Two separate corners of India's Extended Producer Responsibility framework moved in the same fortnight: plastic packaging rules closed a loophole that let companies count landfilled waste as “recycled,” and a policy brief on EV battery recycling laid out, in detail, why a strong rulebook on paper still leaves a black market in battery scrap untouched. Read together, they are the same story — a regulator writing increasingly specific rules, and an enforcement gap that specificity alone does not close.
Regulation · Circularity · Waste
India's EPR Regime Just Got Teeth — and a Battery Recycling Policy Brief Explains Where It Still Bites
Published · v1.0.0 · EPR notification of 19 January 2026 · Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E), 31 March 2026) · CSE policy brief, 2026
Plastic: the loophole that let disposal count as recycling
Closed with no grace period.
India's Ministry of Environment, Forest and Climate Change issued a notification on 19 January 2026, effective immediately, withdrawing a Central Pollution Control Board notice of 28 November 2025 that had temporarily allowed the practice, with the annual-return deadline falling just twelve days later. The headline change: companies can no longer use End-of-Life (EOL) disposal certificates — credits earned by sending plastic waste to landfill or incineration — to meet their recycling obligations. That closes a real loophole: an EOL certificate let a producer technically satisfy its EPR target without any material actually being recycled. The replacement framework enforces a strict hierarchy — reuse offsets every downstream obligation, recycling offsets recycling and EOL disposal, but EOL disposal can no longer offset reuse or recycling — and certificates must now match the specific waste category they claim to satisfy, with no cross-category substitution once FY2025-26 closes.
Exhibit 1
Mandatory recycled-content targets, plastic packaging (Category I)
Minimum share of recycled content required in new plastic packaging, by producer category and year. First set in the 2022 EPR guidelines and kept in the Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E), 31 March 2026).
| Fiscal year | Category I target, % |
|---|---|
| 2025-26 | 30 |
| 2026-27 | 40 |
| 2027-28 | 50 |
| 2028-29 onward | 60 |
Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E), 31 March 2026), as summarised by Corporate Professionals' regulatory update. Category II targets run 10%→10%→20%→20% over the same years; Category III runs 5%→5%→10%→10%. All recycled plastic must comply with IS 14534:2023 and carry mandatory recycled-content labelling; food-contact applications carry a separate FSSAI layer and unfulfilled targets there may be carried forward up to three years.
For what these targets mean specifically for PET bottles — the FSSAI food-grade rPET capacity coming online to meet them, and the informal kabadiwala collection network the certification requirement doesn't yet formally recognise — see this site's dedicated PET-recycling piece.
Reuse targets tighten on a similar curve: rigid packaging in the 0.9–4.9 litre-per-kilogram range moves from a 10% reuse target in 2025-26 to 25% by 2028-29; drinking-water packaging, already at a demanding 70% reuse target this year, rises to 85%. CPCB had six months from the 31 March 2026 notification, that is until the end of September 2026, to prescribe verification guidelines, and registered environment auditors — a role the amendment formally creates — will conduct the checks.
Batteries: the rulebook is detailed. The enforcement gap is documented.
A 2026 policy brief lays out exactly where India's battery-EPR regime is being routed around.
India's Battery Waste Management Rules, first notified in 2022 and amended in 2023, 2024 and 2025, run a comparably detailed regime for EV and other batteries. Manufacturers must hit a 90% recovery rate of battery materials by 2026-27, up from 70% in 2024-25, and incorporate recycled material into new cells starting at 5% in 2027-28 and rising to 20% by 2030-31. Roughly 4,000 producers, recyclers and refurbishers are registered with the Central Pollution Control Board, which fixes a floor and ceiling price for EPR certificates every six months and allows limited carry-forward of unmet targets across a seven-year compliance cycle. A 2025 amendment added QR-code and barcode marking requirements so a battery's EPR registration travels with the physical product.
The brief's own framing is instructive: EV batteries reach “end-of-life” inside a vehicle once their state of health drops to 70–80% of original capacity — well before the cell is chemically exhausted. Under the EPR framework, producers are supposed to assess that residual capacity and route the battery to second-use applications, such as stationary storage, before final recycling. That second-use stage is itself where NITI Aayog's proposed “battery passport” — a QR-code-embedded digital record of a battery's source, composition, performance history and supply chain — is meant to matter most, giving a second-use buyer and an eventual recycler the data to make that assessment reliably. The passport system is announced, not yet operating at scale.
The pattern across both
Detailed rules, escalating targets, and a persistent gap between what's mandated and what's tracked.
Sources. Plastic Waste Management (Amendment) Rules, 2026, G.S.R. 237(E) of 31 March 2026 — Corporate Professionals, regulatory update summarising the Ministry of Environment, Forest and Climate Change notification; Aleph India, coverage of the End-of-Life certificate removal, dated to the 19 January 2026 notification. EV battery EPR regime, recovery-rate and recycled-content targets, registered-entity count, black-mass and informal-sector findings, and the ₹1,500 crore NCMM recycling incentive — Anumita Roychowdhury and Moushumi Mohanty, Electric Vehicle Battery Recycling and Extended Producer Responsibility (EPR): Reform the Terms of Action, Centre for Science and Environment, New Delhi, 2026. Battery Waste Management Rules background (2022 notification and 2023/2024/2025 amendments) as summarised within the same CSE brief. Update of 7 November 2026: Beacon Filing on the 2022 origin of the recycled-content targets; CPCB plastic EPR portal notice; CPCB battery e-invoice notice (copy); MoEFCC annual-return extension.
A companion piece on the used-oil EPR regime covers a parallel circular-economy mandate under the same Hazardous and Other Wastes rules framework — a 5%-to-50% recycling ramp for lubricants, running on the same registration-and-certificate mechanics, and showing the same pattern: a real legal target, and a registration system still catching up to it.
What would fix this
- The Central Pollution Control Board should publish a compliance summary of plastic EPR annual returns filed after the 19 January 2026 notification, by producer category, showing targets met and shortfalls, so the effect of removing End-of-Life certificates can be measured rather than assumed.
- The Central Pollution Control Board should notify the verification guidelines the amendment requires within its six-month window and publish a list of registered environment auditors, so recycled-content and reuse targets are checked by named auditors under published rules.
- The Central Pollution Control Board should publish quarterly figures for black mass produced by registered battery recyclers, and how much was refined in India, sold on or exported, so the market the CSE brief calls a black hole becomes visible in official data.
- The Central Pollution Control Board should publish, by battery category, the tonnes registered recyclers actually received and processed against producers' EPR obligations each year, so the reverse-logistics gap — recyclers unable to obtain the batteries their certificates assume — is quantified.
- The Ministry of Mines should report how much of the ₹1,500 crore National Critical Mineral Mission recycling incentive has been sanctioned and disbursed, to which recyclers, so it is clear whether the support is reaching the battery-recycling ecosystem or remains an approved allocation.
These are proposals from this blog, not recommendations any agency has adopted.
About this article: Researched, written and edited by Umashankar Triplicane Dwarakanathan, with AI research assistance; every figure is meant to trace to the primary source cited. See the Editorial Policy for how sourcing, AI use and corrections work.
