EPR & CIRCULAR ECONOMY CONSULTING · WITH CLYMACO PROPRIETARY SOFTWARE LAYER
Founded by IIM Lucknow alumniRun by a network of industry veteransPartners in Gurugram · Dublin · Tbilisi · London · Paris · Abu Dhabi

EPR and circular economy are no longer compliance.They are market access, lower cost, and first-mover advantage.

Clymaco runs multi-stream EPR for producers in India and carries Indian exporters through the EU, UK and US regimes. Strategy, filings, credit procurement and evidence, held together on our own EPR Control Portal.

What We Do
06

Six practice areas. One system.

EPR Wire · Live
DEADLINEEU PPWR applicable since 12 Aug 2026UPDATEIndia: non-ferrous scrap and C&D EPR live since 1 Apr 2026ALERTCPCB recovering Environmental Compensation on past shortfallsDEADLINECalifornia SB 54 reporting begins 2027NOTICEEarly access to the EPR Control Portal opens October 2026UPDATEOregon and Colorado already invoicing producersDEADLINEEU PPWR applicable since 12 Aug 2026UPDATEIndia: non-ferrous scrap and C&D EPR live since 1 Apr 2026ALERTCPCB recovering Environmental Compensation on past shortfallsDEADLINECalifornia SB 54 reporting begins 2027NOTICEEarly access to the EPR Control Portal opens October 2026UPDATEOregon and Colorado already invoicing producers
01
Start Here

Which of these is you?

Eight situations we see every week. One of them is yours. The cards rotate on their own, or pick one yourself.

01 / 08

We export goods to Europe or the UK.

What this makes you

potentially a producer under PPWR Article 3(1)(15)

What bites

EU Packaging and Packaging Waste Regulation (EU) 2025/40, applicable since 12 August 2026.

What it costs

consignments held, buyer compliance questionnaires failed, contracts quietly not renewed.

What we do

Producer status determination, member state registration and authorised representative appointment.

Why we're differentStrategy before filingsData collated from every sourcePWP due diligence before credit purchaseTraceability you can defend
02
What We Do

Six practice areas. One system.

From a small exporter's first registration to a CXO's global EPR strategy, every engagement runs on the same register.

Exporters

Global EPR for Exporters

For Indian manufacturers shipping to obligated markets.

  • Producer status determination under PPWR
  • Member state registration and authorised representatives
  • LUCID, VerpackG, UK pEPR and US state EPR
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Indian manufacturers

India EPR Compliance, All Eight Streams

For PIBOs, PWPs, SIMPs and bulk consumers.

  • Applicability mapping across all eight streams
  • CPCB registration: PIBO, PWP and SIMP
  • Target computation and credit procurement
  • Returns filing and EC resolution
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Manufacturers

Reuse, Recycled Content and Take-Back Systems

For companies facing content mandates and reuse targets.

  • Recycled content strategy and sourcing
  • Take-back channel design
  • Deposit and return systems
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Sustainability teams

Circular Economy and Reverse Supply Chain

For companies building collection and processing rather than buying paper.

  • Collection network economics
  • Reverse logistics network design
  • Recycler onboarding, audits and traceability
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Compliance heads

Data, Diligence and Traceability

For companies whose numbers cannot yet be defended.

  • SKU-level packaging master from source data
  • PWP compliance checks before credit purchase
  • Chain-of-custody documentation
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CSR teams

Impact Assessment and CSR Project Design

For CSR and sustainability teams that need measurable outcomes.

  • Schedule VII-aligned programme design
  • Baseline, monitoring and evaluation
  • BRSR and ESG reporting support
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03
How We Do It

A method, not a pile of filings

Compliance run as a system: diagnosed, designed, deployed and defended.

The Clymaco method
01
Diagnose

Applicability and exposure mapped across every market and stream.

02
Design

Registration, data and credit strategy planned before anything is filed.

03
Deploy

Filings, credit procurement and evidence collection, executed.

04
Defend

Audits, notices and EC queries answered with documents on hand.

Most vendors sell you Deploy. The exposure sits in Diagnose and Defend.

The EPR Maturity Index
L0
Unregistered

Not registered, or registered in one stream when several apply.

L1
Filing

Filings go in, numbers come from a spreadsheet nobody can reconstruct.

L2
Reconciled

Tonnage is traceable to source data and survives a query.

L3
Controlled

Liability is forecast, credits are bought on a plan, evidence is on demand.

L4
Circular

Compliance generates value: own take-back, recyclate supply, saleable surplus.

Most Indian producers we assess are at Level 1. Most think they are at Level 3.

04
EPR Control Portal

Advice on top. A system underneath.

Six modules hold your registrations, data, filings, credits and evidence.

Early access opens October 2026

Consultants leave you a report. We leave you a system, and we run it with you.

01

Obligation Register

Every stream, market and deadline in one register.

02

Packaging & Product Master

SKU-level packaging data, mapped to regulated categories.

03

Filing Calendar

Every return, every due date, no surprises.

04

Credit & Certificate Ledger

Purchases, balances and provenance, on record.

05

Liability & Cost Forecast

Next year's EPR cost, visible this year.

06

Evidence Vault

Audit-ready proof, on demand.

05
Point of View

What the market gets wrong

One technical position, stated plainly.

Exhibit 01 · Producer status under PPWR (EU) 2025/40

Most Indian exporters are being sold an EU registration they may not owe.

Under PPWR Article 3(1)(15), producer status attaches to whoever first makes packaging available on a member state's territory. Depending on your incoterms and your buyer's structure, that may be your importer, not you.

The exporter's exposure is real. It just sits in a different place: in the contract, in the buyer's questionnaire, in who carries the obligation on paper.

We run the producer status test before we sell you a registration.

06
Regimes in Force

One product. Dozens of regulators.

EPR is now law on every continent you sell to. Tap a marker to see what is in force.

Tap a marker
Regimes in force

India

  • CPCB multi-stream EPR, live
  • Eight streams in force
  • Plastic: PIBO · PWP · SIMP
  • ELV 2025 · Non-ferrous & C&D from 1 Apr 2026

India: eight streams live

Plastic packagingLive
PWM Rules 2016 · EPR Guidelines 2022 · Cat I-IV
E-wasteLive
E-Waste (Management) Rules 2022
BatteriesLive
Battery Waste Management Rules 2022
Waste tyresLive
H&OW Amendment Rules 2022
Used oilLive · FY 2024-25
H&OW Amendment Rules 2023
End-of-life vehiclesLive · 1 Apr 2025
Environment Protection (ELV) Rules 2025
Non-ferrous metal scrapLive · 1 Apr 2026
H&OW Amendment Rules 2025
Construction & demolitionLive · 1 Apr 2026
Environment (C&D) Waste Rules 2025
07
The Cost of Inaction

What non-compliance really means

EPR is no longer paperwork. Across India, the EU, the UK and the US, regulators enforce it at customs, on marketplaces and in audits.

€200K
Max fine per violation, Germany (VerpackG § 34)

Lose access to markets

Customs can hold consignments. Regulators in the EU, UK and US can suspend sales until registration and reporting are complete.

Per tonne
Environmental Compensation, routinely backdated

Environmental Compensation

CPCB and State Pollution Control Boards levy EC on unfulfilled targets, computed per tonne and applied to past periods.

Backdated
The card nobody budgets for

Liability discovered late

Understated returns do not disappear. They surface at audit, with past periods reconstructed and payable.

Delisted
Marketplaces now ask for EPR proof

Lose the shelf

Amazon, Flipkart and export buyers request registration and certificates. Listings that cannot prove compliance come down.

Why Act Now

The enforcement window has already closed

These are not upcoming deadlines. They are in force.

Now

CPCB is recovering Environmental Compensation on past shortfalls. Marketplaces are delisting non-registered sellers.

Since 1 Apr 2026

India's EPR net spans eight streams, adding non-ferrous metal scrap and construction and demolition waste.

Since 12 Aug 2026

The EU Packaging and Packaging Waste Regulation (EU) 2025/40 applies across all 27 member states.

2027

California SB 54 reporting and fee obligations begin. Oregon and Colorado are already invoicing producers.

2030

Binding EU recycled content and reuse targets lock in design decisions being made today.

The only choice left: pay for compliance, or pay the penalty.

Book a 20-minute call
08
The Opportunity

From cost centre to revenue centre

Done right, EPR stops being a fine you fear and becomes an asset you trade, a tender you win, a story your board can tell.

Today
  • Fees, fines and firefighting
  • Spreadsheets and scattered vendors
  • Compliance nobody can prove
With CLYMACO
  • Credits banked and traded
  • One portal, one source of truth
  • Audit-ready proof, on demand

Sell surplus EPR credits

PWPs and recyclers turn processing capacity into certificate revenue on the CPCB portal.

Win recycled-content contracts

Early movers on recycled-content mandates win tenders that laggards cannot even bid for.

Protect shelf space

EPR proof is now the entry ticket for marketplaces, export buyers and B2B supply chains.

Bank the ESG dividend

Audited circularity data feeds BRSR, ESG ratings and CSR narratives your board can quote.

09
For Every Team

Built for every seat at your table

EPR is not one department's job. Each role gets exactly what they need.

01

CXO

Live compliance health, exposure and credit position, one dashboard, boardroom-ready.

02

Finance

EPR cost projections, credit budgeting and penalty scenarios, before they hit the P&L.

03

Packaging & Product Design

Design-for-recycling requirements by market, Cat I-IV, PPWR, recycled-content rules, before the artwork is locked.

04

Compliance & Ops

Registrations, filings, deadlines and evidence, collated from every plant, vendor and marketplace.

05

Procurement & Sourcing

Compliance-checked PWPs and fair-price credits, buy proof, not promises.

06

Sustainability & ESG

Audited diversion data for BRSR, ESG ratings and CSR narratives, straight from the field.

10
Proof & Who We Are

Small by design.

You work with the person who does the work.

Built by a practitioner with 9+ years across EPR, circular economy, decarbonisation and ESG disclosure. Founded by IIM Lucknow alumni.

Clymaco Sustainability Services LLP

Kolkata · Mumbai · Brussels

Representative engagement

FIBC and jute packaging exporter

Rs 120 Cr turnover · exports to 4 EU member states

Situation: Selling packaging into Europe on distributor terms, with India EPR handled on paper by a consultant.
Complication: Producer status under PPWR had never been tested. Two member state registrations were missing. India returns understated flexible packaging.
What we did:
  • Ran the producer status test under Article 3(1)(15) for all four markets.
  • Completed the two missing registrations and appointed an authorised representative.
  • Rebuilt the India packaging master from SKU data and refiled.
Result: EU shipments clear without buyer questionnaires stalling. India filings now reconcile to sales data.
11
Engagement Model

Three ways to work with us

Fixed scope or running mandate, always on the same system.

Obligation review

Fixed-scope diagnostic across every market and stream you operate in.

Compliance mandate

Ongoing. Registrations, filings and credit procurement, run for you.

Project mandate

Defined build: a take-back channel, a reverse supply chain, a CSR programme.

Engagements are scoped and priced per mandate. No published rate card.

12
Talk to Us

Start with a conversation

A registration, a notice, a tender that demands EPR proof, whatever brought you here, we can help.

Reach CLYMACO

Email
alik@clymaco.com
Phone
+91 8240968144
Presence
Kolkata · Mumbai · Brussels

20 minutes with a specialist. Your obligations mapped, no sales pitch.