EPR Guidance for Distributors
Understanding EPR obligations and exemptions for distributors
Overview
Distributors typically do not have direct EPR obligations unless they act as brand owners or importers. We help you understand your role, ensure upstream compliance, and avoid liability.
EPR Requirements for Distributors
Distributor Exemption Understanding
Distributors purchasing finished branded products for resale generally do not require EPR registration unless acting as brand owner.
Brand Owner Verification
Ensure brands you distribute have valid EPR registration and are compliant to avoid potential future liability.
Private Label Compliance
If you sell products under your own distributor brand/label, you become responsible for EPR registration and compliance.
Importer-Distributor Clarity
If you import products for distribution (even under others' brands), you may have importer EPR obligations.
Common EPR Challenges
- Confusion about when distributors need EPR vs when they are exempt
- Risk of liability if upstream brand owners are non-compliant
- Determining EPR responsibility for distributor-owned brands
- Managing EPR for products imported for distribution
- Pressure from buyers/retailers to show EPR compliance
- Lack of clear regulatory guidance on distributor role
How We Help Distributors
EPR Applicability Assessment
Clear analysis of your specific situation to determine if you need EPR registration or are exempt as a pure distributor.
Vendor EPR Verification
Process to verify EPR compliance of brands you distribute to protect against potential liability.
Private Label Registration
If you have distributor-owned brands, we provide complete EPR registration and compliance management.
Legal Advisory
Expert guidance on distributor agreements, EPR indemnity clauses, and compliance responsibility allocation.
Our Process
- 1Initial Consultation
We analyze your scope and EPR applicability.
- 2CPCB Registration
Complete documentation, portal setup, and EPR registration submission.
- 3Target Setting
Calculate annual EPR targets based on PIB (Plastic in Brand).
- 4Certificate Procurement
Source EPR certificates from our recycler network at competitive rates.
- 5Annual Returns
Compile data, prepare Form 1 & Form 2, and submit before the June 30th deadline.
- 6Ongoing Support
Year-round compliance monitoring and regulatory updates.
Success Story
A distributor handling 30+ FMCG brands thought they needed EPR registration for all brands. After assessment, we clarified they were exempt as a pure distributor for third-party brands. However, they had 3 private label products where EPR was required. We registered only for these 3 private labels, saving them from unnecessary compliance costs for the other 30 brands, while ensuring protection through EPR verification of those brands.
Ready to Achieve EPR Compliance?
Not sure if you need EPR as a distributor? We provide clear assessment, registration if required, and protection strategies regardless of your status.