- Government reports 19.7 mnt recycled since 2022
- Self-reported data complicates EPR accountability
India’s Extended Producer Responsibility (EPR) system has reported recycling 19.697 million tonnes (mnt) of plastic waste since the regime came into force in 2022, according to government data as of 5 March 2026. The same data shows 19.697 mnt of EPR certificates generated by 2,986 registered plastic recyclers. Yet continued plastic waste in cities, drains and waterways raises questions over how reported recycling volumes reconcile with actual collection and processing.
The issue becomes more important as India moves towards wider EPR certificate trading. The credibility of the system will depend on whether producer obligations, processor activity and certificate generation can be linked to verifiable physical recycling.
EPR system creates formal recycling obligations
Under EPR, producers, importers and brand owners (PIBOs) are responsible for collecting and recycling plastic packaging. PIBOs have been required to collect 100% of their plastic packaging since 2023-24, while recycling targets for 2026-27 range from 50% to 70% depending on the category.
For Category II plastic, which includes flexible and multilayer packaging, the collection target is 100% and the recycling target is 50%.
PIBOs meet these obligations through registered plastic waste processors (PWPs). Each tonne of eligible plastic recycled generates one EPR certificate, linking producer obligations with recycling activity.
Reported volumes need reconciliation
The government reports 19.697 mnt of plastic recycled and an equal volume of EPR certificates generated since 2022. However, official data does not publicly establish certificates retired or utilised, or provide a category-wise recycling breakdown.
An analysis cited in the original source found 41,544 PIBOs registered in 2024, with targets based on self-reported data, while the validation mechanism remains unclear.
Processor verification remains critical
CPCB’s framework requires reporting on waste generation, collection, segregation, PWP capacity, processing and audits. Previous audits identified irregularities and prompted state-level action.
The original source also cites a June 2026 CPCB direction on non-compliant PWPs, although detailed findings are not publicly available. Processors must provide GST invoices for recycled-product sales, while the source notes that 18% GST and informal-sector consumption can complicate formal transactions.
Recycling economics create an incentive gap
The economics of compliance add another concern.
For Category II plastic, the prescribed processing rate is INR 1,500/t, while the source estimates actual recycling costs at INR 4,000-6,000/t. CPCB’s estimated recycling cost is INR 4,000/t, while non-compliance attracts environmental compensation at 2.5 times the compliance cost.
If physical recycling costs substantially exceed the prescribed rate, the economics could weaken incentives for actual recovery, making robust certificate verification more important.
Transparency is the next test
India’s EPR framework has formalised recycling responsibility and created a market for compliance. However, certificate generation alone does not establish how much plastic has been physically recovered and recycled.
As certificate trading expands, greater disclosure of PIBO obligations, PWP capacity, certificates generated and retired, audit findings and physical recycling volumes could improve confidence in the system.
The key measure of EPR effectiveness is therefore not simply how many certificates are generated, but how reliably they correspond to verifiable physical recycling.
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