Every packaged drinking water (PDW) brand that sells water in PET bottles or 20-litre jars has a yearly plastic EPR (Extended Producer Responsibility) filing to make. For FY 2025-26 that filing was due on 30 June 2026, but the window has now been extended. Brand owners, producers and importers (called PIBOs in the rules) now have until 31 December 2026.
That gives plants about two months. This guide explains the extension, the targets the return will be checked against, and a practical checklist.
What exactly was extended
The Ministry of Environment, Forest and Climate Change (MoEFCC) issued a notification dated 28 August 2026 (No. 12/64/2023-HSM Part (1)) after a request from the Central Pollution Control Board (CPCB) dated 10 August 2026, as reported by TeamLease RegTech on 31 August 2026. The same dates were reported by Lexplosion on 3 September 2026 and Kar Parivartan on 9 September 2026.
The extension was granted as a special case, and CPCB was asked to resolve EPR portal issues on priority during the extended period. The extension covers annual returns for FY 2025-26 only. It does not reduce any target.
Key dates and targets at a glance
| Item | What applies | Source (date) |
|---|---|---|
| Annual return FY 2025-26: brand owners, producers, importers (PIBOs) | 31 December 2026 (earlier 30 June 2026) | MoEFCC notification, 28 Aug 2026 |
| Annual return FY 2025-26: plastic waste processors (PWPs) | 31 October 2026 | MoEFCC notification, 28 Aug 2026 |
| Registration on the Common EPR Portal | Covered entities asked to register immediately; transactions with unregistered entities to be blocked | CPCB directive, 27 Aug 2026 |
| Recycled content, Category I rigid plastic (PET bottles, jars) | 30% in 2025-26, 40% in 2026-27, 50% in 2027-28, 60% from 2028-29 | PWM (Amendment) Rules, G.S.R. 237(E), 31 Mar 2026 |
| Reuse, rigid drinking water packaging of 4.9 litres and above | 70% in 2025-26, rising to 85% from 2028-29 | G.S.R. 237(E), 31 Mar 2026 |
| Food-contact recycled content shortfall for 2025-26 | May be carried forward for up to three years from 2026-27, clearing at least one-third each year | G.S.R. 237(E), 31 Mar 2026 |
Dates in this table are as reported in the sources listed at the end. Always confirm the current position on the CPCB Common EPR Portal before filing.
The portal has changed too
Plastic EPR is now handled on CPCB's Common EPR Portal (epr.cpcb.gov.in), which brings plastic, e-waste, battery, tyre and used oil EPR under a single login. According to a CPCB directive dated 27 August 2026, reported by Enviliance on 17 September 2026, all producers, importers, brand owners and processors covered by the Plastic Waste Management Rules must register on the Common EPR Portal and file their annual reports there. CPCB said transactions involving unregistered entities will be blocked.
In practice, a plant that registered on the older plastic portal should log in to the new portal, check that its registration has carried over correctly and confirm its company, GST and signatory details.
What this means for water plant owners
If you sell water under your own brand, you are a brand owner. You must file the FY 2025-26 annual return yourself by 31 December 2026. It will show the plastic packaging you placed on the market in 2025-26, the EPR certificates you hold against it, and your recycled-content and reuse position.
If you run 20-litre jars, the 70% reuse obligation for drinking water packaging of 4.9 litres and above applies from 2025-26. Your jar issue and return records are the evidence for this. Our guide on the 70% jar reuse target explains how to keep them.
If you only bottle for another brand, the filing position depends on who is registered as the brand owner and what your contract says. Read our co-packer EPR guide and confirm in writing with your principal which entity files.
A short checklist for November and December:
- Log in to the Common EPR Portal and confirm your registration is active.
- Reconcile 2025-26 PET, preform, cap and jar purchase invoices with your sales and production data.
- Check that EPR certificates against your 2025-26 obligation are in your account, and buy any shortfall early.
- Collect recycled-content declarations from your preform or bottle supplier.
- Keep your consent to operate, FSSAI licence and CGWA NOC details current, as auditors often check them together.
Do not wait for the last week. The extension was granted because of portal problems, and late filing leaves no margin if issues come back.
How ClearPath Compliance India can help
We help packaged drinking water plants in Rajasthan and nearby states with EPR registration, annual return preparation and the related Pollution Control Board consents. If you are setting up a new unit, our PDW plant approval checklist lists every licence in order. Contact us with your 2025-26 purchase and sales data and we will tell you what your return needs.
Sources
- TeamLease RegTech: MoEFCC extension for annual returns of PWPs and PIBOs (31 Aug 2026)
- Lexplosion: CPCB extends FY 2025-26 annual return timelines (3 Sep 2026)
- Kar Parivartan: revised deadlines for PIBOs and PWPs (9 Sep 2026)
- Enviliance: CPCB calls on companies to register on the Common EPR Portal (17 Sep 2026)
- Corporate Professionals: PWM (Amendment) Rules 2026, G.S.R. 237(E) (7 Apr 2026)
General information only, not legal advice. Rules, deadlines and targets are as reported by the sources on the dates stated; check the CPCB Common EPR Portal and official notifications before filing. Brand names, if any, are trademarks of their owners and are used for identification only. This article is not sponsored or endorsed by any brand.