EPR and recycled content: what India's plastic rules mean for flexible packaging

Extended Producer Responsibility (EPR) makes producers, importers and brand owners responsible for the plastic packaging they put on the market. In April 2026 the Ministry of Environment, Forest and Climate Change amended the Plastic Waste Management Rules again, strengthening recycled-content, reuse and enforcement provisions. Here is what flexible packaging buyers should know.

The four packaging categories

• Category I: rigid plastic packaging.
• Category II: flexible plastic packaging of a single layer or multiple layers of different plastics, plus plastic sheets, carry bags, sachets and pouches.
• Category III: multilayered packaging with at least one layer of plastic and at least one layer of another material, such as aluminium foil or paper.
• Category IV: plastic sheets and carry bags made of compostable plastic.

Most pouches and laminates fall into Category II (all-plastic laminates, including mixed ones such as PET/PE) or Category III (laminates with foil or paper). Category matters for your targets, but recyclability depends on the structure itself, which is why mono-material designs are gaining ground.

Recycled content obligations

Brand owners must use rising percentages of recycled plastic in their packaging. As reported, the targets rise to:

• Category I: from 30% in 2025–26 to 60% from 2028–29;
• Category II: from 10% to 20% by 2028–29;
• Category III: from 5% to 10% by 2028–29.

Exemptions apply where FSSAI, CDSCO or another statutory body restricts recycled plastic, for example in some food-contact uses. Unmet 2025–26 targets for food-contact applications can be carried forward for up to three years. Recycled packaging must conform to IS 14534:2023 and carry labels showing recycled content.

Enforcement is moving closer to the ground

The 2026 amendment decentralises enforcement to Urban Local Bodies and panchayats, with state-level monitoring committees and audits by Registered Environment Auditors. Expect more questions from regulators, and from your customers, about what your packs are made of.

Practical steps for brands

1. Map every SKU's packaging to the right EPR category.
2. Identify packs that could move to mono-material structures.
3. Ask your converter for material declarations for every structure.
4. Plan recycled content where food-safety rules allow it, for example in outer or non-contact layers.

How we can help

We can document the structure of every pack we make and suggest simpler, more recyclable alternatives. Get in touch.

General information only. Targets and dates should be checked against the official Gazette notifications and CPCB guidance.