An unresolved FY 2025–26 Extended Producer Responsibility (EPR) shortfall does not automatically disappear when a new financial year begins. If your business still has outstanding plastic packaging obligations, you need to address them while managing the targets for FY 2026–27.
The good news is that eligible previous-year shortfalls can still be addressed through the applicable EPR framework. The process, however, depends on the type of obligation, the available EPR credits, the category in which the shortfall exists, and the eligibility of the certificates being used.
For businesses managing both financial years, the priority should be to assess the outstanding quantity, identify eligible certificates and close the previous year’s gap without creating additional compliance pressure.
Why You Should Close Your EPR Shortfall Now
The rules provide a reason not to leave an EPR shortfall unresolved.
Under Schedule II of the Plastic Waste Management Rules, 2016, the unfulfilled EPR obligation for a particular year is carried forward for up to three years. Paying environmental compensation does not remove the underlying EPR obligation. If the shortfall is addressed within that period, a portion of the environmental compensation may be returned.
The sooner the shortfall is closed, the larger the share of compensation returned. After three years, the environmental compensation becomes liable to forfeiture under the provision.
This means delaying compliance can have a direct financial consequence.
These provisions are subject to the applicable rules and the circumstances of the obligated entity. Refer to Schedule II, paragraph 9.5, of the Plastic Waste Management Rules, 2016.
Can You Still Fulfil Your FY 2025–26 EPR Shortfall?
Yes. FY 2025–26 shortfalls can still be fulfilled. However, the available route depends on the category and nature of the outstanding obligation.
Having EPR credits available does not automatically mean they can be applied to every outstanding obligation. The category, certificate eligibility and applicable portal process must be checked first.
What About the FY 2026–27 Targets?
While closing an older shortfall, businesses must also plan for their ongoing FY 2026–27 EPR obligations.
These are two separate compliance priorities. Addressing the previous year’s gap should not result in neglecting the current year’s targets.
A practical approach is to review both years together:
- FY 2025–26: Identify outstanding obligations and assess eligible options to close the shortfall.
- FY 2026–27: Calculate current-year targets and plan the required EPR credits.
- Certificate eligibility: Check category, quantity, validity and registration details.
- Documentation: Maintain the required certificates, transaction records and portal information.
- Compliance tracking: Monitor progress separately for each financial year.
The 2026 amendment to the Plastic Waste Management Rules also introduced a specific carry-forward provision for Brand Owners with an unfulfilled FY 2025–26 target for mandatory recycled plastic content in food-contact packaging. That particular target may be carried forward for up to three consecutive years starting from FY 2026–27, with at least one-third of the carried-forward target to be fulfilled in each year.
This is a specific provision for the stated recycled-content obligation. It should not be treated as a general carry-forward extension for every EPR shortfall.
Refer to the Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E), 31 March 2026).
How to Close Your FY 2025–26 EPR Shortfall
A structured assessment can help businesses identify the right route instead of purchasing certificates without checking their eligibility.
Step 1: Assess Your Outstanding EPR Obligations
Start by reviewing your FY 2025–26 EPR records.
Identify the outstanding quantity under each applicable obligation, including recycling, end-of-life disposal, reuse and recycled plastic content, wherever applicable.
Compare your targets with the credits already generated or recorded in the portal.
Step 2: Identify the Applicable EPR Category
EPR certificates are not universally interchangeable.
The applicable category must be checked before selecting a certificate to address a shortfall.
This is important because an available certificate may not be eligible for the particular obligation you need to fulfil.
Step 3: Source Eligible EPR Certificates
Once the shortfall and category are established, identify eligible certificates from registered entities.
The registration status of the relevant entity and the certificate details should be verified before proceeding.
You can also explore Fitsol’s EPR compliance solutions to understand how the process can be managed.
Step 4: Verify the Counterparty Before the Transaction
Certificate eligibility is only one part of the process. You must also check whether the entity involved in the transaction is registered.
In its public notice dated 27 August 2026, CPCB stated that the Common EPR Portal would discontinue the recording of purchase or sale transactions with unregistered entities, except for applicable transactions involving Micro and Small Brand Owners and Plastic Waste Processors.
Before proceeding, buyers should therefore:
- Check the counterparty’s registration status on the Common EPR Portal.
- Verify the relevant registration details and certificate information.
- Confirm that the transaction is permitted under the applicable rules.
- Ensure that the required transaction records are captured through the portal.
Do not rely only on an invoice, quotation or offline certificate when assessing compliance.
Use the Common EPR Portal for the relevant registration and transaction checks.
Step 5: Track Closure and Plan the Current Year’s Targets
After the applicable process is completed, review the portal records and retain the supporting documentation.
Keep the FY 2025–26 shortfall closure separate from FY 2026–27 compliance tracking. This helps prevent the previous year’s outstanding obligations from being confused with current-year targets.
What Determines EPR Certificate Cost?
The cost of an EPR certificate is not necessarily the same across all categories or transactions.
The EPR certificate cost may depend on factors such as:
- The category of EPR obligation.
- The quantity of credits required.
- Availability of eligible certificates.
- Certificate and counterparty eligibility.
- The applicable transaction and documentation requirements.
Businesses should assess certificate eligibility before comparing prices. A lower-cost certificate is not useful if it cannot be applied to the outstanding obligation.
The right approach is to establish the exact shortfall first and then evaluate eligible options.
How Fitsol Can Help You Address Your EPR Shortfall
Managing an older EPR shortfall while working towards new financial-year targets requires accurate assessment and careful certificate selection.
Fitsol helps businesses assess their outstanding EPR requirements and identify suitable options based on the applicable category and compliance requirements.
Get a free EPR shortfall assessment. Share your FY 2025–26 compliance details with the Fitsol team. Fitsol will review the shortfall and share available options within five working days.
Request your EPR shortfall assessment
Frequently Asked Questions
1. Can an FY 2025–26 EPR shortfall still be fulfilled? Yes. Eligible FY 2025–26 shortfalls can still be addressed through the applicable EPR framework. The available route depends on the obligation category, certificate eligibility and prescribed portal process.
2. What happens if an EPR shortfall is not addressed? The unfulfilled EPR obligation is carried forward for up to three years under Schedule II. Payment of environmental compensation does not remove the underlying obligation. If the shortfall is addressed within the prescribed period, a portion of the environmental compensation may be returned, depending on when the shortfall is closed.
3. How much does an EPR certificate cost? EPR certificate cost varies according to the obligation category, quantity required, availability of eligible credits and transaction conditions. Businesses should first assess their shortfall and certificate requirements before comparing prices.
Over to you: Are you carrying an FY 2025–26 shortfall into this year, and what’s held it up so far? Tell us in the comments.
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