Fake recycling certificates, inflated processing claims and weak traceability are undermining India's Extended Producer Responsibility system for plastic and other waste streams.
Extended Producer Responsibility (EPR) was designed to make producers, importers and brand owners financially responsible for the waste generated by their products. Companies meet much of this obligation by purchasing certificates from registered recyclers, with each certificate representing a stated quantity of waste collected and processed. However, regulatory investigations and independent assessments indicate that many certificates may not correspond to actual recycling.
The problem became public in October 2023 when the Central Pollution Control Board (CPCB) and state pollution control boards uncovered certificate fraud. A Centre for Science and Environment (CSE) assessment released in October 2024 estimated that recyclers had generated about 700,000 fake plastic-recycling certificates - nearly 40 times the sector's realistic certificate-generation capacity.
CSE also reported processing claims far beyond installed capacity. Cement plants engaged in end-of-life co-processing reportedly declared annual throughput around 30 times their actual capacity of approximately 11.4 million tonnes.
The certificate-trading model allows producers to purchase compliance instead of directly managing their waste. When fraudulent certificates enter the market at very low prices, legitimate recyclers that invest in collection, segregation and processing cannot compete. Cheap certificates weaken accountability and make genuine and fabricated transactions difficult to distinguish.
Traceability is further reduced because urban local bodies and informal waste collectors, who handle a substantial share of actual collection, remain poorly integrated with the formal EPR portal. Similar discrepancies reported in the United Kingdom suggest that certificate-based schemes can face structural vulnerabilities when physical material flows are not independently verified.
The CPCB has imposed cumulative penalties of roughly Rs 355 crore on companies linked to the fraud identified in 2023. Enforcement alone, however, cannot restore confidence. CSE recommends stopping fraudulent certificates, strengthening portal reporting, establishing realistic baseline costs for genuine waste management, and formally integrating local bodies and informal collectors into the compliance chain.
EPR certificates should be linked to verified collection records, weighbridge data, processing capacity, digital invoices and periodic third-party audits. Pricing that reflects the real cost of collection and recycling would also protect credible operators. The central test is simple: producers must finance measurable waste recovery, not merely purchase the appearance of compliance.
Sources: Centre for Science and Environment; Down To Earth; Sustainable Plastics; Outlook Business.