Every bottle cap, pouch, tray and shrink wrap that a beauty or Ayurveda brand sells counts. Under India’s Plastic Waste Management (PWM) Rules, 2016, as amended, brand owners are responsible for the plastic packaging they put on the market, through a system called extended producer responsibility (EPR). The rules have been updated several times since 2022. This guide explains, in plain English, what EPR means for cosmetic and Ayurveda brands, and how moving to plastic-free packaging makes compliance simpler.
This article is a general overview, not legal advice. Rules and portal procedures change, so please confirm your obligations with the Central Pollution Control Board (CPCB), your State Pollution Control Board or a compliance consultant.
Key takeaways
- EPR makes producers, importers and brand owners (PIBOs) responsible for collecting and processing the plastic packaging they introduce in the market.
- Brand owners operating in more than two states or union territories register on CPCB’s centralised EPR portal; others register with their State Pollution Control Board.
- Obligations cover recycling, reuse of rigid plastic packaging, use of recycled content and annual returns, with targets rising each year.
- Paper, glass, metal and mycelium are not plastic packaging, so switching inserts and wraps to them reduces your plastic footprint and what you report.
What is EPR?
Extended producer responsibility is a “polluter pays” principle. If your brand puts plastic packaging into the market, you are responsible for making sure an equivalent quantity is collected and processed through recycling, reuse or approved end-of-life routes. In practice, brands fulfil this by buying EPR certificates from registered plastic waste processors on the CPCB portal and filing annual returns.
The Guidelines on Extended Producer Responsibility for Plastic Packaging were notified on 16 February 2022, as Schedule II of the PWM Rules. They have since been amended, including in 2024 and 2025.
Does EPR apply to my cosmetic or Ayurveda brand?
The obligated entities include:
- Producers of plastic packaging.
- Importers of plastic packaging or of products in plastic packaging.
- Brand owners, including online platforms, marketplaces and retail chains.
- Plastic waste processors, manufacturers of plastic raw material, and makers of compostable or biodegradable plastic items.
Micro and small enterprises (as defined under the MSME Act) that are brand owners are exempted from EPR obligations under the guidelines, but it is worth checking your status carefully as you grow. Contract manufacturing arrangements were brought clearly within scope by the 2024 amendment, so the obligations do not disappear when a third party fills your products.
Where to register
- Brand owners operating in more than two states or UTs register on the CPCB centralised EPR portal for plastic packaging.
- Brand owners operating in one or two states or UTs register with the concerned State Pollution Control Board or Pollution Control Committee, through the same centralised portal.
Most D2C beauty brands sell across India online, so CPCB registration is usually the relevant route.
The four plastic packaging categories
| Category | What it covers | Cosmetic and Ayurveda examples |
|---|---|---|
| I: Rigid plastic | Rigid plastic packaging | PET bottles, PP jars, caps, tubs, plastic trays |
| II: Flexible plastic | Single or multilayer flexible plastic of one or more plastic types, sheets, covers, carry bags, sachets, pouches | Shrink wrap, refill pouches, sample sachets, poly mailers |
| III: Multilayered plastic | At least one plastic layer and at least one non-plastic layer | Laminated tubes, metallised sachets, laminated cartons |
| IV: Compostable plastic | Compostable plastic sheets, carry bags and commodities | Certified compostable films or pouches |
The 2024 amendment also added biodegradable plastics to the framework, with their own certification and EPR requirements.
Targets: recycling, reuse and recycled content
The EPR target is calculated from the plastic packaging you introduced in the market, category by category. On top of that:
- Minimum recycling of the EPR target rises each year. For 2025–26 it is 60% for Categories I and IV and 40% for Categories II and III, rising to 80% and 60% respectively from 2027–28.
- Reuse targets apply to brand owners for rigid plastic packaging, starting in 2025–26, with separate targets for packs of 0.9–4.9 litres or kilograms and for larger packs.
- Recycled content in plastic packaging is mandated from 2025–26 for rigid, flexible and multilayer categories, and the share rises over the following years.
Shortfalls can attract environmental compensation under the polluter pays principle.
Labelling and QR codes
Plastic packaging must carry the brand owner’s name and EPR registration certificate number, along with other details depending on the category, such as thickness for some single-layer flexible packaging. Since 1 July 2025, brand owners can provide this information through a barcode or QR code printed on the plastic packaging, a product information brochure, or a unique number issued under law, after informing CPCB. The 2025 amendment also states that contraventions are liable to penalties under the Environment (Protection) Act.
How plastic-free packaging simplifies EPR
EPR applies to plastic packaging. Materials that are not plastic, such as paper and board, glass, metal and plant-based mycelium, are not part of these plastic packaging categories. Every plastic component you replace reduces the plastic tonnage you introduce, report and offset.
For beauty and Ayurveda brands, the easiest swaps are usually:
- Inserts and trays: PET, PVC or foam trays (Category I) to moulded mycelium or moulded pulp.
- Wraps: shrink film (Category II) to paper sleeves, belly bands or cotton ribbon.
- Mailers and void fill: poly mailers and air pillows (Category II) to corrugated boxes and paper or mycelium fill.
- Cartons: laminated cartons (potentially Category III) to paperboard with water-based coatings.
Primary containers such as bottles and jars take longer to change, because they involve product stability testing. Many brands move them to glass or aluminium in a second phase.
A simple EPR action plan for beauty brands
- Map your packaging. List every component of every SKU, its material and its weight.
- Classify the plastic. Assign each plastic component to Category I, II, III or IV.
- Register and file. Register on the CPCB portal if required, and keep annual returns on schedule.
- Reduce first. Replace easy components with paper, glass, metal or mycelium, and track the tonnage you remove each year.
- Update labels. Add the required EPR details or a QR code to any remaining plastic packaging.
- Tell the story. Customers notice when a brand takes plastic out of the box.
EPR for Ayurvedic products: special notes
Ayurvedic brands often use glass bottles for oils and metal or glass for ghee and churnas, which are already outside the plastic categories. The plastic usually hides in caps, inner liners, pouches, shrink wrap and the trays used in gift boxes. These are exactly the parts where plant-based alternatives are ready today.
How Dharaksha helps
Dharaksha Ecosolutions is India’s largest mycelium packaging manufacturer, based in Faridabad. We replace foam and plastic trays with custom-moulded mycelium inserts and supply paper-based cartons, rigid boxes and corrugated shippers, so the secondary pack can be completely plastic-free. See our mycelium inserts for luxury and beauty and the full packaging range.
Frequently asked questions
Brand owners that put plastic packaging on the market are obligated under the Plastic Waste Management Rules. Those operating in more than two states or UTs register on CPCB’s centralised EPR portal; micro and small enterprises that are brand owners are exempted from EPR obligations under the guidelines.
Category I is rigid plastic, Category II is flexible plastic, Category III is multilayered plastic (with at least one non-plastic layer), and Category IV is compostable plastic. Biodegradable plastics were added to the framework in 2024.
No. EPR under the Plastic Waste Management Rules covers plastic packaging. Paper, glass, metal and mycelium are not plastic, so replacing plastic components with them reduces your plastic EPR quantities.
Yes. Since 1 July 2025, brand owners can provide the required information through a barcode or QR code on the plastic packaging, a product brochure or a unique number issued under law, after informing CPCB.
Register on the CPCB centralised EPR portal for plastic packaging if you operate in more than two states or UTs, or with your State Pollution Control Board otherwise, then file annual returns and meet your targets through EPR certificates.
Related reading
Work with Dharaksha
Want less plastic to report next year? Start with the insert.
Send us your SKUs and we will suggest plastic-free inserts and boxes, drop-test the pack and send a free sample. Call or WhatsApp +91 92173 09172, or write to us through the contact page.
Featured photo: Cup of Couple / Pexels.
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