What SEBI asks, verbatim
Whether Extended Producer Responsibility (EPR) is applicable to the entity's activities (Yes/No). If yes, whether the waste collection plan is in line with the Extended Producer Responsibility (EPR) plan submitted to Pollution Control Boards? If not, provide steps taken to address the same
Disclose EPR applicability and compliance status with PCB-submitted plans under MoEFCC Uniform Framework for EPR.
Quoted from the SEBI BRSR Format as amended March 2025, with measurement guidance from the ICAI Background Material on BRSR, Revised Edition 2024, page 97.
In plain English
Tell whether the company’s activities fall under the Extended Producer Responsibility (EPR) rules – answer “Yes” or “No.” If it is “Yes,” say whether the company’s waste collection plan matches the EPR plan that was filed with the Pollution Control Board; if it does not match, explain what steps the company is taking to fix the gap. The information comes from the company’s own EPR plan and the filing records with the Pollution Control Board.
What a complete, assurance-ready answer contains
A complete, assurance‑ready answer states unequivocally whether EPR applies to the entity’s activities, then confirms compliance with the PCB‑submitted EPR plan, citing the specific PCB reference number and the date of submission. It includes a concise audit trail of the waste collection plan, showing alignment with the PCB plan, and lists any corrective actions taken if gaps were identified. A common gap is omitting the PCB reference or failing to provide evidence that the waste collection schedule matches the PCB‑approved plan.
Describes the completeness and granularity an assurer expects. No company figures are named.
Where the data comes from
Usually found in sourcing, product and lifecycle records. Forward to your Procurement or Product team.
Much of what BRSR asks for already exists in filings the company makes elsewhere, such as Pollution Control Board consents, PAT returns, hazardous-waste manifests and EPR registrations. The free gap analysis cross-references those filings against all 108 fields and shows which are already covered.
Does this apply to a services company?
Usually not. P2-E4 is one of eleven Section C disclosures that assume manufacturing operations. A pure services business with no factory, physical product or industrial effluent can mark it not applicable, but should record a short written justification rather than leaving it blank. A bare “not applicable” with no reason is what invites scrutiny.
See BRSR for IT services companies for all eleven, with the justification wording for each.
Frequently asked questions
What does BRSR P2-E4 ask for?
Tell whether the company’s activities fall under the Extended Producer Responsibility (EPR) rules – answer “Yes” or “No.” If it is “Yes,” say whether the company’s waste collection plan matches the EPR plan that was filed with the Pollution Control Board; if it does not match, explain what steps the company is taking to fix the gap. The information comes from the company’s own EPR plan and the filing records with the Pollution Control Board.
Is BRSR P2-E4 an Essential or a Leadership indicator?
P2-E4 is an Essential indicator, so it is mandatory for every BRSR filer. It sits under Principle 2, Products & Services.
Who inside the company holds the data for P2-E4?
Procurement / Product. Usually found in sourcing, product and lifecycle records. Forward to your Procurement or Product team.
Does P2-E4 apply to a services company?
Usually not. P2-E4 is one of eleven Section C disclosures that assume manufacturing operations. A pure services business with no factory, physical product or industrial effluent can mark it not applicable, but should record a one-line written justification rather than leaving it blank.
What does a complete answer to P2-E4 look like?
A complete, assurance‑ready answer states unequivocally whether EPR applies to the entity’s activities, then confirms compliance with the PCB‑submitted EPR plan, citing the specific PCB reference number and the date of submission. It includes a concise audit trail of the waste collection plan, showing alignment with the PCB plan, and lists any corrective actions taken if gaps were identified. A common gap is omitting the PCB reference or failing to provide evidence that the waste collection schedule matches the PCB‑approved plan.
Other disclosures under Principle 2
R&D and capex spent on cleaner / safer products & processes (% of total R&D and capex)
Do you have sustainable sourcing? If yes, % of inputs sourced sustainably
How you reclaim / recycle / dispose products at end-of-life (plastics, e-waste, hazardous, other)
Have you done a Life Cycle Assessment (LCA) on any product / service? (Yes/No + details)
Any major social / environmental risks from your products found via LCA, and action taken
% of recycled or reused input material used in production (by value)
See P2-E4 against a real client
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