Law Updates

Subject

Summary: The State Pollution Control Board, Odisha , through a public notice dated 7 September 2026, has asked certain businesses covered under the Plastic Waste Management Rules, 2016, to complete their registration on the Common Extended Producer Responsibility (EPR) Portal. The notice is relevant to a range of entities working in the plastic sector, including producers, importers, brand owners, manufacturers, sellers and Plastic Waste Processors. The notice is particularly important for businesses that have not yet completed the registration applicable to them. It also affects companies whose suppliers or buyers remain unregistered because the Board has linked registration with continued reporting of purchase and sale transactions on the portal. There is one distinction that needs to be made from the start. Odisha has not implemented Plastic EPR using this notice issued in September 2026. The EPR system was there all along. The current document is centered around the aspect of registration on the Common EPR Portal of CPCB, migrating from the old portal, and transaction reporting.  Odisha SPCB EPR Notice at a Glance Particular Details Issuing authority State Pollution Control Board, Odisha Document Public Notice Notice No. 13525 / IND-IV-PCP-PWM-37 (Part-IV) / 2025-26 Date 7 September 2026 Subject Mandatory Registration on Common EPR Portal for Entities under the Plastic Waste Management Rules, 2016 Main regulatory framework Mandatory Registration on Common EPR Portal for Entities under the Plastic Waste Management Rules, 2016 Provisions referred to Clauses 6.1 and 6.2 of the EPR Guidelines Portal Common EPR Portal developed by CPCB Earlier portal Plastic-packaging EPR portal discontinued from 28 June 2026 Main requirement Registration of applicable entities on the Common EPR Portal Registration timing Immediate registration called for Transaction issue Recording/declaration of certain transactions with unregistered entities is to be discontinued Separate future deadline Not expressly specified in the notice Non-compliance Action may follow under the Plastic Waste Management Rules, 2016 Specific penalty amount Not expressly specified in the notice The notification is brief; however, it has business implications that go beyond merely requesting firms to establish an account with the portal. It links registration with the capacity for proper reporting of transactions in the plastic value chain.  What Is the Common EPR Portal for Plastic Packaging? The Common EPR Portal is the digital system developed by the Central Pollution Control Board for handling different parts of Extended Producer Responsibility compliance. For plastic packaging, the Odisha notice specifically refers to functions connected with: registration;  transaction reporting;  compliance with EPR targets; and  annual return filing.  In practical terms, the portal becomes the place where a covered entity's regulatory status and its EPR-related activity are brought together. Registration is therefore only one part of the system. Once an entity falls within the applicable regulatory category, other responsibilities may arise depending on whether it is a Producer, Importer, Brand Owner, manufacturer, seller, or Plastic Waste Processor . Registration Covered entities need to hold the registration applicable to their activity. The first task is to identify the correct category because two businesses dealing with plastic may not necessarily have the same EPR obligations. Transaction Reporting The portal is also used to report relevant transactions. This is where the September 2026 notice becomes particularly important. If a business is required to be registered but remains outside the portal, other entities dealing with that business may face a reporting problem. EPR Target Compliance Some regulated parties have EPR obligations associated with the collection, recycling, or other appropriate disposal of plastic packaging. The specific obligation will vary based on the regulation class and relevant provisions. The Odisha notice itself does not introduce a new EPR target percentage. Annual Returns Annual return filing also forms part of the portal-based compliance system. Companies therefore need to see registration as the starting point of compliance, rather than the entire compliance exercise. What Happened to the Earlier Plastic Packaging EPR Portal? Before the Common EPR Portal became the relevant system, plastic-packaging EPR activities were being handled through the earlier portal. According to the Odisha SPCB notice, operations of that portal were discontinued with effect from 28 June 2026, and existing user data was migrated to the Common EPR Portal.  That creates two different situations for businesses. Existing Registered Entities An entity that was already registered earlier should not automatically assume that no action is required simply because its data was migrated. As a practical internal check, it makes sense to verify: whether the Common EPR Portal account can be accessed;  whether basic business details are correct;  whether the registration category appears properly;  whether transaction records are available where relevant; and  whether the responsible compliance team has working portal access.  These checks are sensible migration controls. They are not all separately listed as statutory duties in the Odisha notice. Unregistered Entities For entities that should already be registered but are not, the Board's message is much more direct. The notice asks stakeholders to ensure immediate registration. Event Date What It Means Earlier plastic-packaging EPR portal discontinued 28 June 2026 Earlier portal operations stopped User data migrated Following portal transition Existing users were moved to the Common EPR Portal Odisha SPCB public notice 7 September 2026 Covered stakeholders were told to address registration and transaction-reporting compliance Separate later deadline Not specified Notice asks for immediate registration instead The 28 June date relates to the change in portal infrastructure. It should not be confused with the beginning of Plastic EPR regulation. Regulatory Framework Behind the Notice The simplest way to understand the update is to separate the law, the regulator, and the online portal. Plastic Waste Management Rules, 2016 The Plastic Waste Management Rules provide the underlying legal framework. They govern plastic-waste management and have been amended over time to deal with changing responsibilities across the plastic supply chain. EPR Guidelines Extended Producer Responsibility places responsibility on specified entities for managing plastic packaging after it enters the market. The Odisha notice specifically relies on Clauses 6.1 and 6.2 of the EPR Guidelines while listing entities required to register on the Common EPR Portal.  Central Pollution Control Board CPCB has developed the Common EPR Portal. Its role is therefore different from that of an individual business using the system. CPCB operates at the central regulatory level, while covered companies use the portal to fulfil applicable requirements. State Pollution Control Board, Odisha Odisha SPCB has issued the present communication to stakeholders operating within its jurisdiction. The notice also directs that copies be circulated through government departments, urban local bodies, District Collectors and the Board's regional network for wider awareness. Page 2 is largely concerned with this circulation rather than adding another set of substantive registration conditions.  Does the Odisha Notice Introduce a New Plastic EPR Requirement? No. It mainly reinforces and operationalises requirements under the existing Plastic Waste Management and EPR framework. The difference matters. A reader could otherwise look at the words "mandatory registration" and assume that registration became mandatory only on 7 September 2026. That is not the correct way to read the notice. The document instead addresses three immediate matters: use of the Common EPR Portal after migration from the previous portal;  registration of entities already falling within the relevant regulatory categories; and  transaction reporting involving entities that remain unregistered.  The business question is therefore not simply, "Has a new law been introduced?" The more useful question is: "Does my business fall within one of the categories that should already be registered, and is our present portal and transaction-reporting position compliant?" Who Needs to Register on the Common EPR Portal? The notice lists several categories. Companies need to identify themselves correctly because the regulatory position depends on the actual business activity. Producers The notice expressly includes Producers, including micro and small enterprises as defined under the Micro, Small and Medium Enterprises Development Act, 2006.  This point deserves attention from smaller units. A business should not assume that being a micro or small enterprise automatically means no registration is needed. The registration question and the extent of EPR obligations are separate issues. Importers Importers of: plastic packaging; and  plastic raw material  are also covered by the notice. An importer should therefore check exactly what is being brought into India and how that activity is classified under the Plastic Waste Management framework. Brand Owners Brand Owners are another expressly mentioned category. For a company selling products under its own brand, plastic packaging can bring the business within the EPR framework even where the company does not manufacture the packaging itself. Manufacturers of Plastic Raw Material Manufacturers supplying plastic raw material are also covered. This is important because Plastic EPR compliance is no longer something that should be viewed only from the perspective of consumer-facing brands. Manufacturers of Compostable or Biodegradable Plastic Items The notice specifically includes manufacturers of items made from: compostable plastics; and  biodegradable plastics.  These terms should be kept separate. Their regulatory treatment and technical requirements are not necessarily identical. Sellers Sellers are also referred to in the notice. The exact registration position should be assessed according to the activity being carried out and the applicable provisions rather than treating every person selling any plastic-containing product as automatically falling into the same category. Plastic Waste Processors Plastic Waste Processors, commonly referred to as PWPs, include entities engaged in: recycling;  waste-to-energy;  waste-to-oil; and  industrial composting.  Their role differs from that of a Producer or Brand Owner because PWPs handle plastic waste after generation and form part of the processing side of the EPR system. Entity-Wise Applicability Matrix Entity Industrial composting operator Main Area to Review Producer Yes Main Area to Review Micro/small Producer Yes Registration applicability despite enterprise size Importer Yes Plastic packaging/raw-material activity Brand Owner Yes EPR registration and transaction position Plastic raw-material manufacturer Yes Correct portal registration Compostable plastic manufacturer Yes Appropriate regulatory category Biodegradable plastic manufacturer Yes Appropriate regulatory category Seller Yes Whether the selling activity falls within the covered category Recycler Yes PWP registration and reporting Waste-to-energy operator Yes PWP registration Waste-to-oil operator Yes PWP registration Industrial composting operator Yes PWP registration What Is the Position of Micro and Small Enterprises? This is one area where careless wording can easily create confusion. The Odisha notice expressly refers to Producers, including micro and small enterprises, while listing entities required to register.  Therefore, a micro or small enterprise should not begin with the assumption that MSME status automatically removes the registration requirement. The notice also refers separately to micro and small Brand Owners in the part dealing with recording transactions with unregistered entities. That reference is limited. It should not be turned into a statement that every micro or small Brand Owner enjoys a complete exemption from the Plastic Waste Management framework. For an MSME, the compliance assessment should therefore answer four separate questions: What role does the enterprise perform?  Is Common EPR Portal registration required for that role?  Which EPR duties actually apply?  Are there any specific exceptions relevant to that entity or transaction?  Keeping those questions separate reduces the risk of either over-compliance or missed obligations. Is Registration Required Before Carrying on Business? The notice takes a firm position for entities falling under Clause 6.1. It states that covered entities shall not carry out business without registration obtained through the Common EPR Portal.  For a company that clearly falls within the covered category, registration is therefore not something that should be left until the annual return stage. The practical sequence is straightforward: identify the entity's correct regulatory category;  check whether registration already exists;  verify whether it is available on the Common EPR Portal; and  address any registration gap before continuing to rely on an incomplete compliance position.  This is a practical roadmap, not a separate statutory procedure prescribed word for word by the notice. What Happens to Transactions With Unregistered Entities? This is probably the most important operational part of the September notice. Odisha SPCB states that declaration or recording of purchase and sale transactions with unregistered entities will be discontinued on the Common EPR Portal, except in respect of the stated Brand Owner (micro and small) and PWP-related transactions, as applicable.  The wording needs to be handled carefully. It does not automatically mean that every commercial agreement with an unregistered party becomes void. The notice is specifically addressing regulatory registration and portal transaction reporting. Purchase Transactions Consider the procurement side first. If a supplier is required to hold EPR registration but remains unregistered, the purchasing company may not be able to treat that transaction in the normal manner for portal reporting. That creates a practical reason to check suppliers before the issue reaches the reporting stage. Sale Transactions The same concern works in the opposite direction. A seller dealing with a buyer that should be registered may face difficulty when the relevant transaction needs to be reflected on the portal. Why Counterparty Status Now Matters More EPR registration can therefore affect more than the entity named on the certificate. Situation Possible Problem Practical Response Registered buyer dealing with unregistered supplier Purchase reporting may be affected Check whether supplier registration is required Registered seller dealing with unregistered buyer Sale reporting may face difficulty Ask buyer to review registration Existing supplier has unclear status Reporting risk may remain unnoticed Carry out a registration-status review PWP transaction involved Special transaction treatment may apply Review the applicable PWP provisions before reporting A company may have its own registration in place but still face reporting problems because another business in its supply chain has not regularised its position. What Should Businesses Do About Unregistered Suppliers and Buyers? The notice directly asks stakeholders to require their unregistered suppliers and buyers to obtain registration immediately so that continued transaction reporting can be enabled.  For a company with many suppliers or customers, this cannot always be managed only by the legal department. Procurement, sales, accounts and compliance teams may all need to work together. A sensible internal review may cover: suppliers handling plastic packaging or raw material;  buyers falling within a covered EPR category;  EPR registration details already available in vendor records;  transactions waiting to be reported;  suppliers or customers whose registration position is unclear; and  communication sent to counterparties asking them to regularise their registration.  The notice does not prescribe a new formal KYC process. These are practical controls that can help the company manage the reporting issue highlighted by Odisha SPCB. How Does This Affect Different Business Teams? Procurement Procurement teams may need to add EPR status to their vendor-compliance checks where the supplier falls within a covered category. A low price or established commercial relationship does not solve a registration problem if the transaction later cannot be properly reflected in the regulatory system. Sales Sales teams may also need basic visibility over whether certain customers are registered. This becomes more relevant where the customer's status affects transaction reporting. Accounts and Finance Finance teams generally hold the underlying purchase and sales records. If the commercial data in the company's books and the information available for EPR reporting do not match, the compliance team may struggle when filing or reconciling portal data. Environmental and Compliance Teams These teams have to connect the regulatory requirement with actual business records. That includes registration status, entity classification, portal access, and transaction reporting. Waste-Management Teams Where a company works with recyclers or other PWPs, it should confirm that the processor being relied upon is appropriately registered for the relevant activity. What Does the Notice Mean for Plastic Waste Processors? Plastic Waste Processors do not all perform the same activity. Recyclers Recyclers process plastic waste into material that can be used again, subject to the applicable regulatory framework. For EPR purposes, their registration status can be important for businesses relying on recycling to meet applicable obligations. Waste-to-Energy Operators These entities use plastic waste in approved energy-recovery operations. Their role and regulatory treatment should not be confused with conventional recycling. Waste-to-Oil Operators Waste-to-oil facilities process plastic waste through technologies that convert it into oil or related outputs. They are separately recognised in the notice under the PWP category. Industrial Composting Facilities Industrial composting is relevant particularly in the context of suitable compostable plastic waste. Again, this is a different processing route and should not be presented as if it were simply another name for recycling. What Does the Notice Mean for Plastic Raw-Material Businesses? Raw-material businesses can no longer treat EPR registration as an issue that belongs only to packaged-goods companies. The notice expressly includes: Importers of plastic raw material;  manufacturers of plastic raw materials; and  Sellers falling within the covered regulatory category.  For these businesses, the priority is correct classification. A company may manufacture raw material, import part of its requirement and sell material to other manufacturers. That can create more than one compliance question. Its internal review should therefore look at: the nature of the material;  whether it manufactures, imports or sells;  the registration category presently shown on the portal;  transactions with other regulated businesses; and  whether transaction reporting is being completed correctly.  What Does the Notice Mean for Compostable and Biodegradable Plastic Businesses? Manufacturers dealing with compostable or biodegradable plastic items are expressly mentioned in the Odisha notice. This does not mean the two categories are the same. A manufacturer should use the exact classification that applies to the product and should not casually describe a product as "biodegradable" or "compostable" simply because it is marketed as environmentally friendly. For this notice, the immediate point is registration. Product-specific certification or technical requirements, where applicable under other provisions, should be examined separately. Is There a Separate Registration Deadline? The public notice asks for immediate registration, but it does not set out another future calendar date by which every stakeholder must register.  Three dates or timing points should not be mixed: Event Timing Earlier EPR portal discontinued 28 June 2026 Odisha SPCB public notice issued 7 September 2026 Registration direction Immediate Separate later deadline Not expressly specified This matters because saying "registration is due by X date" without an official source would create a deadline that the notice does not provide. What Does the Notice Not Specify? The Odisha SPCB communication should be read for what it actually contains. It does not expressly introduce a new: application fee;  EPR target percentage;  Registration validity period;  fixed application-processing period;  environmental compensation amount;  monetary penalty;  separate transition period after 7 September 2026; or  future registration cut-off date.  Some of these subjects may be addressed elsewhere in the governing rules, amendments, guidelines, or CPCB procedures. They should not be attributed to this particular notice unless they actually appear in it. Immediate Compliance Checklist Compliance Area What to Check Responsibility Nature Entity classification Whether the company is a P, I, BO, manufacturer, seller or PWP Compliance/Legal Essential applicability review Portal registration Whether registration required for the entity is active Compliance Source-based requirement Migrated account Whether old account data is properly available Compliance/IT Recommended migration check Suppliers Whether relevant suppliers are registered Procurement/Compliance Practical control Buyers Whether relevant buyers are registered Sales/Compliance Practical control Transactions Whether purchases/sales can be reported Finance/Compliance Source-linked issue PWP relationships Whether waste-processing partners have the required status Sustainability/Compliance Practical compliance control Records Whether commercial and portal data match Finance/Compliance Recommended internal control Risks of Leaving the Issue Unresolved Regulatory Risk Odisha SPCB clearly says that non-compliance with the provisions referred to in the notice will attract action in accordance with the Plastic Waste Management Rules, 2016. The notice itself does not state a fresh numerical penalty. That distinction should be maintained. Transaction-Reporting Problems An entity may find that transactions involving an unregistered counterparty cannot be recorded in the expected manner. This can turn a supplier-registration issue into the registered company's own reporting problem. Internal Data Gaps EPR reporting relies on commercial information. If sales, procurement and compliance teams maintain different versions of the same transaction data, reconciliation can take more time and create avoidable errors. Counterparty Disruption Registered businesses may increasingly prefer dealing with counterparties whose compliance position is clear because it makes regulatory reporting easier. That is a possible commercial effect of the notice, not a separate punishment imposed by the Board. Impact on Different Stakeholders Stakeholder Immediate Effect Main Concern Producers Registration position comes under sharper focus Missing or incorrect EPR registration Importers Packaging and raw-material activities need review Wrong entity classification Brand Owners Existing EPR responsibilities continue Reporting with unregistered counterparties MSMEs Cannot rely only on enterprise size Assuming registration is unnecessary Raw-material businesses Greater portal compliance responsibility Registration and transaction data Sellers Need to check whether their activity is covered Unclear applicability PWPs Processing activity linked with portal status Correct registration Procurement teams Supplier status becomes relevant Unregistered vendors Finance teams Commercial data supports EPR reporting Data mismatch Compliance teams Need coordination across functions Incomplete records Benefits of Keeping Common EPR Portal Compliance in Order Good portal compliance is mainly about reducing avoidable gaps. For a regulated business, it can help create: clearer visibility over registration status;  better coordination between commercial and compliance data;  more organised transaction reporting;  easier identification of unregistered counterparties;  cleaner records for annual reporting; and  a more structured approach to EPR responsibilities.  These are practical compliance benefits. They should not be presented as guaranteed savings or guaranteed protection from regulatory action. Challenges Businesses May Face Identifying the Right Category The first problem is often not filling the form. It is deciding which legal category applies. A company may perform two or three activities at the same time. Cleaning Up Migrated Data Businesses already present on the earlier portal may have to spend time reviewing migrated information and resolving mismatches. Following Up With Suppliers and Customers A company's own registration can be complete while its supply chain remains inconsistent. That means follow-up may be needed outside the compliance department. Managing Transaction Volumes Companies processing a large number of purchases and sales may need better internal controls so the data reported on the portal matches commercial records. Limited Compliance Resources in MSMEs Smaller units may not have a separate legal or environmental team. That makes correct classification and timely portal work more difficult, even though the registration issue still needs attention. Is the Direction Useful or an Added Burden? The answer depends largely on how organised the business already is. For a company with current registration, clean transaction records and registered counterparties, the direction may require only a targeted review. For a business that has postponed registration or never checked the EPR status of its suppliers and buyers, the work can be considerably larger. From the regulator's side, a common portal can improve visibility and make it harder for unregistered entities to remain outside the reporting chain. From the business side, the same system creates more responsibility for checking data and counterparties. So the real burden is not simply the existence of a portal. It is the need to make commercial transactions and regulatory records match. What Businesses Should Do Now 1. Confirm the Business Category Do not begin the compliance exercise by filling a registration form. Start by confirming whether the company is acting as a Producer, Importer, Brand Owner, manufacturer, seller, or Plastic Waste Processor. 2. Verify Registration In cases where registration is necessary, ensure that the business has been duly registered on the Common EPR Portal. 3. Check Migrated Information In case of a previous EPR account for the business, check the information post-migration. 4. Unregistered Counterparties Suppliers and buyers can be found in procurement and sales data. 5. Verify Transaction Reporting Capability Check if the transactions can be adequately reported using the portal. 6. Verify Correspondence Between Portal Information and Internal Information Information on sales, purchases, waste disposal, and regulatory compliance must be checked before submission. 7. Address Problems Promptly It is always best to solve problems pertaining to registration, classification, and transaction reporting before the number of transactions starts increasing. How Can Corpseed Help With Plastic EPR Registration Services? Plastic EPR compliance is easier to manage when the business first understands exactly where it fits in the regulatory chain. Corpseed's Plastic EPR Registration Services can support businesses that need help with applicability assessment, registration, portal compliance, and related EPR requirements. 1.    EPR Applicability Assessment Before starting registration, Corpseed can help review the company's activities and determine whether it falls within a relevant category such as: Producer;  Importer;  Brand Owner;  Plastic raw-material manufacturer;  Covered Seller; or  Plastic Waste Processor.  This is useful where the company carries out several activities and the correct regulatory position is not immediately clear. 2. CPCB Common EPR Portal Registration Support Where registration applies, Corpseed can assist with the registration process and organisation of the information required for the applicable filing. This support can be useful for newly covered entities as well as businesses that need help understanding their position after migration to the Common EPR Portal. 3. EPR Compliance Gap Assessment Existing registration does not always mean the entire compliance position is complete. Through EPR compliance services, Corpseed can help identify gaps involving: registration details;  entity classification;  portal records;  transaction reporting;  counterparty information; and  ongoing compliance responsibilities.  4. Transaction Reporting Support Where a business is facing difficulties because suppliers or buyers are unregistered, Corpseed can help review the compliance issue and identify the information that needs attention. The portal itself remains under CPCB's regulatory control so that no consultant can guarantee regulator approval or portal acceptance. 5. Supplier and Buyer EPR Compliance Review A counterparty review can help identify suppliers or customers whose registration status may affect portal reporting. This can be particularly useful for businesses with a large vendor network. 6. Plastic Waste Compliance Services Where the issue extends beyond registration, Corpseed can support businesses with wider plastic waste compliance services, including regulatory applicability reviews and ongoing documentation support. 7. Ongoing EPR Compliance Support For many businesses, EPR does not end once registration is received. Depending on the entity and activity, further work may involve transaction reporting, annual returns, records and continuing regulatory requirements. An experienced EPR registration consultant can help the business keep these activities organised while the company focuses on its day-to-day operations. Key Takeaways The 7 September 2026 Odisha SPCB notice puts the focus on a very practical issue: covered plastic businesses need to be properly registered on the Common EPR Portal, and unregistered entities can create problems for transaction reporting. The main points are: CPCB has moved plastic-packaging EPR activities to the Common EPR Portal.  The earlier portal was discontinued on 28 June 2026.  Existing user data was stated to have been migrated.  Producers, Importers, Brand Owners, relevant manufacturers, Sellers and Plastic Waste Processors are among the categories named in the notice.  Micro and small Producers are specifically referred to.  Entities covered under Clause 6.1 are told not to carry on business without the required registration.  Purchase and sale reporting involving unregistered entities is specifically addressed.  Stakeholders are asked to get unregistered suppliers and buyers registered so transaction reporting can continue.  The notice calls for immediate registration but does not provide a separate future calendar deadline.  Non-compliance may lead to action under the Plastic Waste Management Rules, 2016, although this notice does not itself state a specific monetary penalty.  For companies still unsure about their category, registration status, or portal reporting, the first step should be an applicability review. Where professional assistance is needed, Plastic EPR Registration Services, CPCB EPR registration support, and ongoing EPR compliance assistance can help organise the process without treating every business as if it has identical obligations.