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Compliance is no longer a choice today in the context of ferocious competition in trade — it is the key to effective global business. For Indian importers, two of the most crucial yet least comprehended compliances are EPR (Extended Producer Responsibility) Registration and LMPC (Legal Metrology Packaged Commodities) Registration.
Although both are for different reasons, majority of companies require both registrations simultaneously in order to avoid customs delay, penalties, or even goods seizure. Let us understand why both these registrations are required, how they are different, and where they overlap in the real world.
What is EPR Registration?
Extended Producer Responsibility (EPR) is an environmental scheme initiated by the the Central Pollution Control Board powered by Ministry of Environment, Forest and Climate Change (MoEFCC). EPR holds producers, importers, and brand owners (PIBOs) responsible for the generated waste resulting from their product and packaging.
Depending on the type of product, different EPR models are as follows:
- EPR Plastic Waste – For importers of plastic packaging.
- EPR E-Waste – For importers of electronics and electrical equipment.
- EPR Battery Waste – For manufacturers and importers of batteries.
- EPR Tyre Waste – For tyre manufacturers and importers.
Why it concerns importers: Imported items under these heads cannot be legally cleared from Indian ports unless there is EPR registration.
What is LMPC Registration?
Legal Metrology Packaged Commodities (LMPC) Registration is a consumer protection compliance under the Department of Legal Metrology powered by Ministry of Consumer Affairs . It applies to any importer who imports pre-packaged commodities into India.
Regulations of LMPC ensure that all pre-packed commodity displays significant information such as:
- Importer’s name and address
- Net weight (weight/volume/number)
- Date of manufacture/packing and expiry (where applicable)
- Maximum Retail Price (MRP)
Why it is significant for importers: LMPC certificate must be provided in order to clear pre-packaged goods at customs. Non-compliance results in detention of goods at port until registration is attained.
EPR vs LMPC – What are the Key Differences?
| Aspect | EPR Registration | LMPC Registration |
| Objective | Recycling and eco-friendly disposal of waste | Transparency and consumer protection |
| Authority | CPCB / SPCBs (MoEFCC) | Legal Metrology Department |
| Applicability | Product category-based (plastic, e-waste, battery, tyre) | Packaged commodities imported into India |
| Timing | Before importing relevant goods | Before customs clearance of pre-packaged goods |
What are the cases where EPR and LMPC Overlap?
This is where most importers get caught by surprise. Often, a single consignment can require both registrations. Here are some examples –
- Battery Imports
- Require EPR Battery Waste Registration (as per Battery Waste Management Rules).
- Require LMPC Registration (if imported in pre-packed retail packs).
- Electronics Imports
- Require EPR E-Waste Registration (for post-consumer disposal)
- Also require LMPC Registration (since electronics are sold in pre-packaged form).
- Cosmetics or Packaged Food Imports
- Require EPR Plastic Waste Registration (for packaging waste).
- Require LMPC Registration (to ensure labelling compliance for consumers).
In short: EPR ensures environmental accountability, while LMPC ensures consumer transparency. Both are indispensable.
Challenges Facing Importers
- Import consignments held up at customs due to non-registration.
- Delay in processing applications due to documents being non-compliant with customs and compliance requirements.
- Illusion that one compliance is enough — several importers feel that LMPC is enough for packaged goods, unaware of EPR requirements.
- Risks of penalty for non-compliance under environmental as well as consumer legislations.
Benefits of EPR and LMPC Compliance:
- Smooth Customs Clearance – Port detention and demurrage-free.
- Regulatory Goodwill – Establish confidence with regulatory bodies.
- Brand Reputation – Showing concern about environment and consumers.
- Cost Saving – Penalty, delay, and port storage charges avoidance.
Conclusion
EPR and LMPC Registration are mutually beneficial requirements for Indian importers. Each ensures your business is answerable for environmental sustainability, and the other ensures transparency and justice to consumers.
Businesses that prepare beforehand in terms of compliance — by acquiring both the registrations before importing — do not just save time at ports unnecessarily, but enhance their business reputation in the long term as well.
