Extension in Timeline for Filing of Annual Returns of PIBOs and PWPs

Extension in Timeline for Filing of Annual Returns of PIBOs and PWPs. The Ministry of Environment, Forest and Climate Change (MoEF&CC), through its Hazardous Substances Management Division, has released an official memorandum on 29th July 2025, granting a timeline extension for filing annual returns by PIBOs and PWPs. This move comes as a relief to many stakeholders involved in the plastic waste management ecosystem.
This article provides a detailed overview of the memorandum, its implications, regulatory background, and the responsibilities of PIBOs and PWPs under the EPR Guidelines and Plastic Waste Management Rules, 2023.
Background of the Notification
The office memorandum (F. No.:12/64/2023-HSM) was issued in response to a letter from the Central Pollution Control Board (CPCB) dated 24th July 2025. The CPCB had sought an extension for the timeline related to the filing of annual returns by PIBOs (Producers, Importers, and Brand Owners) and PWPs (Plastic Waste Processors) under the Extended Producer Responsibility (EPR) framework.
Recognizing the difficulties faced by stakeholders and in view of the operational challenges for the financial year 2024–25, the Ministry has extended the deadline to 30th September 2025. This special extension is expected to help ease compliance and improve the quality of reporting.
Official Announcement and Purpose
The Ministry of Environment, Forest and Climate Change, via its Hazardous Substances Management Division, formally communicated that the deadline for filing annual returns for the financial year 2024–25 by registered PIBOs and PWPs is now extended up to 30th September 2025.
The main objectives of this extension are:

To remove operational and compliance difficulties for PIBOs and PWPs.

To support the smooth filing of annual returns under the Plastic Waste Management Rules.

To encourage environmentally sound plastic waste management practices.

To reduce pollution from littered and unmanaged plastic packaging.

This relaxation applies specifically to entities registered under the EPR guidelines for the financial year 2024–25.
Legal and Regulatory Framework
Plastic Waste Management (Second Amendment) Rules, 2023
The extension granted is in accordance with the provisions of the Plastic Waste Management (Second Amendment) Rules, 2023. These rules emphasize the responsibilities of plastic producers, brand owners, and plastic waste processors under the concept of Extended Producer Responsibility (EPR).
The EPR system is a policy approach where producers are given significant responsibility financial and/or physical for the treatment or disposal of post-consumer products. In the context of plastic packaging, this includes collection, segregation, recycling, and disposal.
Learn more about Plastic Waste Recycling Plant.
EPR Guidelines for PIBOs and PWPs
Under the EPR guidelines:

PIBOs are required to collect and manage plastic waste equivalent to the amount of plastic packaging they introduce into the market.

PWPs are responsible for recycling and processing the collected plastic waste in an environmentally sound manner.

Both parties must submit annual returns to the CPCB detailing their plastic packaging quantities, collection efforts, and recycling data.

The timeline for submitting these returns plays a crucial role in evaluating and monitoring compliance.
Significance of the Extension
The extension until 30th September 2025 offers stakeholders breathing space to comply with the complex EPR-related documentation and reporting requirements. This decision has several positive outcomes:

Support for Environmental Governance: By ensuring accurate and complete data submission, the extension contributes to the government's broader goals of responsible plastic waste management.

Relief to PIBOs and PWPs: Many PIBOs and PWPs face technical and logistical hurdles while collecting, validating, and submitting their annual returns. The extended timeline eases their burden and helps maintain compliance.

Better Data Quality: More time allows organizations to ensure the accuracy and completeness of their data, leading to more reliable environmental impact assessments.

Reduction in Legal Disputes: Delayed or incorrect filing often leads to penalties or legal proceedings. This extension gives companies an opportunity to rectify their submissions and avoid enforcement actions.

Who Will Benefit from This Extension?

Producers: Manufacturers of plastic packaging material or products using plastic components who need to disclose their annual usage and waste management activities.

Importers: Entities importing plastic-packaged products or plastic raw material for commercial use.

Brand Owners: Firms whose branding appears on plastic-packaged goods, irrespective of who manufactured or distributed them.

Plastic Waste Processors: Organizations engaged in the collection, segregation, recycling, or energy recovery from plastic waste.

All these stakeholders are legally required to register and submit annual returns under the EPR regime. The extension directly impacts their regulatory responsibilities.
Implementation Process
The implementation of this extension will involve the following steps:

Update on the EPR Portal: The CPCB is expected to update the online portal for filing annual returns, reflecting the new deadline of 30th September 2025.

Awareness by Pollution Control Boards (PCBs): State and Union Territory PCBs must notify all registered entities under their jurisdiction.

Internal Compliance Timelines: Organizations must now revisit their compliance calendar and adjust their internal review and submission processes accordingly.

Role of Regional and Central Authorities
Central Pollution Control Board (CPCB)

Acts as the nodal authority for monitoring compliance with EPR rules.

Manages the EPR registration portal and reviews annual returns.

Issues necessary directions and updates based on MoEF&CC’s memorandum.

State Pollution Control Boards (SPCBs)

Assist in enforcing compliance at the state level.

Coordinate with stakeholders to ensure that they meet the filing requirements.

Conduct inspections, audits, and assessments.

Summary
In summary, the Ministry of Environment, Forest and Climate Change has issued an important extension for the filing of annual returns by PIBOs and PWPs under the Plastic Waste Management framework. The new deadline of 30th September 2025 will provide much-needed flexibility to stakeholders and support environmental compliance.
The government’s proactive decision not only eases administrative challenges but also reinforces the commitment toward sustainable waste management practices. All registered entities are advised to make use of the extended time judiciously to ensure complete and accurate filings.

Frequently Asked Questions (FAQs)
Q1. What is the new deadline for filing annual returns for PIBOs and PWPs?
Ans. The deadline has been extended to 30th September 2025 for the financial year 2024–25.
Q2. Which entities are covered under this extension?
Ans. All registered Producers, Importers, Brand Owners (PIBOs) and Plastic Waste Processors (PWPs).
Q3. Why has the deadline been extended?
Ans. To facilitate the smooth filing of annual returns and remove compliance difficulties for stakeholders.
Q4. What legal framework governs this extension?
Ans. The Plastic Waste Management (Second Amendment) Rules, 2023.
Q5. Do PIBOs and PWPs need to register to avail the benefit of this extension?
Ans. Yes, only registered PIBOs and PWPs are eligible for this timeline extension.
Q6. Will the EPR portal reflect the new deadline?
Ans. Yes, CPCB is expected to update the EPR portal to reflect the extended deadline.
Q7. Can this extension be used for filing returns of earlier financial years?
Ans. No, this extension is applicable only for the financial year 2024–25.
Q8. What happens if a PIBO or PWP still fails to file within the extended deadline?
Ans. They may face penalties or legal action under the EPR and Plastic Waste Management Rules.
Q9. Will this extension be granted again in future years?
Ans. There is no guarantee. This extension is a special case for 2024–25, and future timelines will depend on government discretion.

The Ministry of Environment, Forest and Climate Change (MoEF&CC), through its Hazardous Substances Management Division, has released an official memorandum on 29th July 2025, granting a timeline extension for filing annual returns by PIBOs and PWPs. This move comes as a relief to many stakeholders involved in the plastic waste management ecosystem.

This article provides a detailed overview of the memorandum, its implications, regulatory background, and the responsibilities of PIBOs and PWPs under the EPR Guidelines and Plastic Waste Management Rules, 2023.

Background of the Notification

The office memorandum (F. No.:12/64/2023-HSM) was issued in response to a letter from the Central Pollution Control Board (CPCB) dated 24th July 2025. The CPCB had sought an extension for the timeline related to the filing of annual returns by PIBOs (Producers, Importers, and Brand Owners) and PWPs (Plastic Waste Processors) under the Extended Producer Responsibility (EPR) framework.

Recognizing the difficulties faced by stakeholders and in view of the operational challenges for the financial year 2024–25, the Ministry has extended the deadline to 30th September 2025. This special extension is expected to help ease compliance and improve the quality of reporting.

Official Announcement and Purpose

The Ministry of Environment, Forest and Climate Change, via its Hazardous Substances Management Division, formally communicated that the deadline for filing annual returns for the financial year 2024–25 by registered PIBOs and PWPs is now extended up to 30th September 2025.

The main objectives of this extension are:

To remove operational and compliance difficulties for PIBOs and PWPs.
To support the smooth filing of annual returns under the Plastic Waste Management Rules.
To encourage environmentally sound plastic waste management practices.
To reduce pollution from littered and unmanaged plastic packaging.

This relaxation applies specifically to entities registered under the EPR guidelines for the financial year 2024–25.

Legal and Regulatory Framework

Plastic Waste Management (Second Amendment) Rules, 2023

The extension granted is in accordance with the provisions of the Plastic Waste Management (Second Amendment) Rules, 2023. These rules emphasize the responsibilities of plastic producers, brand owners, and plastic waste processors under the concept of Extended Producer Responsibility (EPR).

The EPR system is a policy approach where producers are given significant responsibility financial and/or physical for the treatment or disposal of post-consumer products. In the context of plastic packaging, this includes collection, segregation, recycling, and disposal.

Learn more about Plastic Waste Recycling Plant.

EPR Guidelines for PIBOs and PWPs

Under the EPR guidelines:

PIBOs are required to collect and manage plastic waste equivalent to the amount of plastic packaging they introduce into the market.
PWPs are responsible for recycling and processing the collected plastic waste in an environmentally sound manner.
Both parties must submit annual returns to the CPCB detailing their plastic packaging quantities, collection efforts, and recycling data.

The timeline for submitting these returns plays a crucial role in evaluating and monitoring compliance.

Significance of the Extension

The extension until 30th September 2025 offers stakeholders breathing space to comply with the complex EPR-related documentation and reporting requirements. This decision has several positive outcomes:

Support for Environmental Governance: By ensuring accurate and complete data submission, the extension contributes to the government's broader goals of responsible plastic waste management.
Relief to PIBOs and PWPs: Many PIBOs and PWPs face technical and logistical hurdles while collecting, validating, and submitting their annual returns. The extended timeline eases their burden and helps maintain compliance.
Better Data Quality: More time allows organizations to ensure the accuracy and completeness of their data, leading to more reliable environmental impact assessments.
Reduction in Legal Disputes: Delayed or incorrect filing often leads to penalties or legal proceedings. This extension gives companies an opportunity to rectify their submissions and avoid enforcement actions.

Who Will Benefit from This Extension?

Producers: Manufacturers of plastic packaging material or products using plastic components who need to disclose their annual usage and waste management activities.
Importers: Entities importing plastic-packaged products or plastic raw material for commercial use.
Brand Owners: Firms whose branding appears on plastic-packaged goods, irrespective of who manufactured or distributed them.
Plastic Waste Processors: Organizations engaged in the collection, segregation, recycling, or energy recovery from plastic waste.

All these stakeholders are legally required to register and submit annual returns under the EPR regime. The extension directly impacts their regulatory responsibilities.

Implementation Process

The implementation of this extension will involve the following steps:

Update on the EPR Portal: The CPCB is expected to update the online portal for filing annual returns, reflecting the new deadline of 30th September 2025.
Awareness by Pollution Control Boards (PCBs): State and Union Territory PCBs must notify all registered entities under their jurisdiction.
Internal Compliance Timelines: Organizations must now revisit their compliance calendar and adjust their internal review and submission processes accordingly.

Role of Regional and Central Authorities

Central Pollution Control Board (CPCB)

Acts as the nodal authority for monitoring compliance with EPR rules.
Manages the EPR registration portal and reviews annual returns.
Issues necessary directions and updates based on MoEF&CC’s memorandum.

State Pollution Control Boards (SPCBs)

Assist in enforcing compliance at the state level.
Coordinate with stakeholders to ensure that they meet the filing requirements.
Conduct inspections, audits, and assessments.

Summary

In summary, the Ministry of Environment, Forest and Climate Change has issued an important extension for the filing of annual returns by PIBOs and PWPs under the Plastic Waste Management framework. The new deadline of 30th September 2025 will provide much-needed flexibility to stakeholders and support environmental compliance.

The government’s proactive decision not only eases administrative challenges but also reinforces the commitment toward sustainable waste management practices. All registered entities are advised to make use of the extended time judiciously to ensure complete and accurate filings.