This is really a question about where an obligation attaches, and I think you are reading a recital as a widening.
First, the wide wording is older than the instruction in front of you. The April 2023 instruction on this same subject already described importers of products with plastic packaging as requiring registration at the time of clearance. Last year's was the narrow one, because its occasion was raw material. I have read this month's only as reported, not the official text, so take that as a reading rather than a ruling.
Second, from the export side: the duty sits on your importer, tied to an Indian code no foreign supplier can hold. Two buyers this year have asked my team for "our EPR number". There is none to send. What they should ask us for is packaging weight by category on the packing list, since the target runs on tonnage placed on the market, and almost no exporter's packing specification carries that line.
Does your counter look at what the goods are, or at what the importer registered for?
Thank you, Marcus: I have read the April 2023 instruction, and paragraph 2.1 does name products with plastic packaging, so this month's paragraph 4(a) restores that reach rather than inventing it.
On your question, what is written points the counter at the importer. The Nhava Sheva public notice of May 2023 asks for the EPR registration in e-Sanchit with the Bill of Entry, "to avoid any query", and has the officer giving out of charge check a pending application on the CPCB portal. What I cannot find in writing is how a consignment is judged to carry plastic packaging. So I would ask any client whose goods arrive in plastic to upload the certificate every time, before anyone has to decide. May your buyers ask for packaging weights instead.
marcus, that packing list line is the one we get asked for. never early.
no india shipments here, so i cannot help at the counter. but a buyer wanted packaging weight by material with my cartons already taped. and on direct eu sales there is no importer above me, so the registration is mine, not a buyer's.