Understanding Intra-Group EPR Credit Transfers, And Why They’re Under Pressure in 2025

Whether you're an importer launching new SKUs or a multinational managing 10+ product lines in India, Extended Producer Responsibility (EPR) is no longer just a checkbox, it’s an accountability framework with teeth.

Among the most discussed topics this year?

Intra-Group EPR Credit Transfers, once widely used, are now under regulatory heat.

Let’s Start with the Basics: What is EPR?

Under India’s Plastic Waste Management Rules, Producers, Importers, and Brand Owners (PIBOs) are legally responsible for the plastic waste they generate.

This responsibility is met by:

• Physically collecting and recycling plastic, or
• Procuring plastic credit certificates from authorized recyclers or PROs (Producer Responsibility Organizations).

What Are Intra-Group EPR Credit Transfers?

In simple terms, these are internal reallocations of plastic credits between multiple companies or brands under the same corporate group.

Example:

• You have Brand A and Brand B, both operating under your company.
• Brand A procures excess EPR credits through a PRO (Producer Responsibility Organization).
• Brand B falls short of its target.
• So, you reassign credits from A to B to balance your group-wide EPR obligation.

✔️ Efficient. ✔️ Cost-effective. ✔️ Flexible — until now.

What’s Changed in 2025?

While no explicit gazette notification bans intra-group transfers, recent CPCB interpretations and audit flags suggest a decisive shift:

“Each PIBO must fulfill its own compliance independently.”

This means:

• One brand’s surplus can no longer cover another’s shortfall, even under the same ownership.
• CPCB is prioritizing entity-wise traceability.
• Group-wide credit pooling models are being challenged or rejected during scrutiny.

Why This Matters for You

Whether you’re:

• A D2C importer with 3 product categories, or
• A global brand managing 12 Indian licenses...

You must now ensure:

• Each registered PIBO ID meets its own EPR target
• Separate PRO contracts, invoices, and plastic waste declarations
• Packaging-level identifiers (as per Jan 2025 Gazette), including QR/barcodes or licensing numbers
• CPCB filings are updated per entity, not just the parent group

How to Stay Compliant in 2025

• Map your legal entities and PIBO IDs
• Build a SKU- and unit-level compliance tracker
• Rework PRO agreements with entity-specific responsibility
• Align pack labels with Jan 2025 disclosure rules (Rule 11A)

What NKG Advisory Can Do

We're helping companies:

• Transition from centralized EPR strategies to decentralized, CPCB-aligned models
• Review SKU-level declarations
• Validate PRO coverage
• Ensure every PIBO’s credit flow and pack compliance is audit-ready

📣 Still managing EPR at a group level? It’s time to restructure before CPCB notices do it for you.

📩 Book an EPR Health Check with NKG Today

Visit our website 👉 www.nkgabc.com

📧 Email: navraj@nkgabc.com

📞 Call: 9711197602