On 28 June, the old plastic EPR portal went dark.
Every producer, importer, brand owner, and recycler who had spent years logging packaging tonnes into eprplastic.cpcb.gov.in woke up to a new address, a new Common EPR ID, and a filing module that still wasn’t ready.
For three months, the annual return for FY2025-26 simply could not be filed. No Environmental Compensation could be levied either — because there was no deadline to miss.
That protection is over.
The module is live on the Common EPR Portal. Plastic Waste Processors have until 31 October to file. Producers, Importers, and Brand Owners have until 31 December. And for the first time, every brand using rigid plastic packaging in India has to put a number on the screen that says: 30% of last year’s packaging was recycled plastic.
Eighty-seven days. That’s the clock for brands, as of today. For recyclers, it’s closer to twenty-six.
The deadline is not the story. The supply chain is.
The recycled-content targets for FY2025-26 were never a secret.
Category I rigid packaging: 30%.
Category II flexible: 10%.
Category III multilayer: 5%.
Those climb to 60%, 20%, and 10% by 2028-29. A parallel reuse obligation sits alongside them — 10% minimum reuse for smaller rigid packaging, 70% for rigid drinking-water packaging above 4.9 litres.
What changed on 31 March 2026 — the last day of the financial year those targets applied to — was relief.
The Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E)) let producers who miss their food-contact recycled-content target carry the shortfall forward for up to three years, clearing at least one-third each year. The same logic covers reuse shortfalls.
That relief exists only for food-contact packaging. Non-food rigid packaging does not get the same runway.
And the amendment also brought “sellers” of plastic raw material into the obligated net for the first time, and directed CPCB to issue audit guidelines for recycled-content claims within six months. Self-reporting is on a countdown.
If you run packaging compliance at a company that sells cookware, foodservice film, or industrial components - the practical question is not “do we have a target?”
You already know you do.
The question is whether every supplier in your chain can prove theirs.
Register, or your trades stop counting.
On 27 August, CPCB issued a public notice that most compliance teams should have printed and pinned above their monitors.
Entities covered under the Plastic Waste Management Rules cannot carry on business without registration on the Common EPR Portal. That list is not just brand owners and recyclers. It includes producers (including micro and small enterprises), importers of plastic packaging and raw materials, manufacturers of plastic raw materials and compostable or biodegradable items, sellers, and Plastic Waste Processors across recycling, waste-to-energy, waste-to-oil, and industrial composting.
The sharper line is this: CPCB said it will discontinue recording purchase and sale transactions with unregistered entities on the portal, subject to limited exceptions for certain micro/small brand owners and some PWP transactions.
Your own registration is no longer enough.
An unregistered supplier can break your compliance chain — because the portal will stop recognising the deal.
States are already echoing the notice. Odisha’s pollution control board followed on 7 September. Nagaland’s pollution control board (NPCB) directed stakeholders on 23 September. When state boards start sending the same letter, “we’ll migrate next quarter” stops being a plan.
At Cercle X we see this from the middle of the chain — brands trying to go waste-neutral with end-to-end traceability, and processors who need those transactions to land on a portal that still recognises them. The companies that will get through December cleanest are the ones that started calling suppliers in September, not the ones that start calling in December.
The supply fight nobody has settled.
Here is the part that makes the 30% number uncomfortable.
In April, the PET Packaging Association for Clean Environment (PACE) — which represents leading beverage companies and recyclers — told the Environment Ministry that food-grade recycled PET supply was about 3.54 lakh tonnes, against a requirement of 6.84 lakh tonnes to meet the 40% recycled-content mandate for FY2026-27. Their ask: revise targets to match FSSAI-approved availability, and ease the carry-forward terms until supply catches up.
In May, the Association of PET Recyclers (APR) Bharat answered from the other side of the same table. Director General Goutham Jain said India has built roughly 4.39 lakh tonnes of food-grade rPET capacity (including non-members), at an investment of over ₹10,000 crore — and that 20–25% of that capacity sits idle because brands are not buying. APR Bharat argues the FSSAI-approved plants can cover the 40% FY26-27 mandate and the carry-forward, and that capacity is headed toward around 12.26 lakh tonnes by March 2027.
Read both letters carefully. They are not arguing about the same tonne.
PACE is talking about food-grade material actually available to packaging endpoints after fibre demand, exports, and non-food use take their cut. APR Bharat is talking about approved plant capacity and whether brands are placing orders. Both can be directionally true at once. Capacity without offtake looks like idle lines. Offtake without enough food-contact-qualified resin looks like a compliance cliff. The uncomfortable question for a beverage or FMCG packaging lead is which of those two stories your own purchase orders will support when CPCB starts auditing the recycled-content column.
These figures are from April and May. I have not seen a newer, reconciled national supply number that both sides accept. Treat them as a snapshot of the fight, not a live dashboard.
Can the certificate be trusted?
SCRAPPED already covered the “ghost certificate” scam angle in depth on 1 October, so I won’t re-litigate it here.
Brief context for anyone who missed it: on 25 June, CPCB reportedly acted against more than 200 plastic waste processing units over fake invoices and related irregularities — that figure comes from industry reporting of the enforcement wave, not from the order text itself sitting in front of me.
And on 8 September, Saurabh Shah, Managing Director of Landbell GreenForest Solutions India, wrote in Waste & Recycling that CPCB’s new exchange-style trading platform for EPR credits (EPRETP, with MSTC) risks solving a trading problem the market never primarily had.
His line is the one that sticks: the market does not have a trading problem. It has a verification problem.
An auction venue cannot make an unreliable underlying asset reliable.
If the certificate entering the system has not been independently verified against real processed tonnes, a more sophisticated marketplace just gives questionable credits a better listing page.
For packaging buyers, that lands as a procurement question: are you buying compliance, or are you buying a PDF?
The March amendment’s promised Registered Environment Auditor framework — CPCB guidelines within six months of notification — is the piece that could close that gap. Watch whether those guidelines actually land, and whether they bind recycled-content claims the same way they bind certificate generation.
The honest caveat
Three things I want you to treat carefully before you forward this to your compliance Slack.
One: the 31 December PIBO deadline and 31 October PWP deadline are as reported by Kar Parivartan on 9 September, tracking MoEFCC/CPCB’s revised FY2025-26 filing window after the portal migration. CPCB has revised plastic annual-return deadlines several times in prior cycles. Cross-check the Office Memorandum on the Common EPR Portal (epr.cpcb.gov.in) or cpcb.nic.in before you put either date in a board note. A five-minute check. Do it.
Two: the food-contact carry-forward is not a general amnesty. If your shortfall sits in non-food rigid packaging, you do not automatically get the three-year runway. Read the category line on your own SKUs.
Three: I am writing this from inside a waste-and-recycling company. That gives me a useful view of how registration gaps and certificate quality show up in real supplier conversations. It also means I have a dog in the traceability fight. Discount accordingly where you need to.
The signal to watch
Not the press release when someone announces they “achieved 30%.”
Watch whether, between now and 31 December, large brand owners publish supplier-registration completion rates alongside their recycled-content claims — what share of their plastic packaging counterparties hold a live Common EPR ID, and what share of FY2025-26 tonnes sit on transactions the portal will actually record. If that number starts showing up in investor decks and sustainability reports the way recycled-content percentages already do, the 27 August notice worked. If it doesn’t, December will produce a lot of filings that look complete on the brand’s side and fall apart one supplier deep.
The portal is open. The trades with unregistered parties are the ones quietly disappearing from the ledger.
This is the feature + roundup edition of the Circularity Digest, built by the research team of Cercle X, headed by Vishnu Vardhaan.
Loved reading this? Share it with your friends and your peers, and colleagues. Let’s build a wave of circularity across the world.
Quick Hits — everything else from today’s digest
Water & Ocean Systems
A desalination process that leaves behind solid salt instead of toxic brine — and recovers roughly half the lithium hidden in the water along the way. University of Rochester engineers built laser-etched black metal panels aimed at the 2.2 billion people worldwide without safely managed drinking water. Source
Materials, Packaging & Building
An engineering college in Tamil Nadu built a concrete that eats carbon dioxide. Swapping half the sand for zeolite and 1% of the cement for bamboo biochar produces “ZB5” — 15% stronger in tension than regular concrete, and it actively absorbs CO2 from the air around it. Source
Waste & Circularity
India holds roughly 35% of the world’s ship-recycling market, re-rolling scrapped-vessel steel straight back into construction supply chains at 58% less carbon than virgin steel — though the recycled steel still trades at a discount because no formal certification standard exists yet. Source
Mobility & EVs
India sold a record 327,901 EVs in July 2026, up 66% year-on-year — but its 52,718 public charging stations remain concentrated in a handful of cities, leaving the ownership math difficult everywhere else. Source
Agriculture & Food Systems
2,550 farmers in Punjab and Haryana received India’s first soil carbon payments — ₹2.9 crore total, verified by satellite and soil sampling — for practices that also diverted 200,000+ tonnes of paddy straw from burning and saved an estimated 45 billion litres of groundwater. Source
Policy, Finance & Carbon Markets
The EU’s Circular Economy Act targets doubling material circularity from 12.2% to 24% by 2030, with the remanufacturing sector projected to triple from €31 billion to €100 billion. Source
Climate & Biodiversity
Indian forest fire activity is running more than 80% above the decade average this year, worst in the Northeast and Himalayan states — in February, the Air Force dropped over 12,000 litres of water on fires above 2,800 metres in Arunachal Pradesh and Nagaland. Source
Energy Transition
India added 6.6 GW of rooftop solar in the first half of 2026 alone — up 131% year-on-year, 84% of it residential. The PM Surya Ghar scheme has now reached 4.5 million households, 45% of its 10-million target. Source
Deep Dive
Edo-period Japan ran a near-total circular economy 400 years before the term existed — a city of over a million people with almost no imports, supported by ash merchants, umbrella-paper resellers, and roughly 4,000 dealers trading used clothing alone. Source
Sources referenced in the feature
Kar Parivartan (9 Sep 2026) — FY2025-26 AR window, PWP 31 Oct / PIBO 31 Dec, old portal shut 28 June: https://www.karparivartan.com/cpcb-reopens-the-fy-2025-26-annual-return-window-revised-deadlines-notified-for-pibos-and-pwps/
SJ Exim / ALS (11 Sep 2026) — CPCB 27 Aug notice, Common EPR Portal registration, unregistered transactions restricted: https://sjexim.services/2026/09/11/cpcb-mandates-common-epr-portal-registration-for-plastic-packaging-entities-transactions-with-unregistered-entities-to-be-restricted/
Morung Express (23 Sep 2026) — Nagaland NPCB direction: https://morungexpress.com/nagaland-npcb-directs-plastic-stakeholders-to-register-on-epr-portal
Corpseed (7 Sep 2026) — Odisha SPCB notice: https://www.corpseed.com/law-update/odisha-spcb-common-epr-portal-registration-notice-2026-plastic-businesses
Newtral (reviewed Jul 2026) — 31 Mar PWM Amendment relief, 30/10/5% targets, food-contact carry-forward: https://newtral.io/articles/relief-delivered-after-the-deadline
Zee Live News / businessline report (26 Apr 2026) — PACE 3.54 lakh t vs 6.84 lakh t: https://zee-live-news.com/tech/beverage-industry-flags-challenges-in-meeting-recyled-pet-content-targets-in-packaging/
Packaging South Asia (27 May 2026) — APR Bharat 4.39 lakh t capacity, 20–25% idle: https://packagingsouthasia.com/she-safety-health-and-environment/sustainability-health/rpet-facilities/
NexG Petro Lube blog — 25 June enforcement vs 200+ units (industry blog, not the order itself): https://www.nexgpetrolube.com/blog/cpcb-tightens-epr-enforcement-against-plastic-waste-processors
Waste & Recycling (8 Sep 2026) — Saurabh Shah / Landbell on EPRETP verification problem: https://www.wasterecyclingmag.com/news/the-mystery-behind-cpcb-s-exchange-trade-platform-for-epr-credits