Over the years, we have worked directly across the waste value chain with brands, waste collectors, aggregators, recyclers, processors, auditors, and regulators. This proximity gives us a very clear view of how EPR compliance functions in practice, not just in policy.
One consistent pattern stands out. Most companies that face challenges during audits do not lack intent. In fact, many invest time, money, and internal effort into compliance. The failure usually comes from a gap between how compliance is understood and how waste actually moves on the ground.
Too often, EPR for plastic waste is approached as a reporting requirement. Data is compiled, documents are uploaded, and the system is expected to work. But audits are not designed to validate paperwork alone. They are designed to validate reality.
This article reflects what we see repeatedly where compliance breaks down, why audits raise questions, and what companies must do differently if they want their EPR systems to hold up under scrutiny.
1. The Fundamental Misunderstanding About EPR Audits
The most common assumption we encounter is that documentation equals compliance.
Certificates, invoices, recovery statements, and agreements are all necessary. But they are not sufficient on their own. During audits, these documents are treated as starting points, not proof.
Auditors are trained to look beyond what is submitted and ask whether the numbers make sense when viewed as a system. They examine whether the recovery claimed could have realistically occurred given the infrastructure, geography, and material involved.
We have seen audits raise concerns when:
- Recovery volumes exceed the physical capacity of recycling facilities
- The same recycler appears to process disproportionate quantities across multiple brands
- Plastic types reported do not align with known recycling pathways
- Recovery timelines are too compressed to be operationally feasible
These issues are rarely intentional. They arise when compliance is assembled from documents rather than built from operations.
2. What CPCB Audits Are Actually Trying to Establish
Audits are often perceived as adversarial. In reality, their objective is straightforward: to verify whether the plastic a company claims to have recovered has genuinely been diverted and processed through authorised channels.
From our experience, audits focus on coherence. They examine whether each part of the compliance story supports the others.
Key questions include:
- Does the company’s plastic footprint align with the recovery claimed?
- Is the movement of waste logical and traceable?
- Are the entities involved authorised and operational?
- Can the reported quantities be sustained over time?
- Does the data remain consistent across reporting periods?
When compliance is built only to satisfy immediate reporting needs, it often lacks this coherence.
3. Where Compliance Most Commonly Breaks Down
3.1 Treating EPR as a Fully Outsourced Responsibility
Many companies appoint an EPR partner and step away from the process entirely. While outsourcing execution is reasonable, outsourcing understanding is risky.
During audits, brands are expected to demonstrate awareness of how their compliance operates. When internal teams cannot explain where recovery happens, how recyclers are selected, or how data is verified, audits become difficult.
Accountability under EPR does not shift away from the brand. Even when third parties are involved, responsibility remains with the Producer or Brand Owner.
3.2 Limited Understanding of Material Reality
Plastic waste is highly fragmented. Different materials behave differently, have different recovery values, and require different processing capabilities.
We often see compliance challenges when companies do not:
- Break down their plastic footprint by category
- Understand which materials are recyclable and where
- Align recovery strategies with actual material composition
This gap becomes visible during audits when recovery appears generic while plastic introduction is highly specific.
3.3 Recovery That Lacks Geographic Logic
Geography matters more than many companies realise.
Auditors do not expect waste to be recovered exactly where it is generated. However, they do expect recovery patterns to be reasonable.
When products are predominantly sold in certain regions but recovery is shown from unrelated locations without explanation, it raises questions. Over time, these patterns become easier to detect through data comparisons.
4. The Midpoint Reality: What Compliance Really Represents
At its core, EPR for plastic waste is not a reporting mechanism. It is a responsibility framework that extends a company’s accountability beyond its direct operations.
Effective compliance requires a clear, defensible trail:
- How waste is collected
- Where it is aggregated and sorted
- How it is transported
- Where and how it is processed
- How data is captured and retained
When this trail exists, documentation becomes supportive evidence. When it does not, documentation becomes fragile.
5. What CPCB Auditors Commonly Validate on the Ground
Based on what we have seen, auditors focus on whether the system works as claimed.
They typically validate:
- Physical existence and operational status of recyclers
- Processing capacity relative to volumes reported
- Maintenance of records over time
- Consistency in reporting across multiple brands
- Realistic assumptions around recovery efficiency
Audits do not require perfection. They require plausibility and consistency.
6. The Human Reality of Waste Systems
Waste management in India is not a linear, automated process. It is driven by people working in complex, informal, and semi-formal networks.
When compliance systems ignore this, they become vulnerable. Assumptions of zero loss, perfect segregation, or uniform quality do not reflect real conditions.
Auditors increasingly recognise these realities. Compliance that acknowledges operational complexity is often more credible than compliance that presents an overly simplified narrative.
7. The Risk of Cost-Only Compliance Models
Pressure to minimise EPR costs has led to the emergence of models that prioritise volume over verification.
While these approaches may reduce short-term expenditure, they often compromise:
- Traceability
- Data integrity
- Ground visibility
As audit systems mature and historical data is analysed, such models become harder to sustain. What appears compliant today may not remain so under future scrutiny.
8. What We See Working in Practice
Companies that consistently navigate audits successfully share certain characteristics.
They:
- Maintain a clear understanding of their plastic footprint
- Stay involved in compliance oversight
- Work with partners who have on-ground operations
- Focus on traceability rather than headline volumes
- Treat compliance as an evolving system, not a one-time exercise
These practices do not eliminate audits. They make audits manageable.
9. How Audits Are Evolving
EPR audits are becoming more data-driven and interconnected.
Historical trends, recycler-level capacity, and cross-brand comparisons are increasingly part of review processes. This shift rewards systems built on operational reality and exposes those built on assumptions.
Companies that invest early in robust compliance systems will find it easier to adapt as expectations rise.
What EPR Audits Ultimately Reflect
An EPR audit is not just an assessment of plastic recovery. It reflects how seriously a company engages with its responsibility beyond production and sales.
As regulations mature, EPR for plastic waste will demand systems that are transparent, consistent, and grounded in reality.
The companies that succeed will not be those seeking the lowest threshold of compliance, but those building systems they can confidently explain, defend, and improve over time.
Our Perspective
At ReCircle, we work across the waste ecosystem to help brands build EPR systems rooted in real operations. Our approach focuses on traceability, operational integrity, and long-term audit readiness.
We believe that when compliance is built honestly and thoughtfully, audits shift from being a source of concern to a process of validation.
FAQs
Q1. What is EPR for plastic waste?
A: Extended Producer Responsibility (EPR) is a legal framework where companies producing plastic packaging are responsible for its collection, recycling, and disposal. It ensures producers take accountability for the entire lifecycle of their plastic products.
Q2. Why do most companies fail EPR audits?
A: From our experience, failures usually happen because companies:
- Lack proper documentation of plastic collected versus produced
- Do not segregate or track waste effectively
- Fail to engage with authorized recyclers
- Miscalculate their compliance targets
Q3. What does CPCB check during audits?
A: CPCB reviews:
- Annual plastic consumption and production data
- Collection and recycling records
- EPR plan submission and execution
- Engagement with recyclers and recovery documentation
- Proper reporting of multi-layered plastics and non-recyclables
Q4. How can companies improve EPR compliance?
A: Companies should focus on:
- Maintaining accurate records at each stage
- Partnering with verified recyclers
- Monitoring collection and recycling closely
- Ensuring segregation and proper disposal at source
Q5. How does ReCircle help with EPR compliance?
A: We work directly with companies to:
- Audit plastic usage and collection
- Design EPR-compliant recovery systems
- Track recycled materials
Provide verified reporting for CPCB audits
