EPR for Importers of Machinery and Equipment
Check whether EPR applies to the machinery and equipment you import: e-waste, battery, plastic packaging, waste tyre or used oil EPR, which CPCB portal applies, and why registration must come before import.
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Does EPR Apply to Imported Machinery and Equipment?
Extended Producer Responsibility (EPR) in India attaches to products, not to the act of importing. Importing a machine does not, by itself, make you an EPR producer. What decides it is what the shipment contains and what you do with it.
As of November 2026, five EPR regimes run by the Central Pollution Control Board (CPCB) can apply to an importer:
- E-waste: electrical and electronic equipment (EEE) listed in Schedule I of the E-Waste (Management) Rules, 2022.
- Batteries: any battery you import, on its own or inside equipment, under the Battery Waste Management Rules, 2022.
- Plastic packaging: the plastic packaging of goods you import, under the Plastic Waste Management Rules, 2016.
- Waste tyres: new tyres for sale and vehicles fitted with new tyres, under Schedule IX of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
- Used oil: base oil or lubricating oil you import and sell, under Chapter VII of the same Hazardous and Other Wastes Rules.
The short answer for an importer of heavy machinery
Schedule I of the E-Waste Rules covers "Electrical and Electronic Tools (With the exception of large-Scale Stationary Industrial Tools)". A large stationary industrial machine is therefore outside the e-waste tools category. Schedule I has no category named for industrial machinery, but a few entries in other categories are worded broadly, so compare your machine's description with the full list (see the E-waste section).
A machinery import can still need EPR registration if:
- the machine contains a battery, even if you import it only for your own plant;
- it arrives in plastic packaging, such as plastic film or wrap;
- it is a vehicle fitted with new tyres; or
- the shipment also contains Schedule I items that you sell, such as electrical tools, UPS units, inverters or display panels.
Check each shipment against the table in the next section before it leaves the supplier.
Which EPR Applies to What You Import
| What you import | EPR that can apply | Rule | CPCB portal |
|---|---|---|---|
| A machine that is a large-scale stationary industrial tool, with no battery, no plastic packaging and no tyres | None of the five regimes, on these facts | E-Waste (Management) Rules, 2022, Schedule I, category (iv), which excludes large-scale stationary industrial tools | Not applicable |
| Electrical and electronic tools: drills, saws, sewing machines, equipment for turning, milling, sanding, grinding, sawing, cutting, shearing, drilling, punching, folding or bending wood, metal and other materials, tools for riveting, nailing or screwing, tools for welding or soldering, spraying equipment, and mowing or gardening tools (codes EETW1 to EETW8) | E-waste EPR | E-Waste (Management) Rules, 2022, Schedule I, category (iv) | eprewaste.cpcb.gov.in |
| Other Schedule I equipment shipped with a machine or in the same consignment, for example UPS (ITEW24), inverters (ITEW25), monitors and display panels (CEEW6, LSEEW34) or laboratory equipment having electrical and electronic components (LIW2), and their components, parts and spares | E-waste EPR, if you offer them for sale | E-Waste Rules, rules 2 and 3(1)(t), Schedule I | eprewaste.cpcb.gov.in |
| Used (second-hand) electrical and electronic equipment | E-waste EPR | E-Waste Rules, rule 3(1)(t)(iv) | eprewaste.cpcb.gov.in |
| Batteries, on their own or inside equipment (portable, automotive, industrial or electric vehicle batteries) | Battery EPR, including batteries put to self-use | Battery Waste Management Rules, 2022, rules 3(1)(u)(iii) and 4(1), as amended on 25 October 2023 | eprbattery.cpcb.gov.in |
| Any goods imported for commercial use that arrive in plastic packaging | Plastic packaging EPR, as an importer | Plastic Waste Management Rules, 2016, rule 3(k) and Schedule II, paragraph 4(b), as amended on 14 March 2024 | eprplastic.cpcb.gov.in |
| Vehicles fitted with new tyres, or new tyres that you sell | Waste tyre EPR | Hazardous and Other Wastes Rules, 2016, Schedule IX, paragraph 1(e) | eprtyres.cpcb.gov.in |
| Base oil or lubricating oil that you sell in India | Used oil EPR | Hazardous and Other Wastes Rules, 2016, rule 25(k) | eprusedoil.cpcb.gov.in |
If more than one row applies, you need a registration under each regime. Each regime has its own CPCB portal.
E-Waste EPR: What Schedule I Says About Tools and Industrial Machinery
The E-Waste (Management) Rules, 2022 (G.S.R. 801(E), 2 November 2022, in force from 1 April 2023) apply to equipment "listed in Schedule I, including their components, consumables, parts and spares which make the product operational" (rule 2).
Schedule I has seven categories: (i) information technology and telecommunication equipment; (ii) consumer electrical and electronics and photovoltaic panels; (iii) large and small electrical and electronic equipment; (iv) electrical and electronic tools; (v) toys, leisure and sports equipment; (vi) medical devices; and (vii) laboratory instruments.
Category (iv): electrical and electronic tools
The heading reads "Electrical and Electronic Tools (With the exception of large-Scale Stationary Industrial Tools)". It lists:
- EETW1: Drills
- EETW2: Saws
- EETW3: Sewing Machines
- EETW4: Equipment for turning, milling, sanding, grinding, sawing, cutting, shearing, drilling, making holes, punching, folding, bending or similar processing of wood, metal and other materials
- EETW5: Tools for riveting, nailing or screwing or removing rivets, nails, screws or similar uses
- EETW6: Tools for welding, soldering, or similar use
- EETW7: Equipment for spraying, spreading, dispersing or other treatment of liquid or gaseous substance by other means
- EETW8: Tools for mowing or other gardening activities
What this means for industrial machinery
- Large-scale stationary industrial tools are excluded from category (iv). The Rules do not define the term.
- No Schedule I category is named for industrial machinery, but some entries in category (iii) are worded broadly, for example "Appliances used for sewing, knitting, weaving and other processing for textiles" (LSEEW19), "Grinders, coffee machines and equipment for opening or sealing containers or packages" (LSEEW21) and "Other fanning, exhaust ventilation and conditioning equipment" (LSEEW15). Category (vii) includes laboratory "Equipment having electrical and electronic components" (LIW2). Compare your machine's description with the full Schedule.
- Electrical tools of the kinds listed above are covered when they are not large-scale stationary industrial tools.
- Schedule I items that travel with a machine, such as UPS units, inverters or display panels, are covered in their own right.
- If you are not sure whether your machine is a "large-scale stationary industrial tool", get CPCB's view before you import.
Who is a producer
Rule 3(1)(t) defines a producer to include any person who "offers to sell imported electrical and electronic equipment and their components or consumables or parts or spares", and any person "who imports used electrical and electronic equipment", whatever the selling method.
The Rules do not say expressly how they treat listed equipment imported only for your own use. If that is your case, confirm the position with CPCB before import.
Other points
- Under rule 2, the Rules do not apply to waste batteries (covered by the Battery Waste Management Rules, 2022), packaging plastics (covered by the Plastic Waste Management Rules, 2016) or a micro enterprise as defined in the Micro, Small and Medium Enterprises Development Act, 2006.
- Imports of new electrical and electronic equipment are permitted only if it meets the hazardous-substance limits in rule 16 (rule 16(6)). The producer gives a self-declaration of compliance (rule 16(8)).
- The amendments of 30 January 2023 (G.S.R. 61(E)), 24 July 2023 (G.S.R. 534(E)) and 8 March 2024 (G.S.R. 164(E)) did not change rule 2 or Schedule I.
For registration as an e-waste producer, see EPR E-Waste Registration for Importers.
Battery EPR: Batteries Inside Imported Equipment
The Battery Waste Management Rules, 2022 (S.O. 3984(E), 22 August 2022) apply to "all types of batteries regardless of chemistry, shape, volume, weight, material composition and use" (rule 2(1)).
Since the amendment of 25 October 2023 (S.O. 4669(E)), a producer includes an entity engaged in "import of Battery or equipment containing Battery" (rule 3(1)(u)(iii)). The EPR obligation covers "the Battery that they introduce in the market and the Battery which they put to self-use" (rule 4(1)).
So a machinery importer becomes a battery producer when the machine contains a battery, even if the machine is for its own plant. CPCB's producer SOP on the battery portal lists "Importer importing equipment containing battery for self-use" as a producer category.
The Rules define four types of battery: portable, automotive, industrial and electric vehicle. They do not apply to batteries used in equipment connected with essential security interests, including arms and equipment intended specifically for military purposes, or in equipment designed to be sent into space (rule 2(2)).
Registration
- "Every Producer shall obtain registration from the Central Pollution Control Board through online centralised portal in Form 1(A)" (rule 4(4), as substituted in 2023).
- CPCB's FAQ on the battery portal says: "The Importer has to obtain registration from CPCB to carry out import activities related to battery."
- Registration is to be done within two weeks of a completed application. If CPCB does not refuse it within that period, it is deemed done (rule 11(3), as amended in 2023).
For registration, see EPR Battery Registration for Importers.
Plastic Packaging EPR: Importers of Packaged Goods
Under the Plastic Waste Management Rules, 2016, as amended on 14 March 2024 (G.S.R. 201(E)), an importer is "a person who imports for commercial use, any plastic packaging or any commodity with plastic packaging" or other plastic material listed in rule 3(k).
The EPR Guidelines for plastic packaging (Schedule II, paragraph 4) list the entities with EPR obligations. They include an "Importer of plastic packaging including intermediate material used for manufacturing plastic packaging such as films and preforms and plastic packaging of imported products".
Paragraph 4 excludes micro and small enterprises only from the producer and brand-owner entries. The importer entry has no such exclusion.
So if you import goods for commercial use and they arrive in plastic packaging, you are an importer for plastic packaging EPR, whatever the size of your business.
Registration
- Importers must register on CPCB's centralised portal (Schedule II, paragraph 6.1). "The entities covered under clause 6.1 shall not carry any business without registration obtained through on-line centralized portal" (paragraph 6.2).
- The application is made once, in Form I, through the centralised portal. It goes to the State Pollution Control Board if you operate in one or two States or Union territories, and to CPCB if you operate in more than two (rule 13(2), as substituted by G.S.R. 807(E), 30 October 2023).
- If registration is not granted within thirty days of an application complete in all respects, you are deemed registered (rule 13(8), as substituted in 2024).
For registration, see EPR Plastic Registration for Importers.
Waste Tyre and Used Oil EPR
Waste tyres
Schedule IX of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, inserted on 21 July 2022 (G.S.R. 593(E)), defines a producer to include any person who "sells imported new tyre" or "imports vehicles fitted with new tyres" (paragraph 1(e)).
Schedule IX does not mention machinery or equipment and does not define "vehicle". If what you import runs on its own new tyres, for example a wheeled self-propelled machine, check with CPCB before import. A machine without tyres is not covered.
Registration is on CPCB's waste tyre EPR portal. "No entity shall carry out any business without registration" (paragraph 3(2)), and "business" includes "import of vehicle fitted with new tyre" (paragraph 1(a)).
Used oil
Chapter VII of the same Rules, inserted on 18 September 2023 (G.S.R. 677(E)) and in force from 1 April 2024, defines a producer to include any person who "offers to sell imported base oil or lubrication oil domestically" (rule 25(k)).
Oil that arrives inside a machine you import for your own use is not mentioned in this definition. CPCB's used oil FAQ says that a car OEM does not become a producer unless it procures base oil or lubrication oil and sells lubrication oil in India under its own brand.
If you import lubricating oil to sell, register on CPCB's used oil EPR portal. "No entity referred in sub-rule (1) shall carry out business without registration" (rule 26(3)).
Register Before You Import, and What Customs May Check
Register first
- E-waste: "No entity referred in sub-rule (1) shall carry out any business without registration" (rule 4(3)), and "business" includes "import of electrical and electronic equipment as listed in Schedule I" (rule 3(1)(c)).
- Battery: producers, including importers, register in Form 1(A) on CPCB's portal (rule 4(4)). CPCB's FAQ says the importer has to register "to carry out import activities related to battery".
- Plastic packaging: no business without registration (Schedule II, paragraph 6.2).
- Waste tyres: no business without registration (Schedule IX, paragraph 3(2)).
- Used oil: no business without registration (rule 26(3)).
All five registrations are made online on CPCB's centralised EPR portals. CPCB grants them, except that for plastic packaging the State Pollution Control Board registers you if you operate in only one or two States or Union territories.
What customs may check
- E-waste: Schedule V of the E-Waste Rules makes the port authority and the customs authority responsible to "Verify the import or export with respect to Extended Producer Responsibility under these rules", inform CPCB of any illegal traffic and take action against importers for violations.
- Batteries: on 23 December 2022 CPCB asked the Central Board of Indirect Taxes and Customs to instruct customs officials to verify the registration certificate issued by CPCB when clearing consignments of battery importers. The letter's subject covers import of battery as well as equipment containing battery.
- Base oil and lubricating oil: on 2 July 2024 CPCB asked customs to clear import consignments of base oil or lubrication oil on production of the CPCB registration certificate or proof of an application on the used oil EPR portal.
Keep your EPR registration certificate with your import documents.
Documents for EPR Registration as an Importer
Each portal has its own list. These are the items CPCB's e-waste producer SOP (April 2023) and battery FAQ ask for:
- Company PAN, GST registration, and CIN or incorporation certificate (if available). The battery FAQ lists PAN, CIN and GST for KYC.
- Import Export Code (IEC), if available (e-waste SOP).
- PAN of the authorised person, and the address from which sales across the country are managed.
- The list of products you place on the market or import: EEE codes from Schedule I, battery types, or plastic packaging categories.
- Quantity imported or sold in each financial year, in tonnes. For e-waste, a CA certificate (statutory auditor or independent chartered accountant) certifying the quantity sold or imported.
- A covering letter and self-declarations on company letterhead. For e-waste these include a declaration of compliance with the hazardous-substance limits and a declaration that technical documents as per EN 50581 are available.
- For e-waste, the producer's awareness plan.
The address on the IEC, GST certificate and declarations should match the address you give on the portal (e-waste SOP).
Fees and Timelines (Official Only)
E-waste producer registration fee
CPCB's fee structure under the E-Waste (Management) Rules, 2022 (signed 23 November 2023) sets the producer registration fee by annual e-waste recycling target:
| Annual recycling target | Registration fee (Rs.) |
|---|---|
| Below 50 MT | 2,500 |
| 50 MT to below 100 MT | 7,500 |
| 100 MT to below 1,000 MT | 1,50,000 |
| 1,000 MT to below 5,000 MT | 10,00,000 |
| Above 5,000 MT | 15,00,000 |
| Producers whose sales have just started | 10,000 |
The same document sets annual maintenance charges of Rs. 5,000 for producers. E-waste producer registration is valid for five years, and renewal is applied for 120 days before expiry (CPCB producer SOP).
Other regimes
For battery, plastic packaging, waste tyre and used oil registration, the fee is the one shown on the CPCB portal when you apply.
Time
- E-waste: CPCB communicates shortcomings within 25 working days and issues registration within 30 working days of a complete application (CPCB producer SOP).
- Battery: within two weeks of a completed application, after which registration is deemed done if not refused (rule 11(3)).
- Plastic packaging: deemed registration if not granted within thirty days of a complete application (rule 13(8)).
- Waste tyres and used oil: the time depends on CPCB's scrutiny of your application.
Why Corpseed
Corpseed checks what you import against each EPR regime, tells you which CPCB portals apply, and prepares and files your registrations. CPCB or the State Pollution Control Board grants the registration. We can also help with the returns that follow.
Connect With Corpseed
Connect with the Corpseed team to discuss your requirements at IVR: 7558640644 or hello@corpseed.com. It takes 20–25 minutes to discuss the requirement.
Dedicated Manager
Once you discuss the requirement, we will align a dedicated Account Manager to understand your business needs and assist throughout the process.
Real Time Update
Track the progress of your application and always know what’s in progress and what’s done.
Job Completed
Once the job is completed, you will receive registrations & certifications directly to your email ID and at your doorstep.
Frequently Asked Questions
Quick answers to common questions about this service.
Does EPR apply if I only import heavy machinery?
Not for the machine itself, if it is a large-scale stationary industrial tool: Schedule I of the E-Waste (Management) Rules, 2022 lists "Electrical and Electronic Tools (With the exception of large-Scale Stationary Industrial Tools)" and has no category named for industrial machinery. Check that your machine does not match one of the broadly worded entries elsewhere in Schedule I.
EPR can still apply to what comes with it. Batteries inside imported equipment make you a producer under the Battery Waste Management Rules, 2022, even for self-use, and plastic packaging of imported products makes you an importer under the plastic packaging EPR.
Is industrial machinery covered under the E-Waste Rules, 2022?
Schedule I covers electrical and electronic tools such as drills, saws, welding tools and equipment for turning, milling, grinding, cutting or bending metal (codes EETW1 to EETW8), but not "large-Scale Stationary Industrial Tools".
The Rules do not define that term, and a few entries in other categories are worded broadly (for example appliances for processing textiles, or equipment for opening or sealing containers or packages). If your machine is a borderline case, get CPCB's view before import.
My imported machine has a battery inside. Do I need battery EPR registration?
Yes. Since the 2023 amendment, a producer includes anyone engaged in "import of Battery or equipment containing Battery" (rule 3(1)(u)(iii)), and the EPR obligation covers batteries put to self-use (rule 4(1)). Register on CPCB's battery EPR portal in Form 1(A).
I import machinery for my own factory, not for sale. Does EPR still apply?
- Battery: yes. Batteries in equipment imported for self-use are covered.
- Plastic packaging: the importer definition covers imports "for commercial use" of any commodity with plastic packaging.
- E-waste: the producer definition speaks of a person who "offers to sell imported" equipment. The Rules do not say expressly how they treat own-use imports, so confirm with CPCB before import.
Does plastic packaging on imported machinery need EPR registration?
The EPR Guidelines for plastic packaging cover an "Importer of plastic packaging including intermediate material used for manufacturing plastic packaging such as films and preforms and plastic packaging of imported products". The micro and small enterprise exclusion does not apply to importers.
Register through CPCB's centralised plastic EPR portal before you carry on business.
Do I need EPR registration before the goods reach Indian customs?
Yes, where a regime applies. Each set of rules bars carrying on business without registration, and for e-waste "business" expressly includes import. Schedule V of the E-Waste Rules asks customs to verify imports with respect to EPR, and CPCB has asked customs to verify CPCB registration for battery imports and for base and lubricating oil imports.
Does waste tyre EPR apply to imported machinery?
Schedule IX of the Hazardous and Other Wastes Rules covers anyone who "sells imported new tyre" or "imports vehicles fitted with new tyres". It does not mention machinery and does not define "vehicle". If your machine runs on its own new tyres, check with CPCB before import.
Does used oil EPR apply to oil inside imported machines?
The producer definition covers a person who "offers to sell imported base oil or lubrication oil domestically". Oil inside a machine you import for your own use is not mentioned. If you import lubricating oil to sell, you need registration on CPCB's used oil EPR portal.
Which CPCB portal do I use for each EPR registration?
- E-waste: eprewaste.cpcb.gov.in
- Battery: eprbattery.cpcb.gov.in
- Plastic packaging: eprplastic.cpcb.gov.in
- Waste tyres: eprtyres.cpcb.gov.in
- Used oil: eprusedoil.cpcb.gov.in
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