Extended Producer Responsibility in India: Assessing the Progress of the Circular Economy Transition

Policy Update
Tanvi Nerurkar

Introduction

As India’s economy grows, managing waste is becoming more difficult. Urbanisation, higher consumption, greater e-commerce, and the increased use of electronics have changed the amount and type of waste produced. Plastic packaging, e-waste, and used batteries are growing quickly, creating environmental and health problems that traditional waste systems can’t keep up with.

In the past, India managed waste in a linear way: products were made, used, and then thrown away. Local governments were mostly in charge, but many lacked the resources or infrastructure to handle the growing volume of waste. As a result, landfills grew, useful materials were lost, and pollution got worse.

The circular economy takes a different approach. Instead of seeing waste as the end of a product’s life, it tries to keep materials in use as long as possible by reusing, repairing, recycling, and recovering them. Extended Producer Responsibility (EPR) is key to this shift, moving the responsibility for waste from local governments to the companies that make and sell products.

In the past decade, India has increasingly incorporated EPR into regulations for plastic packaging, electronic waste, and batteries. Over the last ten years, India has added EPR rules for plastic packaging, e-waste, and batteries. These changes have reshaped how the country manages waste, aiming to make producers more accountable, boost recycling, and protect natural resources. Still, it’s worth asking: Is EPR really speeding up India’s move to a circular economy, or is it just making small improvements in waste management?

Functionality: Understanding Extended Producer Responsibility 

Extended Producer Responsibility is built on a simple idea: producers should stay responsible for their products even after people have bought and used them.

Traditionally, manufacturers generated profits from their products, while municipalities and taxpayers bore the cost of managing the waste. EPR changes this by making producers, importers, and brand owners pay for or manage the collection, recycling, and recovery of their products when they are no longer useful. However, EPR is not merely a waste management tool. Its broader purpose is to influence product design and business decisions. When producers become financially responsible for managing waste, they gain an incentive to reduce packaging, improve recyclability, increase product longevity, and invest in recovery systems. In short, EPR aims to turn waste from a problem into a valuable resource.

How India’s EPR Rules Have Evolved

India’s EPR rules have grown over time, covering more types of waste as policymakers see the need to manage waste throughout a product’s life.

Plastic Packaging: The Largest Waste Stream

The Plastic Waste Management Rules, which began in 2016 and were later updated, established one of India’s first major EPR systems. These rules require producers, importers, and brand owners to collect and process plastic packaging waste from their products. The challenge is huge.

Table 1: Plastic Waste Indicators (2022–23)

At first glance, a recycling rate of almost 60 % looks good. But 1.65 million tonnes of plastic still escape formal recycling. For every three kilograms of plastic used, about one kilogram still ends up in landfills, is burned in the open, or leaks into nature. Our important concern is the growth in plastic consumption itself. Per-capita plastic waste generation increased from approximately 700 grams in 2016-17 to more than 2.5 kilograms by 2020. This suggests that while recycling capacity is improving, waste generation is expanding rapidly, creating a moving target for policymakers and recyclers alike.

A major step forward was the launch of the Central Pollution Control Board’s digital EPR portal and certificate-trading system. Companies can set up their own collection systems or buy EPR certificates from approved recyclers. This market-based system gives companies flexibility and encourages investment in recycling.

Still, there is a gap between what companies say they will do and the certificates they actually issue, indicating that compliance is incomplete and that enforcement still needs work. (Central Pollution Control Board [CPCB], 2023) 

India’s rapidly expanding digital economy has changed how people live, but it has also created one of the world’s fastest-growing streams of electronic waste. Refrigerators and televisions, electronic products are being replaced more frequently than ever before. Consequently, e-waste generation has surged dramatically over the last few years.

Electronic Waste: The Digital Economy’s Hidden Challenge

Table 2: E-waste generation indicators

The rise in formal recycling rates is a good sign. In just four years, India’s official recycling rate almost doubled, showing that EPR rules and better recycling systems are starting to make a difference.

However, these gains must be seen in context. More than half of India’s e-waste is still handled outside the formal system. Almost one million tonnes are processed informally, often in unsafe conditions and without proper environmental protections. Important reality: India’s challenge is not simply one of technology or regulation but also of social and economic integration. Informal waste collectors and aggregators continue to perform collection functions that formal systems have yet to fully replicate.

Recent E-Waste Management Rules have set stricter collection targets, introduced digital tracking, and made registration mandatory for producers and recyclers. These steps make things more transparent, but their long-term success depends on bringing informal networks into the formal system. (CPCB, 2024) 

Batteries

One of the most future-focused parts of India’s EPR system is the Battery Waste Management Rules, which started in 2022.

The timing is significant. India’s electric mobility ambitions are expected to drive battery demand from approximately 4 GWh in 2023 to nearly 139 GWh by 2035. While this transition is critical for decarbonization, it will also generate a substantial volume of spent batteries containing valuable materials such as lithium, cobalt, nickel, and lead. As of 2022, lithium-ion batteries already accounted for about 700,000 tonnes of India’s total 1.6 million tonnes of e-waste.

Recognising this challenge, the rules establish progressive recovery targets (Government of India, 2022a):

Table 3: Material recovery targets of Li-ion Batteries

For EV batteries specifically, collection targets require producers to recover 70 % of batteries placed in the market by 2027–28, and from 2027–28 the rules also require a minimum share of recycled material, starting at 5 % and rising to 20 % by 2030–31. As with the plastics framework, the battery rules rely on a certificate-based system, where producers must meet recycling obligations through registered recyclers. Even here, though, informal recycling is estimated to handle a large share, roughly 80 % by some CPCB-linked estimates, of India’s battery waste, underlining how far formalization still has to go.

Performance: What EPR Has Achieved So Far?

India’s EPR framework has produced some genuine progress, even if the picture remains mixed.

A More Organized Recycling Market

Perhaps the clearest achievement has been the formalization of recycling activity. Before EPR, much of India’s recycling happened informally, with little regulation, oversight, or consistency. The introduction of EPR rules has increased demand for certified recyclers and properly equipped processing facilities. The tradable EPR certificate system, in particular, has created a genuine financial incentive to invest in recycling infrastructure, since certificates themselves now carry market value.

Producers Are More Accountable

For a long time, the cost of managing waste fell almost entirely on local governments, many of which were already stretched thin. EPR has begun to shift part of that financial and operational burden onto the companies that create the waste in the first place. As a result, many businesses are now factoring sustainability into how they design products, manage supply chains, and plan their operations, rather than treating it as someone else’s concern.

Better Data and Transparency

The rollout of centralized digital portals has made it easier to track what is happening across the system. Producers, recyclers, and waste processors are now required to register and report their activities, which has generated far more reliable data on how much waste is being generated, collected, and recycled. This is a meaningful improvement over the patchy, fragmented reporting that existed before, and it gives regulators a much better basis for monitoring compliance.

Recovering Valuable Materials

EPR has also encouraged the recovery of materials that can be reused in manufacturing. Recycled plastics, metals from electronics, and materials recovered from batteries are increasingly being fed back into production processes. This reduces the need to extract virgin raw materials and is a direct, tangible step toward the resource efficiency that circular economy thinking is built around.

Progress versus Reality

Even with these achievements, there are still big gaps between what policies aim for and what actually happens.

Table 4: Current status of India’s circular economy

This contrast illustrates a broader pattern within India’s circular economy transition, regulatory frameworks are evolving faster than supporting systems. (Kaza et al., 2018; World Bank, 2022) 

Challenges Holding EPR Back

Despite this progress, several persistent problems continue to limit how effective India’s EPR framework really is.

Free Riders and Compliance Gaps

A significant number of producers, particularly smaller businesses and informal market players, still operate outside the formal EPR system altogether. They avoid registering, avoid reporting, and avoid meeting their obligations, all while their compliant competitors bear the costs of doing things properly. This unevenness not only undermines the overall effectiveness of EPR but also creates an unfair playing field that discourages full participation.

Industry experts are increasingly worried that some parts of the EPR system focus too much on paperwork and trading certificates rather than on actually recovering materials.

Too Much Reliance on Paper Compliance

There have been reports of fake certificates and incorrect reporting, casting doubt on the authenticity of recycling claims. If following the rules is not linked to real recycling, the whole system’s credibility could suffer.

The Informal Sector Remains Outside the Framework

India’s recycling has long relied on millions of informal waste pickers, aggregators, and scrap dealers. Yet, despite their key role, most EPR systems still operate separately from these informal networks. Leaving out informal workers makes the system less efficient and raises fairness issues, since they have always been important for resource recovery.

Big cities have seen significant investment in collection and recycling, but smaller cities and rural areas still lack these facilities. Without sufficient collection, sorting, and processing facilities, EPR targets may end up as numbers on paper rather than real results.

Weak Monitoring Capacity

It is a huge challenge to monitor thousands of producers, recyclers, and waste processors across such a large and diverse country. Regulatory agencies often lack sufficient staff, technical resources, or auditing tools. Without strong checks and steady enforcement, gaps in compliance are likely to continue.

Impact

Reality Check: Is India Truly Becoming Circular?

The answer is a bit of both. India has clearly made progress in waste management and recycling. Formal recycling markets are growing, producers are more accountable, and resource recovery is better organised. But a true circular economy needs more than just better waste collection and recycling

Most EPR systems today focus on dealing with waste after it’s generated, not on preventing it before it’s produced. Product design, repair, durability, and reuse are still not strong parts of the circular economy plan. Often, producers still see EPR mainly as a rule to follow, rather than as an opportunity to innovate or use resources more efficiently.

So, India is improving its waste management, but it hasn’t yet changed how products are made and used in a significant way.

What India Can Learn from Other Countries

India is not the first country to try to build a circular economy around EPR, and there are useful lessons from places that have gone further down this road. (OECD, 2016) 

Table 5: Comparative case study of global scenarios as opposed to India

But India’s situation is very different from these countries. European EPR systems were built on strong local collection networks and good recycling infrastructure. India, on the other hand, is trying to set up producer responsibility while also building basic waste management systems.

This means India’s path to circularity cannot simply replicate international models. Instead, it must develop a uniquely Indian approach that recognises and integrates the informal sector while strengthening formal infrastructure.

Wayforward: Priorities for the Road Ahead

For EPR to become a transformative force rather than a compliance mechanism, several priorities require attention:

• Strengthen enforcement against non-compliant producers and free riders.
• Improve traceability and verification systems to eliminate fraudulent reporting.
• Integrate informal waste workers into formal collection and recycling networks.
• Expand recycling infrastructure in smaller cities and rural regions.
• Encourage manufacturers to adopt eco-design principles.
• Increase public awareness regarding waste segregation and responsible disposal.
• Create stronger market incentives for the use of recycled materials.

Together, these steps can help connect production, use, recovery, and reuse in a full circle.

Conclusion

Extended Producer Responsibility (EPR) has become a cornerstone of India’s circular economy transition. Over the past decade, the country has moved from a fragmented, largely city-led waste management system towards one with greater producer accountability, formal recycling markets, and improved resource recovery.

While significant progress has been made, challenges such as weak enforcement, compliance gaps, inadequate infrastructure, and the limited integration of informal workers continue to hinder its full potential. The next phase must focus on strengthening implementation, improving transparency, expanding recycling infrastructure, and prioritising waste prevention alongside waste management.

Ultimately, the success of EPR will be measured not only by how much waste is recycled, but by how effectively India keeps materials in use, reduces dependence on virgin resources, and decouples economic growth from resource consumption. If implemented effectively, EPR can evolve from a regulatory requirement into a key driver of a truly circular and resource-efficient economy.

About the Contributor

Tanvi Nerurkar is currently working as a Research & Editorial Intern at IMPRI. She holds a Bachelor’s degree in Architecture from VESCOA, University of Mumbai and is presently pursuing a Master’s in Urban Management at CEPT University, where she explores cities through research-driven policy approaches, adaptive governance frameworks, and sustainable development initiatives. Her objective is to contribute implementation-oriented policy research that supports the efficient functioning of cities and creates meaningful value for society at large.

Acknowledgement 

The author extends her sincere gratitude to Paridhi Passi, Asmatwali, and the IMPRI team for their invaluable guidance throughout the process. The author acknowledges data from the Reserve Bank of India’s Report on Municipal Finances (2024), Janaagraha’s urban governance research, and World Bank and OECD comparative tax studies.

Disclaimer: All views expressed in the article belong solely to the author and not necessarily to the organisation.

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This article was posted by Pallavi Lad, a Research and Editorial Intern at IMPRI.