem faced by importers whose consignments were reportedly encountering Customs clearance difficulties because their EPR certificates displayed a one-year validity period even though, under the amended regulatory framework referred to in the Instruction, the registration is to be treated as a one-time registration.

CBIC Issues Instruction No. 15/2026-Customs

The Instruction has been issued by the Government of India, Ministry of Finance, Department of Revenue, Central Board of Indirect Taxes & Customs, under File No. 401/11/2022-Cus.III.
It is dated 9 September 2026 and has been addressed to Principal Chief Commissioners/Chief Commissioners of Customs, Customs (Preventive), Customs & Central Taxes, Principal Commissioners/Commissioners and Principal Directors General/Directors General under CBIC.

The subject of the Instruction is:

“Registration of Importers under Centralized EPR Portal for Plastic Packaging as per Plastic Waste Management Rules, 2016 (as amended) and verification of registration.”

The Instruction also refers to earlier CBIC Instruction No. 14/2023-Customs dated 17 April 2023, CBIC Instruction No. 21/2025-Customs dated 2 July 2025, and a letter issued by the Tamil Nadu Pollution Control Board (TNPCB) dated 15 August 2026.

Who Is Required to Obtain EPR Registration?

The attached TNPCB communication explains the scope of the EPR framework applicable to importers.

It states that importers dealing commercially in the following categories are covered:

1. Plastic packaging or commodities with plastic packaging, including carry bags, plastic sheets or similar material;

2. Plastic raw material, including resin or pellets; and

3. Intermediate material used for manufacturing plastic packaging, such as films or preforms.

According to the communication, all importers falling within these categories are mandated to register on the Common EPR Portal developed by the Central Pollution Control Board (CPCB) and are not permitted to carry out business activity without obtaining the requisite EPR registration.
This makes EPR registration a significant pre-import and Customs-clearance compliance consideration for businesses dealing with plastic packaging and related materials.

What Is Extended Producer Responsibility for Plastic Packaging?

Extended Producer Responsibility, or EPR, is based on the principle that entities introducing plastic packaging into the market should bear responsibility for its environmentally sound management.
The TNPCB letter annexed to the CBIC Instruction states that the Ministry of Environment, Forest and Climate Change has notified the EPR framework for plastic packaging under the Plastic Waste Management Rules, 2016 and subsequent amendments.
The framework places responsibility upon regulated entities, including Producers, Importers and Brand Owners (PIBOs), for management of plastic packaging waste introduced into the Indian market through mechanisms including recycling, reuse and end-of-life disposal.
For importers, therefore, EPR is not simply an environmental compliance requirement arising after the goods enter the market. It can also have a direct interface with Customs clearance at the point of importation.

The Practical Problem: EPR Certificates Showing One-Year Validity

The immediate reason for CBIC’s latest clarification was a practical difficulty being faced by importers.
According to the TNPCB communication, grievances had been received from various importers who were experiencing difficulty in obtaining Customs clearance because their EPR Registration Certificates were being treated as invalid after the one-year validity period printed on the certificate.

This created an apparent mismatch between:

the validity period appearing on the face of the EPR certificate, and

the legal treatment of the registration following amendment of the Plastic Waste Management Rules.

The issue was consequently brought to CBIC’s attention so that Customs officers could be given uniform instructions.

Major Clarification: One-Year EPR Certificates Are to Be Treated as One-Time Registrations

The most important clarification in Instruction No. 15/2026-Customs is that EPR Registration Certificates issued to importers indicating a validity period of one year are to be considered:

“One-time Registration Certificates” which do not require renewal.

CBIC states that this treatment follows the amendment to the Plastic Waste Management Rules notified on 30 October 2023.
Accordingly, even where the certificate itself displays a one-year validity period, Customs officers have been instructed that such registration certificates may be accepted as valid proof of EPR registration for the purpose of import clearance.
This clarification is likely to remove a significant source of port-level uncertainty for importers.

Customs Directed to Clear Consignments After Verification of EPR Registration

CBIC has specifically requested Customs formations to clear consignments involving import of:

plastic packaging;
any commodity with plastic packaging;
plastic raw material; and
intermediate material for manufacturing plastic packaging,

upon verification of the EPR Registration Certificate.

This is an important operational direction.
It indicates that the relevant Customs check is to focus upon verification of EPR registration, rather than rejecting an otherwise valid registration merely because a one-year period appears on the certificate.

How Is an Importer’s EPR Registration Verified?

The documents clarify that applications submitted by importers through the Common EPR Portal are scrutinised by the CPCB and/or the concerned State Pollution Control Board (SPCB).
EPR Registration Certificates are issued after verification of the correctness of the information furnished by the importer in the application.
The TNPCB communication further records that CPCB had requested instructions to Customs authorities for verification of proof of registration on the Common EPR Portal under the importer category at the time of clearance of consignments.
Thus, the regulatory emphasis is on confirming the existence and correctness of the registration rather than relying exclusively on a printed validity date.

What Changes for Importers After Instruction No. 15/2026-Customs?

The practical position emerging from the CBIC Instruction can be summarised as follows:

Issue	Clarified Position
Import of plastic packaging	EPR registration required
Commodity imported with plastic packaging	Importer falls within the stated EPR registration framework
Plastic raw material/resin/pellets	Covered by the Instruction/TNPCB communication
Intermediate material for plastic packaging	Covered
Registration platform	CPCB Common/Centralized EPR Portal
Certificate shows one-year validity	Should not automatically be rejected as expired
Nature of such registration	To be considered a one-time Registration Certificate
Annual renewal	Not required as per the amendment referred to in the Instruction
Customs verification	EPR Registration Certificate to be verified
Import clearance	Consignment may be cleared after verification

Important Relief for Importers at Customs Ports

The Instruction has substantial practical importance because regulatory ambiguity can lead to:

assessment delays, Customs holds, detention of consignments, container detention charges, demurrage and disruption of manufacturing supply chains.

An importer may have completed EPR registration correctly but still encounter clearance problems if a Customs officer interprets the one-year period printed on an older certificate as meaning that the registration has expired.
Instruction No. 15/2026-Customs seeks to eliminate that inconsistency.
Customs officers across formations have now been asked to follow a uniform approach.

One-Time Registration Does Not Mean Exemption from EPR Obligations

Importers should carefully distinguish between one-time registration and ongoing EPR compliance.
The CBIC Instruction addresses the validity of the registration certificate for Customs-clearance purposes.
It should not be interpreted to mean that an importer is permanently exempt from substantive obligations imposed under the Plastic Waste Management Rules merely because the registration itself does not require annual renewal.
Depending upon the applicable regulatory framework, registered entities may still have continuing obligations relating to plastic packaging waste management, returns, EPR targets, recycling, reuse, certificates, portal filings or other compliance requirements.

Therefore:

One-time registration ≠ one-time EPR compliance.

This distinction is particularly important for compliance teams.

Significance for Importers of Finished Goods Packed in Plastic

Another important aspect of the Instruction is that it is not confined to businesses importing plastic as a standalone commodity.
The wording specifically extends to importers of “any commodity with plastic packaging.”
Accordingly, businesses importing finished goods packed in plastic should not assume that EPR requirements apply only to companies importing plastic resin, packaging material or plastic products.
The nature of the packaging accompanying the imported goods can itself create an EPR compliance requirement.

Plastic Raw Materials and Intermediate Materials Also Covered

The documents also specifically refer to:

plastic raw material, including resin or pellets, and

intermediate material used for manufacturing plastic packaging, such as films or preforms.

This is commercially significant for converters, packaging manufacturers and industrial users importing materials for domestic manufacture of plastic packaging.

Businesses should therefore assess EPR applicability based on their actual import profile rather than only the description of the finished goods they manufacture.

Special Reference to Tamil Nadu’s Single-Use Plastic Restrictions

The TNPCB letter annexed to the CBIC Instruction also contains an important State-specific reminder.
It records that the Government of Tamil Nadu, through G.O. Ms. No. 84 dated 25 June 2018, imposed a ban with effect from 1 January 2019 on the manufacture, storage, transport, supply, sale and use of 14 categories of “use-and-throwaway” plastic items, including plastic carry bags irrespective of thickness.

This demonstrates an important compliance principle:

EPR registration does not override an independent prohibition on a particular plastic product.

A product may satisfy EPR registration requirements and nevertheless remain restricted or prohibited under another applicable environmental regulation or State measure.

Interaction Between Environmental Regulation and Customs Clearance

Instruction No. 15/2026-Customs is a good example of the growing interface between environmental regulation and border compliance.

Historically, Customs clearance primarily focused on matters such as:

classification;
valuation;
rate of duty;
import policy;
exemption notifications; and
licensing restrictions.

Today, importers increasingly need to account for allied regulatory requirements including environmental and waste-management obligations.

EPR registration is therefore becoming an important element of pre-import compliance planning.

Practical Checklist for Importers

Importers dealing with plastic packaging or plastic-packaged goods should consider adopting the following compliance process:

Determine EPR applicability before shipment based on the product, packaging and imported material.
Ensure registration on the CPCB Common EPR Portal under the correct importer category.
Verify that the registration details match the importing entity, including relevant identification particulars.
Keep a copy of the EPR Registration Certificate readily available for Customs clearance.
If an older certificate shows a one-year validity period, retain a copy of CBIC Instruction No. 15/2026-Customs dated 09.09.2026 for reference during clearance.
Verify the registration status on the portal wherever necessary.
Continue complying with substantive EPR obligations independently of the one-time registration clarification.
Check whether any separate product-specific or State-level plastic prohibition applies.

Importance for Customs Brokers

Customs Brokers should also take note of the Instruction because they are often the first point of contact when a consignment is held for allied-law compliance.
Where Customs raises an objection solely because an EPR certificate displays a one-year validity period, the broker or importer can draw attention to Instruction No. 15/2026-Customs and request verification of the registration in accordance with the latest CBIC direction.
This can potentially prevent avoidable delays and escalation.

Earlier CBIC Instructions Continue to Form Part of the Regulatory Background

Instruction No. 15/2026-Customs does not arise in isolation.

It expressly refers to:

CBIC Instruction No. 14/2023-Customs dated 17.04.2023, and
CBIC Instruction No. 21/2025-Customs dated 02.07.2025.

Businesses dealing regularly with plastic-related imports should therefore examine the current instruction together with the earlier CBIC guidance and the underlying Plastic Waste Management Rules to understand the complete compliance framework.

Conclusion

CBIC’s Instruction No. 15/2026-Customs dated 9 September 2026 provides an important and practical clarification for importers operating under India’s plastic-packaging EPR regime.

The most significant takeaway is that an EPR Registration Certificate should not be treated as invalid merely because it displays a one-year validity period. In light of the amendment to the Plastic Waste Management Rules referred to by CBIC, such certificates are to be treated as one-time registrations that do not require renewal, and may be accepted for Customs clearance after verification.

In case you face any issues related to Indirect Tax-Customs, GST, Foreign Trade Policy (FTP), Arbitration matters and Central Licensing and related advisory matters in India then please feel free to get in touch with SJ EXIM Services.

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Source: CBIC, Ministry of Finance, Govt. of India

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