Do small online sellers need plastic EPR registration in 2027?

Sellers ask us about EPR registration more and more. Usually the question comes after a consultant's cold call, and usually with some panic.

The short answer is good news for most small sellers. If your business sells under its own brand and is a micro or small enterprise, India's plastic EPR rules have not put brand-owner obligations on you since 14 March 2024. Nothing in the 2026 amendment changed that. There are two big catches. Importers are covered at any size, and a business that grows past the "small" limits is covered again.

We make the packaging these rules talk about, so we read every notification ourselves.

I am not a lawyer, and I cannot tell any particular business that it is exempt. What I can do is show you where the rule sits, so you and your CA can check it in ten minutes.

Checked against official sources on 28 October 2026.

What changed in 2024 and 2025?

Two notifications, one year apart, decide this question for most small sellers.

1. On 14 March 2024, the Ministry of Environment rewrote the list of who is covered by plastic packaging EPR (Schedule II, paragraph 4 of the Plastic Waste Management Rules). Brand owners are covered, other than micro and small enterprises. Producers of plastic packaging get a similar carve-out. All importers stay covered. You can read the consolidated rules yourself.
2. From 1 April 2025, the Ministry of MSME raised the size limits in notification S.O. 1364(E).

Here are the limits that apply now, as the gazette gives them. A business must be inside both columns to stay in a category.

The turnover limit for "small" doubled from ₹50 crore to ₹100 crore. So some growing D2C brands that had become "medium" under the old limits are "small" again.

Am I a brand owner, an importer or a producer?

This is where most of the confusion starts.

The rules give each role its own duties, and one business can hold two roles at once.

1. A brand owner sells goods under its own registered brand label or trade mark. Most online sellers with their own brand are here. Micro and small brand owners are outside the EPR obligations.
2. An importer brings plastic packaging, or goods packed in plastic, into India. There is no size exemption. A small seller who imports finished products in their retail pouches is an importer for those products, even if everything else is made in India.
3. A producer makes plastic packaging, such as courier bags or pouches. Micro and small producers must still register on the CPCB portal and declare what they make. Their EPR target is met through the plastic raw material they buy, but the recycled-content target is theirs to meet.

If you are not sure which role fits, write down every plastic item that leaves your door with a product. Then note where each one was made. That list answers the question better than any consultant's brochure.

How do I check whether my business is micro or small?

Start with your Udyam registration certificate.

It shows the category of your enterprise.

If you have no Udyam registration, get one on the official Udyam portal before you rely on any exemption. Then check two numbers with your CA every year after the books close:

1. Investment in plant and machinery, against the limit above.
2. Turnover, against the limit above.

The exemption is like a student bus pass.

It is valid only while you are a student, and the conductor may ask to see it. If either number crosses the small limit, you are no longer small, and the brand-owner obligations come back.

If I am exempt, what do I still have to follow?

Quite a lot, honestly.

The exemption is from EPR targets, not from the plastic rules. We see sellers mix these two up more than anything else.

1. Carry bags must be at least 120 microns thick, for every shop and seller, since 31 December 2022.
2. The banned single-use plastic items stay banned for everyone.
3. Plastic packaging must carry the producer's or brand owner's name and registration number, printed or (since July 2025) through a QR code. When you buy courier bags or pouches, check that this marking is there.
4. Anything you import puts you in the importer role for that item.
5. Your State may have stricter rules on plastic. Check your State Pollution Control Board's notices once a year.

The marking rule matters most for small sellers in practice, because your suppliers control it. We have written a separate guide on what a plastic courier bag must say and how thick it must be in 2027.

What changes on 1 April 2027 for sellers who are covered?

If your business is medium or large, or an importer, 2027 brings a real step. The Plastic Waste Management (Amendment) Rules, 2026 (31 March 2026) set these minimum shares of recycled plastic in packaging:

The annual return for FY 2026-27 is due on the CPCB portal by 30 June 2027 under the rules. That date has been extended in past years, but no extension for 2027 exists as of today. Plan for 30 June.

Notice where courier bags sit. A plain plastic courier bag fits Category II as the rules describe it, and that share doubles on 1 April 2027.

What should a small seller do before 1 April 2027?

You need about one afternoon. I would do it in this order:

1. Find your Udyam certificate and note your category.
2. List every plastic item you ship: bags, pouches, jars, tape, stretch film. Mark each one Category I, II or III.
3. Mark anything you import, either the goods or the packaging.
4. Ask each packaging supplier for a photo of the name and registration number printed on their item. We would expect the same question from you.
5. Ask your CA to check both MSME limits for FY 2026-27 once the books close.
6. If you are close to the small limit, or you import, talk to an EPR professional before 1 April 2027, not after.

One more option, and I will be careful how I say it. Switching a pack from plastic to paper takes it out of your plastic numbers altogether. Honeycomb wrap, kraft paper tape and padded paper mailers are paper. They do not suit every product, though, and paper does not like rain. Our guide on eco-friendly packaging for a small business explains what to switch first and what to leave alone.

Where we fit

We make packaging. We are not EPR consultants. So I will not tell you that you are exempt, and please do not let any supplier tell you that without seeing your Udyam certificate.

What we can do is tell you, product by product, whether an item is plastic or paper and which category it falls in. Our tamper-proof courier bags are 60 micron LDPE film, which fits Category II. Our honeycomb wrap and kraft tape are paper.

Questions sellers ask about EPR

Does selling on a marketplace make me a brand owner? The platform does not decide it. If the goods go out under your brand label, the rules treat you as the brand owner. Your exemption then depends on your MSME category, not on the website the buyer used.

I am a micro business, but a consultant says I must register. Who is right? Ask the consultant which role they think you hold: brand owner, importer or producer. If it is importer or producer, they may be right. If it is brand owner only, ask them to show you the paragraph that covers you.

Do I need EPR registration for the courier bags I buy? Not as a micro or small brand owner. The bag maker is the producer, and its name and registration number should be printed on the bag.

This is not legal advice. Check your status on the CPCB EPR portal (eprplastic.cpcb.gov.in) and with your CA before you decide anything.

• Share this post: