In India, you don’t just deal with plastics and ignore the negative effects of plastic waste. As a producer, importer, or brand owner dealing with plastics, you need to understand EPR Annual Returns and its filing process.
EPR Annual Returns is a legal obligation under the Plastic Waste Management Rules, which mandates stakeholders dealing in plastic packaging to track how much plastic they put out, collect, and recycle or process each year. Despite the clear guidelines, many companies still make critical mistakes in the filing process, especially those related to EPR registration for plastic waste.
Here, I will highlight the common mistakes people make while filing their EPR Annual Returns and how to avoid them. You need to understand these common errors to save your business from penalties and operational setbacks.
1. Skipping EPR Registration or Forgetting Renewal
Before you can file your EPR Annual Returns, you must have registered for EPR through the Central Pollution Control Board (CPCB). Likewise, you need to renew the registration whenever it expires. Despite the importance of the registration, many companies still forget it.
To avoid errors, make sure you register under the correct category—Producer, Importer, or Brand Owner. Everyone is prone to forgetfulness, so set up calendar reminders 120 days before your registration expires. Likewise, always monitor the CPCB portal for any updates on renewal timelines and documentation.
2. Missing EPR Annual Returns Filing Deadlines
Many make the mistake of filing their EPR Annual Returns after the deadlines. Avoid this, because late filing can lead to automatic penalties and scrutiny from the CPCB. If you are into plastic waste handling, the deadline is June 30 of the next financial year, while the deadline for plastic recyclers is April 30.
Avoid missing the deadline by marking the deadlines on your compliance calendar. To be more proactive, you may assign a team member to compile data at least one month before the due date and submit early to avoid last-minute issues.
3. Misclassifying Waste Categories
Many classify their products wrongly while filing their EPR Annual Returns. This can misdirect your target and cause issues during audits. The categories of plastic waste are rigid, flexible, multilayered, and compostable.
To avoid this mistake, always refer to CPCB’s official classification guide. Likewise, make sure you review your products carefully. If you are not sure of the right classification for your product, consult a compliance specialist.
4. Reporting Incorrect Quantities
Have you ever found yourself in the mess of reporting incorrect figures in your EPR Annual Returns? Some companies give incorrect figures intentionally to appear compliant, while it’s just a mistake in the case of others. Regardless of the reason, incorrect figures may lead to serious penalties.
Avoid this mess by ensuring your weight calculations are accurate. This can be achieved by using calibrated equipment and converting to the correct metric units. Likewise, ensure that your entries match your invoices, shipping documents, and quarterly reports before final submission.
5. Mismatched Documents
Submitting documentation that doesn’t align with your declared data can put your EPR registration under scrutiny. CPCB auditors will verify your supporting documents with your portal entries.
To avoid the stress that comes with being scrutinised, upload clean and readable copies of all documents. Ensure you cross-check them with entries made in the CPCB portal. It is important that you keep original copies of the documents safely for future audits by your State Pollution Control Board (SPCB).
6. Mixing Plastic and E-Waste Data in EPR Annual Returns
If your company deals with both plastic and e-waste, you may mistakenly combine the data of both products in one return. Though it’s a mistake on your side, it’s a violation of compliance protocols and complicates matters during filing.
Therefore, ensure you maintain separate records and ledgers for plastic and e-waste, and always label the documents clearly. Likewise, be careful when filing them through their respective CPCB portals.
7. Using Unapproved Recyclers
Don’t just use any recycler or PRO, make sure they are approved and registered with the CPCB. Partnering with unregistered recyclers nullifies your compliance efforts and affects your EPR registration standing.
To avoid a waste of time and other resources, always verify your recyclers on the official CPCB list before engaging them. It may be necessary to even demand to see their valid recycling certificates and maintain an updated database of your vendor approvals.
8. Ignoring Mandatory Audits
Since 2022, CPCB has made third-party audits compulsory for companies with EPR registration for plastic waste. Avoid missing this step or waiting too long before you engage an auditor, because this could delay your return approval or cause non-compliance.
Since CPCB-authorized auditors are not so many, make sure you book one in advance. Ensure the audit findings and certificate are included in your annual return documentation. This will ensure compliance and add credibility to your reporting.
9. Overlooking Regulatory Updates
This is an issue many don’t regard as a mistake, but it is a costly one. Imagine putting all efforts in filing your EPR Annual Returns, but finding that things changed at the last minute or upon submission. The system of EPR registration changes quickly. New rules, formats, and deadlines can appear unexpectedly, and missing them can have serious consequences.
You can solve this by being updated. Subscribe to official updates from CPCB and SPCBs. Before filing, conduct internal reviews and adjust your compliance plans as needed. You may need to consider hiring experts to stay current with policy shifts.
10. Poor Recordkeeping That Leads to Inaccurate EPR Annual Returns
Poor documentation is the root cause of most issues in EPR Annual Returns. Without keeping a monthly record of what you produced, collected, and recycled, you are prone to mistakes when it’s time to file.
Safe yourself from committing errors by using structured tools like spreadsheets or EPR software to log daily or monthly data. Track your plastic usage, collection efforts, and recycling certificates systematically. A small effort throughout the year saves big headaches at filing time.
Filing EPR Annual Returns doesn’t have to be stressful, but it requires attention to detail, timely planning, and an up-to-date EPR registration for plastic waste. By avoiding these common errors and staying informed about your legal obligations, your business will stay compliant and demonstrate its commitment to responsible environmental practices.
