The Recycling Documentation Gaps That Are Putting Packaging Companies at Compliance Risk

EPR compliance for plastic waste looks straightforward on paper: register on the CPCB portal, declare the plastic you introduce into the market, procure EPR certificates from registered recyclers to meet your targets, and file your annual return. In practice, the documentation behind each of those steps — especially the recycling certificate procurement — is where compliance risk accumulates quietly.

Who Is Actually Obligated

Under the Plastic Waste Management Rules, 2022, a packaging company that manufactures plastic packaging and sells it to brand owners is a Producer. The brand owner who puts goods into that packaging is a Brand Owner. Both have EPR Registration for Plastic Waste obligations — but for different quantities and under different categories. Where companies get into trouble is assuming one entity's registration covers the other's obligation. It doesn't. Get this wrong from the start and every subsequent filing is building on a flawed foundation.

The Certificate Procurement Paper Trail

Procuring EPR certificates from CPCB-registered recyclers isn't just a financial transaction — it generates a digital trail on the CPCB portal that auditors review. Each certificate has a certificate number, the recycler's registration details, the category of plastic covered, the quantity in metric tonnes, and the financial year it applies to.

Certificates from delisted recyclers. CPCB periodically delists recyclers for non-compliance. Certificates purchased from a recycler who was subsequently delisted may not count toward your target. CPCB's portal maintains a current registered recyclers list — verify your recycler's status at the time of purchase, not just during initial identification.

Category mismatch between plastic used and certificates procured. Since January 2026, EPR obligations must be fulfilled using certificates from the same recycling category only — Categories I, II, and III are no longer interchangeable, and EOL disposal certificates can no longer offset recycling targets. A packaging company that used Category II plastic but procured Category I certificates is now non-compliant under the updated rules, regardless of the certificate quantities.

Incomplete quantity documentation for the annual return. The annual return requires declaration of plastic quantities introduced by category and sub-category, matched against certificates procured. Incomplete records of production volumes, sales quantities, or export adjustments create inconsistencies that CPCB flags automatically.

The Traceability Requirement

From January 2025, all plastic packaging must carry traceable QR codes, barcodes, or unique identifiers — enabling regulators to trace packaging back to the producer. For packaging companies producing for multiple brand clients, each batch needs the relevant traceability information. This is both a production process requirement and a documentation requirement — and the records behind those QR codes are what CPCB auditors review during field inspections.

Recycled Content Mandates

Rigid plastic packaging must contain 40% recycled content for FY 2026–27, with reuse targets for rigid containers also now specified. Packaging companies that cannot demonstrate recycled content compliance through supplier documentation and material specifications face a category of non-compliance separate from their EPR target obligations. This requires supplier-level documentation — not just internal claims.

What to Document and How

Build a compliance record that covers: monthly production volumes by plastic category, sales records showing plastic quantities introduced per client, EPR Registration for Plastic Waste numbers with recycler details and CPCB registration confirmation, QR/barcode batch records for each packaging production run, and recycled content supplier certificates for rigid plastic. Maintain these records continuously — they cannot be reconstructed at annual return time without gaps.

How ASC Group Can Help

ASC Group provides EPR compliance management specifically for producers and packaging companies handling plastic waste obligations. We review your existing certificate procurement against the January 2026 category rules, identify recycler registration status for your current supplier network, build your documentation framework for traceability and recycled content compliance, and manage your annual return filing with CPCB EPR Registration for Plastic Waste. For companies that have received notices or discovered documentation gaps mid-year, we conduct a compliance gap assessment and implement corrective measures. Contact ASC Group to close your recycling documentation gaps before CPCB does it for you.