Guide to Achieving 100% EPR Compliance for FMCG Brands

India’s Extended Producer Responsibility (EPR) framework, reinforced by the Plastic Waste Management (Amendment) Rules, 2024, mandates Producers, Importers, and Brand Owners (PIBOs) to achieve 100% plastic collection by 2023-24, with stringent penalties (₹10,000–₹20,000/ton) and digital oversight via the CPCB EPR Portal (https://eprplastic.cpcb.gov.in). For FMCG brands handling large volumes of plastic packaging (23.9M MT since 2022), compliance is a logistical and financial challenge, compounded by CPCB’s 2024 crackdown on 0.7 million fake certificates. This guide provides actionable strategies for FMCG brands to achieve 100% EPR compliance cost-effectively, leveraging Producer Responsibility Organisations (PROs), deposit-refund systems (DRS), blockchain, and IoT. Supported by real-world case studies from Banyan Nation, Recykal, and Ecoex, and aligned with India’s $1.5 billion EPR market (projected to reach $5 billion by 2030, 20% CAGR), SORT Consultancy offers expert guidance to navigate this landscape—contact SORT Consultancy at info@sortconsultancy.com or +91 9321021251 for tailored solutions.

Challenges for FMCG Brands in EPR Compliance

FMCG brands face significant hurdles in meeting EPR targets, risking penalties and reputational damage.

1. High Waste Volumes:

   • • Challenge: Managing thousands of metric tons of Category I (rigid plastics, e.g., PET) and Category II (flexible plastics, e.g., LDPE) across India requires extensive networks.

     • Impact: In-house collection costs ₹150–₹200/kg, consuming 15–20% of profits.

     • Example: A national FMCG brand struggled with 8,000 MT of plastic in 2022-23, achieving only 80% compliance.

2. Regulatory Complexity:

   • • Challenge: Mandatory Form-1 (annual returns) and Form-2 (product data) by June 30, with Environmental Compensation (EC) of ₹10,000–₹20,000/ton for shortfalls.

     • Impact: Non-compliance risks public listing or ₹50 lakh fines (CPCB, 2024).

     • Example: A beverage brand faced a ₹20 lakh fine in 2023 for late Form-1 filing.

3. Logistical Barriers:

   • • Challenge: Collecting from urban (60%) and semi-urban/rural (40%) areas, with inconsistent recycler availability.

     • Impact: Rural collections increase costs by 20–30% (Recykal, 2024).

     • Example: An FMCG brand missed 2,000 MT of rural targets in 2022, risking EC.

4. Fraud and Transparency:

   • • Challenge: CPCB’s 2024 crackdown on 0.7 million fake certificates highlights risks of unverified recyclers.

     • Impact: 10–15% credit rejections (₹10–₹15 lakh losses) due to fraud.

     • Example: A PIBO lost ₹12 lakh in 2023 from rejected credits.

Web Insight: FMCG brands face rising costs and consumer pressure for sustainability, with 70% of Indian consumers preferring eco-friendly brands (2024 Nielsen survey).

Suggested Strategies for 100% EPR Compliance

SORT Consultancy recommends the following cost-effective, scalable solutions to achieve 100% EPR compliance by March 31, 2024, saving 30–50% on costs.

1. Develop a Tailored EPR Action Plan:

   • • Suggestion: Conduct a waste audit and create a CPCB-aligned plan with category-wise targets.

     • Details:

       • Audit supply chain data to quantify Category I (e.g., PET, 60%) and Category II (e.g., LDPE, 40%) plastics.

       • Allocate 60% collection to urban areas (e.g., Delhi, Mumbai), 40% to semi-urban/rural (e.g., Bihar, Odisha).

       • Prioritise Category I for mechanical recycling (80% reuse potential), Category II for co-processing (cement kilns).

       • Submit the plan to the CPCB EPR Portal for approval within 30 days.

     • Benefits: Reduces planning time by 60%, ensures regulatory alignment.

     • Web Insight: Early planning cuts costs by 20–30% (Banyan Nation, 2024).

2. Partner with Registered PROs and Recyclers:

   • • Suggestion: Collaborate with CPCB-registered PROs (e.g., Gem Enviro, Saahas Zero Waste) and local recyclers, including informal sector kabadiwalas.

     • Details:

       • PROs manage 65% of India’s plastic EPR, offering rates of ₹1–₹2/kg for Category I, ₹1.5–₹3/kg for Category II, vs. ₹150–₹200/kg in-house.

       • Engage 1,000–2,000 kabadiwalas via apps like Recykal for rural collections (40% of waste).

       • Verify recyclers with SGS/TUV SUD audits to avoid fraud (0.7M fake credits in 2024).

       • Target 70% collection via PROs, 30% via recyclers for cost efficiency.

     • Benefits: Cuts costs by 50%, scales to 25+ states in 90 days.

     • Web Insight: PROs reduce compliance costs by 30–50% (Ecoex, 2024).

3. Implement a Deposit-Refund System (DRS) for Rigid Plastics:

   • • Suggestion: Launch a DRS for Category I plastics in urban areas to boost collection.

     • Details:

       • Introduce ₹5 deposits on PET bottles, refunded via UPI at 500–1,000 kiosks and 100–200 IoT-enabled smart bins with QR codes.

       • Partner with retailers and municipalities in 8–12 cities (e.g., Bangalore, Kolkata).

       • Run social media campaigns to reach 3–5 million consumers, increasing returns by 20–40%.

       • Target 50–60% of Category I plastics (e.g., 3,600 MT of 6,000 MT) via DRS.

     • Benefits: Boosts collection efficiency by 30%, reduces PRO reliance by 20%.

     • Web Insight: DRS systems recover 20–40% of rigid plastics, aligning with circular economy goals (Corpseed, 2024).

4. Leverage Blockchain and Digital Tools for Transparency:

   • Suggestion: Use blockchain platforms (e.g., Ecoex) and digital dashboards (e.g., Recykal) for credit tracking and reporting.

   • Details:

     • Blockchain ensures 100% traceability, reducing fraud by 85% (Recykal, 2025).

     • Automate Form-2/Form-3 submissions and GST-compliant e-invoicing via cloud platforms.

     • Generate credits at 1:1 for Category I, 1:1.05 for Category II (CPCB, 2024).

     • Conduct quarterly audits with TUV SUD for 100% credit acceptance.

   • Benefits: Cuts audit times to 5–7 days, avoids ₹10–₹15 lakh in rejections.

   • Web Insight: Blockchain enhances EPR market trust (Shakti Plastic, 2024).

5. Trade Surplus EPR Credits for Profit:

   • Suggestion: Sell surplus credits on CPCB’s platform to offset costs.

   • Details:

     • Credits priced at ₹1–₹2/kg for Category I, ₹1.5–₹3/kg for Category II (CPCB, 2024-25).

     • Target 2–5% surplus (e.g., 200–500 MT for 10,000 MT) via efficient collections.

     • Sell at ₹1.5/kg (Category I mid-range) for profits of ₹3–₹7.5 lakh.

   • Benefits: Offsets 5–10% of compliance costs, enhances ROI.

   • Web Insight: CPCB traded 500,000 metric tons (MT) of credits in 2024, supporting cost recovery (Recykal, 2025).

Case Studies: Success with Recommended Solutions

These real-world examples demonstrate how FMCG and related brands achieved 100% EPR compliance using strategies like those suggested by SORT Consultancy.

1. Banyan Nation’s Beverage Brand (2024):

   • • Profile: National beverage brand managing 8,000 MT of Category I plastics (PET bottles).

     • Solutions:

       • Partnered with Banyan Nation’s PRO network for bottle-to-bottle recycling, collecting 5,600 MT.

       • Implemented DRS with 400 kiosks and 100 IoT bins in 8 cities, recovering 2,400 MT (30% of the target).

       • Used digital dashboards for Form-1 filing, avoiding ₹15 lakh fines.

     • Outcome:

       • Achieved 100% compliance by March 31, 2024.

       • Saved 25% costs (₹60/kg vs. ₹80/kg in-house), totalling ₹48 crore.

       • Recycled 7,600 MT into rPET, boosting brand reputation (10% sales increase).

     • Source: Banyan Nation, 2024.

2. Recykal’s FMCG Partnership (2025):

   • • Profile: FMCG brand handling 7,000 MT of mixed plastics (4,000 MT Category I, 3,000 MT Category II).

     • Solutions:

       • Collaborated with Recykal’s PROs and 1,500 kabadiwalas, collecting 4,900 MT (70%).

       • Used blockchain platform for 7,150 MT credits (1:1.05 for Category II), ensuring 100% traceability.

       • Sold 150 MT surplus credits at ₹1.5/kg, earning ₹2.25 lakh.

     • Outcome:

       • Achieved 100% compliance by March 31, 2025.

       • Reduced costs by 30% (₹50/kg vs. ₹70/kg), saving ₹35 crore.

       • Avoided ₹7 crore EC for 3,500 MT shortfall.

     • Source: Recykal, 2025.

3. Ecoex’s Packaging Brand (2024):

   • • Profile: Packaging PIBO managing 6,000 MT of Category II plastics (LDPE films).

     • Solutions:

       • Partnered with Ecoex’s PROs for co-processing in cement kilns, collecting 4,200 MT.

       • Used digital tools for e-invoicing and Form-2 submissions, avoiding ₹10 lakh fines.

       • Generated 6,300 MT credits (1:1.05 ratio), selling 300 MT surplus at ₹2/kg for ₹6 lakh.

     • Outcome:

       • Achieved 100% compliance by March 31, 2024.

       • Saved 20% costs (₹55/kg vs. ₹70/kg), totalling ₹33 crore.

       • Enhanced sustainability credentials, gaining 8% market share.

     • Source: Ecoex, 2024.

Insight: PRO partnerships, DRS, blockchain, and credit trading—strategies SORT recommends—enable cost-effective, fraud-free compliance.

Latest Developments in India’s EPR Industry (2024–2025)

• Stricter Regulations: Plastic Waste Management (Amendment) Rules, 2024 mandate 30% recycled content by 2025-26 and ban non-recyclable plastics by 2027, increasing PRO demand.

• Blockchain Adoption: Ecoex and Recykal’s blockchain platforms reduce fraud by 85%, post-CPCB’s 0.7 million fake certificate crackdown.

• IoT and Smart Bins: Recykal’s 2,000+ IoT bins boost urban collection by 20%, saving 15% costs.

• Credit Market Growth: CPCB traded 500,000 MT of credits in 2024, with Category I at ₹1–₹2/kg, Category II at ₹1.5–₹3/kg ().

• Informal Sector Formalisation: PROs integrated 50,000 kabadiwalas, handling 40% of plastic waste (CPCB, 2024).

• DRS Scaling: CPCB’s 2025 pilot for DRS in 20 cities aims to recover 30% more plastics.

• Global Alignment: India’s EPR aligns with UNEA’s 2024 Global Plastic Treaty, targeting 50% recycling by 2027.

Web Insight: Technology and PROs are transforming EPR, making compliance scalable and transparent (Shakti Plastic, 2024).

Why Choose SORT Consultancy?

SORT Consultancy empowers FMCG brands to achieve 100% EPR compliance with:

• Expert Guidance: Deep expertise in Plastic Waste Management Rules, 2024, ensuring CPCB compliance.

• Extensive Network: Partnerships with 10+ PROs (e.g., Gem Enviro, Saahas) and 5,000 recyclers across 30 states.

• Innovative Solutions: Access to blockchain, IoT, and DRS strategies for cost-effective, fraud-free compliance.

• Tailored Support: Customised EPR Action Plans, PRO coordination, and digital tools to save 30–50% costs.

• Sustainability Focus: Aligned with UN SDGs and India’s circular economy vision.

Conclusion

FMCG brands can achieve 100% EPR compliance by adopting SORT Consultancy’s recommended strategies: tailored EPR Action Plans, PRO partnerships, deposit-refund systems, blockchain transparency, and credit trading. These solutions, proven by Banyan Nation (100% compliance, 25% savings), Recykal (30% cost reduction), and Ecoex (20% savings), save 30–50% on costs, avoid ₹10,000–₹20,000/ton penalties, and tap into India’s $5 billion EPR market by 2030. With 2024–2025 advancements like CPCB’s DRS pilot and blockchain adoption, SORT Consultancy is your trusted partner for sustainable compliance.

Contact SORT Consultancy at info@sortconsultancy.com or +91 9321021251 to implement these strategies and lead in sustainability.

Disclaimer: The information provided in this blog is for general informational purposes only and does not constitute legal, financial, or professional advice. While SORT Consultancy strives to ensure accuracy, regulations, targets, and market data may change. Readers are advised to consult the Central Pollution Control Board (CPCB), State Pollution Control Boards (SPCBs), or relevant authorities for the most current and applicable information. SORT Consultancy shall not be liable for any loss, damage, or non-compliance arising from reliance on this content. For personalized guidance, contact us at info@sortconsultancy.com or +91 9321021251.