EPR Credits in India: Growth, Risks, and Regulatory Action
Extended Producer Responsibility (EPR) credits were created to hold producers accountable for the end-of-life management of plastic packaging placed on the market. Much of the recent growth has been driven by regulatory mandates that require companies to include recycled plastic in packaging. As a result, demand for credits has risen sharply.
Today, these credits function as a tradable commodity, pushed forward by mandatory recycled-content targets. However, the market’s rapid expansion has also revealed major integrity gaps. While trading has generated new economic opportunities, recent investigations and government audits show that it carries serious risks. In particular, the system’s dependence on self-reported data and certificates has left space for large-scale fraud, weakening both environmental outcomes and overall market credibility.
EPR credit market growth
The Indian recycled plastics market was valued at about USD 4.24 billion in 2024. It is projected to reach USD 6.52 billion by 2033, growing at a CAGR of 4.64% (IMARC Group). The plastics recycling services sector—covering both mechanical and chemical recycling—stood at USD 747.8 million in 2024. Forecasts suggest it could reach USD 1.67 billion by 2030, expanding at nearly 14.5% annually (Grand View Research).
Recycling volumes also show a sharp upward trend. Plastic waste processed is expected to rise from 10.9 million tons in 2024 to 25.4 million tons by 2033 (IMARC Group). Equally important, the plastic credit market is set to grow by nearly 70%. Its value could increase from USD 982 million in 2024 to USD 1.67 billion by 2030, highlighting its role as a compliance-driven financial mechanism (Economic Times).
Together, these figures show how regulatory pressure, compliance needs, and demand for recycled content are driving the rapid expansion of India’s EPR credit ecosystem.
Risk: Fraud and misuse
- Ghost plants
Independent investigations into e-waste and plastic recycling uncovered many registered units that either did not exist at the declared address or lacked active operations. One probe found that 31 of 41 government-approved e-waste plants across states were “ghost” facilities. Though authorised to process hundreds of thousands of tonnes and generate credits worth crores, field visits showed idle chimneys, inactive yards, and depots doubling as truck stops. These findings reveal how credits can be issued without actual waste processing.
- Fake invoices
Audits exposed recyclers uploading invoices, photos, and transport records that did not match real activity. Cases included bills for volumes beyond plant capacity, staged photographs simulating processing, and repeated truck trips to nearby weighbridges used only to generate paperwork. Government audit teams and investigative journalists flagged these discrepancies by cross-checking facility capacity, on-site activity, and submitted records.
- Mass over-reporting
A Central Pollution Control Board (CPCB) audit revealed nearly 6 lakh fake EPR or pollution-trading certificates issued without legal compliance. CPCB directed state boards to levy environmental compensation and re-inspect facilities. The National Green Tribunal (NGT) also issued notices to CPCB and the Environment Ministry, demanding recovery and accountability. The scale of this discovery underscores the systemic risk of unchecked credit issuance.
- Fake Certificates
The Centre for Science and Environment (CSE) reported about 70,000 suspect certificates and noted that several major polluters were missing from compliance records. Its review highlighted registry loopholes and weak verification mechanisms that allowed manipulation, leaving many producers effectively outside enforcement reach.
- Burn and earn loopholes in co-processing
Civil society reports also highlight how plastics sent to co-processing or waste-to-energy are often counted as recycled. This practice allows credits to be issued despite no real material recovery. Instead of promoting circularity, it risks legitimising burning, which has harmful environmental and public health consequences.
Regulatory Action: Measures for Strengthening EPR Compliance
- Verified credits
For EPR credits to hold real value, they must be backed by strong verification. This means establishing a clear chain of custody, reconciling invoices, and ensuring payments to beneficiaries are properly documented. Credits should only be issued when validated by accredited auditors.
- Strict Audits
Beyond paperwork, audits must involve physical inspections and capacity checks. Regulators need to confirm that recyclers’ declared operations and processing capacities actually exist and function as reported before credits are granted or accepted.
- IT analytics and portal strengthening
The national portal should be equipped with advanced analytics to flag irregularities such as sudden spikes in recycling claims, repeated use of the same transport IDs, or mismatches between reported volumes and geographic data. Strengthening these systems with tamper-proof logs and anomaly detection will help prevent manipulation and ensure that all reporting remains accurate, traceable, and verifiable.
- Enforcement: fines, suspension and deregistration
Strong enforcement is essential to deter malpractice. Environmental compensation or fines should be imposed in proportion to the number of fake or non-compliant certificates, while repeat offenders must face suspension or deregistration. Such measures reinforce accountability and ensure that fraudulent actors cannot undermine the credibility of the EPR framework.
Conclusion
India’s EPR credit market is expanding quickly, but credibility remains its biggest hurdle. Regulatory mandates have created strong demand. However, widespread fraud—from ghost plants to fake certificates—shows how easily paper compliance can hide inaction on the ground.
Recent action by the CPCB, NGT, and Parliament is an important first step. Even so, lasting trust will require strict audits, physical checks, digital traceability, and clear penalties for violators. If these safeguards are applied with consistency, EPR credits can shift from a loophole-ridden paperwork exercise into a reliable tool. They can then drive genuine recycling and support grassroots waste recovery.
How Envirosense Can Help You Navigate EPR Compliance
At Envirosense, we offer comprehensive EPR solutions tailored to businesses across various industries.
Our services include:
✔ EPR Registration Assistance – Helping you register with CPCB and SPCB.
✔ Compliance Monitoring – Ensuring you meet annual targets and reporting requirements.
✔ EPR Certificate Procurement – Assisting with obtaining and managing EPR credits.
✔ Recycling & Waste Management Solutions – Connecting you with certified waste processors.
Let us help you achieve EPR compliance seamlessly!
📧 Email: mail@envirosense.in
📞 Phone: +91 9667152500
