Plastic EPR: Why India's Recycling Numbers Don't Add Up
India's plastic EPR system reports 17 million tonnes recycled since 2022, but a CSE audit of Agra's drains found branded packaging was 70% of the waste. Sunita Narain's case for real verification over self-reported certificates.
India's Extended Producer Responsibility (EPR) system for plastic packaging has recorded 17 million tonnes of plastic "recycled" since 2022, worth about Rs 2,500 crore in certificate trade, the Central Pollution Control Board's own data shows. Yet columnist Sunita Narain wrote in Down To Earth on 1 September 2026 that plastic remains visible everywhere, because self-reported targets, weak verification and a newly restricted EPR portal point to certificate trading rather than real recycling. The gap between the paper trail and the street is now central to India's circular economy push.
Why doesn't India's plastic EPR system stop plastic pollution despite high recycling numbers?
India's Extended Producer Responsibility system reports 17 million tonnes of plastic recycled since 2022, but a Centre for Science and Environment audit found branded packaging made up 70% of waste in Agra's drains. Producers self-report targets, over 1,000 registered processors issue tradeable recycling certificates with weak verification, and CPCB restricted its EPR portal in June 2026, pointing to certificate trading rather than verified on-ground recycling.
This is not governance for tomorrow, not even of yesterday.
Sunita Narain, Down To Earth (1 September 2026)
What Actually Happened?
Under the Plastic Waste Management (Amendment) Rules, plastic producers, importers and brand owners (PIBOs) must collect 100% of the packaging they put into the market, a rule in force since 2023-24. Recycling targets rise from the current 40-60% band to 50-70% in 2026-27. For Category 2 packaging (multilayer sachets and pouches), the rule requires 100% collection and 50% recycling. As of CPCB's count, 41,544 PIBOs are registered and set their own targets, which the regulator does not independently verify before certificates are issued.
More than 1,000 plastic waste processors (PWPs) are registered to issue EPR certificates, one for every tonne they claim to recycle. CPCB prices these certificates by category: Rs 870 a tonne for PET (Category 1), Rs 1,500 a tonne for flexible plastic, and Rs 2,500 a tonne for compostable plastic. On 26 June 2026, CPCB directed states to act against PWPs issuing certificates beyond their stated processing capacity, an admission that certificates and actual recycling had diverged.
The economics explain why the gap persists. Narain notes an 18% GST rate makes "open", informal recycling commercially unviable, pushing waste either into formal EPR accounting or into drains, dumps and rivers that no certificate tracks. Environmental compensation for non-compliance is set at 2.5 times the cost of compliance, for example Rs 5,000 a tonne for Category 2, but CSE's own cost estimate for that category is Rs 4,000-6,000 a tonne against CPCB's Rs 4,000 benchmark. When the penalty and the real cost of compliance sit close together, producers have little financial reason to ensure the recycling behind a certificate is real.
Concept: How the EPR Certificate Market Works
An EPR certificate is meant to represent one verified tonne of recycled plastic. A PIBO that misses its own collection or recycling target can buy certificates from a processor instead of recycling the plastic itself, so the certificate functions like a tradeable credit. That design only works if the certificate reliably maps to a real tonne processed. CPCB's own June 2026 order against over-certification, and CSE's Agra audit, both suggest that mapping has broken down in practice, even as the headline recycling numbers keep climbing.
India's plastic EPR: what the rules promise vs what the evidence shows
| Element | What the rules require | What the evidence shows |
|---|---|---|
| Collection | 100% of packaging placed in market, since 2023-24 | 41,544 PIBOs self-report their own collection, unverified by CPCB before certificates issue |
| Recycling target | 40-60% rising to 50-70% in 2026-27 | CPCB had to order states (26 June 2026) to act against processors certifying beyond their real capacity |
| Multilayer plastic | 100% collection, 50% recycling for Category 2 | CSE's Agra drain audit found branded multilayer packaging was 70% of waste collected |
| Price signal | Environmental compensation set at 2.5x compliance cost | CSE estimates real Category 2 recycling cost at Rs 4,000-6,000/t, close to CPCB's own Rs 4,000/t benchmark |
| Transparency | EPR portal meant to let the public track certificates | Portal restricted to a closed user group from 28 June 2026; certificate trading on exchanges now under discussion |
How Did We Get Here?
- 2016 Plastic Waste Management Rules notified, introducing the Extended Producer Responsibility principle for plastic in India.
- 2023-24 100% collection obligation for PIBOs takes effect under the EPR system; recycling targets are set at 40-60% depending on packaging category.
- 26 Jun 2026 CPCB directs states to act against processors issuing EPR certificates beyond their verified capacity.
- 28 Jun 2026 The EPR portal is restricted to a closed user group, reducing public visibility into certificate issuance.
- 1 Sep 2026 Sunita Narain writes that the system's own numbers point to certificate trading rather than verified recycling.
Connect the Dots
- PIBOs self-report collection and recycling targets that CPCB does not independently verify before certificates issue
- An 18% GST makes small, informal "open" recycling commercially unattractive compared with the certificate economy
- Processors have an incentive to issue certificates for more plastic than they can actually process
- CPCB's own 26 June order to curb over-certification confirms the gap between paper and processing capacity
- The EPR portal is restricted just as scrutiny rises, reducing the public's ability to audit the system
- Branded plastic keeps showing up in drains, 70% in the Agra audit, even as "recycled" tonnage climbs on paper
Read More
Read More
- CPCB Plastic Waste Management Rules and EPR guidelines (Official rules, amendments and EPR targets for plastic packaging)
- Soil Health: Why More Fertiliser Is Not Fixing India's Soil (Another Sunita Narain-inspired look at how official measurement can miss the real picture, this time in agriculture)
The Debate
| View | Core argument | Evidence cited |
|---|---|---|
| Numbers hide the problem | Self-reported targets and unverified certificates let recycling be claimed on paper without matching ground reality | CSE's Agra drain audit: branded packaging was 70% of waste (Narain) |
| Numbers show progress | Collection and recycling targets have risen steadily since 2016, building a processor industry of over 1,000 units where none existed before | 17 million tonnes certified recycled since 2022 (CPCB) |
| Regulator is responding | CPCB's own June 2026 order against over-certification shows the system is self-correcting | CPCB directive to states, 26 June 2026 |
| Restriction over disclosure | Closing the public EPR portal just as scrutiny rose reduces, rather than improves, transparency | Portal restricted to a closed user group, 28 June 2026 |
What Could Happen Next?
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Why Does It Matter for India?
| Dimension | Why it matters |
|---|---|
| Public health | Unrecycled plastic in drains and rivers, as in the Agra audit, blocks waterways and ends up in soil and water |
| Circular economy goals | India's EPR system is the policy backbone of circularity; if certificates diverge from real recycling, the target itself becomes unreliable |
| Ease of doing business | Over 41,000 registered PIBOs rely on a predictable, credible certificate market; weak verification creates legal and reputational risk for compliant companies |
| Government accountability | CPCB is both regulator and, in effect, the data source on its own rules' success, so independent audits like CSE's matter for oversight |
What Should We Watch?
- Whether CPCB mandates independent, third-party verification of PWP capacity before certificates issue.
- Whether the EPR portal reopens to public scrutiny or stays a closed user group.
- Whether recycling targets, rising to 50-70% in 2026-27, are met on audited ground data, not self-reported numbers.
- Any move to formalise EPR certificate trading on a regulated exchange.
- Future CSE or independent field audits of plastic waste in cities beyond Agra.
Bottom Line
India's plastic EPR system looks successful by its own numbers: 17 million tonnes certified recycled, rising targets, over 41,000 registered producers. But a CSE field audit and CPCB's own enforcement order both point to a gap between certificates and verified, on-ground recycling. Closing the EPR portal to public view, just as this gap became visible, raises the stakes for independent verification rather than resolving them.
Key Terms
Sources & Further Reading
- Down To Earth: Plastic regime needs transparency, Sunita Narain (1 September 2026)
- CPCB: Plastic Waste Management Rules and EPR guidelines
- CPCB directive to states on EPR over-certification, 26 June 2026, as reported in Down To Earth (1 September 2026)
- Centre for Science and Environment field audit of plastic waste in Agra's drains, 2026, as reported in Down To Earth (1 September 2026)