India's Ministry of Environment, Forest and Climate Change has published a draft amendment to the Plastic Waste Management Rules (2022) introducing automatic mandatory EPR certificate purchase requirements for Producers, Importers, and Brand Owners (PIBOs) who miss their annual plastic waste collection and processing targets by more than 20 percent. The amendment, currently open for a 60-day public consultation period, represents the most significant tightening of India's EPR framework since the 2022 revision and brings plastic credits — in the form of EPR certificates issued by registered waste processors — more firmly into the compliance mechanism.
What the amendment introduces
Under the current framework, PIBOs who miss their targets receive a liability notice from the Central Pollution Control Board (CPCB) requiring remediation within a defined period — a process that has produced inconsistent enforcement and limited deterrence. The proposed amendment replaces the discretionary liability notice with an automatic obligation: PIBOs whose annual EPR returns reveal a shortfall greater than 20 percent of their target must purchase EPR certificates from registered plastic waste processors equal to the shortfall volume within 90 days of the return filing date, with no discretionary extension available. EPR certificates are generated by organisations — including rePurpose Global's Indian operations, Recykal, and Hulladek Recycling — that collect and process plastic waste in CPCB-registered facilities. The automatic purchase requirement creates a mandatory demand floor for EPR certificates in the Indian market, with direct implications for credit pricing: if mandatory purchases from non-compliant PIBOs layer on top of existing voluntary credit demand, the combined demand signal could push Indian EPR certificate prices above current levels of INR 800 to 1,500 per tonne for rigid plastic.
Implications for project developers
For plastic credit project developers operating in India, the amendment represents a potential revenue diversification opportunity: projects that already generate Verra PWRS credits for voluntary market buyers may also be eligible to generate CPCB-registered EPR certificates for compliance buyers, provided they meet CPCB registration requirements. Developers currently pursuing single-revenue-stream credit programmes should assess whether dual registration is operationally feasible given the data and reporting requirements of each system.