India Packaging Regulations

The regulatory landscape — what changed and why it matters

India's packaging regulations underwent a fundamental shift between 2021 and 2025. Three separate regulatory actions — the Single-Use Plastic ban, the EPR framework under Plastic Waste Management Rules 2022, and FSSAI's revised food packaging regulations — created a new compliance environment that directly affects how packaging is designed, produced, and labelled in India.

For the print and packaging industry, this has practical implications at every level: which substrates can be used, what must be printed on packaging, whether certain packaging formats are still permitted, and what documentation is required for export markets. Understanding this landscape is no longer optional — it's a core part of packaging specification.

EPR — Extended Producer Responsibility for Plastic Packaging

The EPR framework under the Plastic Waste Management (Amendment) Rules, 2022 (notified February 16, 2022) is the most significant packaging regulation change in India in decades. It makes producers, importers, and brand owners (PIBOs) directly responsible for the end-of-life management of their plastic packaging.

Who must comply

PIBOs — Producers (manufacturers of plastic packaging), Importers (anyone importing products in plastic packaging), and Brand Owners (brands whose products are sold in plastic packaging) must register on the CPCB centralised EPR portal at eprplastic.cpcb.gov.in. Registration was mandatory from April 2022 and CPCB issued show-cause notices for non-compliance from December 2024 onwards.

The four categories of plastic packaging

EPR targets — phased implementation through FY 2027–28

Collection and recycling targets increase annually. The framework allows PIBOs to purchase EPR certificates from Plastic Waste Processors (PWPs) to meet their obligations if they cannot collect/recycle directly. Certificate trading creates a market mechanism — but also a risk of "paper compliance" without actual recycling.

• FY 2022–23: Registration mandatory; initial collection targets assigned based on declared plastic consumption
• FY 2024–25: End-of-Life disposal caps came into effect; annual returns mandatory (CPCB extended deadline to March 31, 2026)
• FY 2025–26: Mandatory use of recycled content begins — minimum percentage of recycled plastic required in packaging
• FY 2027–28: Full implementation of all EPR targets across all categories

Practical implications for packaging designers and specifiers

• Design for recyclability: Single-material packaging (monomaterial) is significantly easier to recycle than multi-material laminates. EPR costs will be lower for Category I (rigid) than Category III (MLP). Brands are beginning to specify packaging that minimises EPR liability.
• Recyclable alternatives to foil laminates: Kotkamills ISLA board, mono-material PE or PP pouches, and recyclable barrier papers are being adopted specifically to reduce MLP classification and EPR costs.
• PCR (Post Consumer Recycled) content: From FY 2025–26, PIBOs must incorporate minimum percentages of recycled plastic. This creates demand for FG rPET and recycled PE/PP pellets — and changes how packaging is specified.

Single-Use Plastic Ban — what's banned and what isn't

Under the Environment (Protection) Act, the Ministry of Environment, Forest and Climate Change banned 19 categories of single-use plastic items from July 1, 2022. This ban affects manufacture, import, stocking, distribution, sale, and use.

What is banned (from July 1, 2022)

• Plastic earbuds with plastic sticks, balloons with plastic sticks
• Plastic flags (national flag and decorative)
• Candy and ice cream sticks made of plastic
• Polystyrene (thermocol) for decoration
• Plastic plates, cups, glasses, cutlery (forks, knives, spoons, straws)
• Plastic trays and wrapping films around sweet boxes
• Plastic invitation cards
• Cigarette packets with plastic wrapping
• Plastic or PVC banners under 100 microns
• Stirrers made of plastic

Plastic carry bag thickness rules

• Carry bags under 75 microns — banned from September 30, 2021
• Carry bags under 120 microns — banned from December 31, 2022
• Carry bags of 120 microns and above — permitted, but must bear name and address of manufacturer

Impact on print and packaging

The most direct print industry impact is the ban on plastic invitation cards and the thickness rules for carry bags. Printers who previously produced plastic-substrate invitation cards (for weddings, events) must now use alternative materials. The carry bag thickness rules affect printers producing bags — carry bags printed at under 120 microns are not permitted to be produced or sold.

QR/Barcode mandate on plastic packaging — from July 2025

The Plastic Waste Management (Amendment) Rules, 2025 (notified May 23, 2025) introduced a new requirement: all plastic packaging must carry product information in one of three ways from July 1, 2025.

The three permitted methods

1. Print a QR code or barcode on the plastic packaging — containing product-related information as specified by CPCB
2. Include the information in the product brochure/leaflet — that accompanies the packaged product
3. Print the Unique Identification Number (issued under any applicable law) on the packaging

The company must report to CPCB which method it has chosen. CPCB will publish a quarterly updated list of compliant entities.

Implications for print artwork and plate-making

The QR code requirement means that packaging artwork must now include a machine-readable code that links to EPR/product information. This has direct implications for artwork briefing, plate-making, and print verification. The QR code must be printed at sufficient resolution to be scannable — minimum 300 dpi, preferably in black on a white or light background. Test scan all QR codes before approving artwork for production.

FSSAI Food Packaging Regulations — what can and can't touch food

The Food Safety and Standards (Packaging) Regulations, 2018 (effective from January 2019) set out the requirements for all materials in contact with food products sold in India. These regulations are enforced by FSSAI (Food Safety and Standards Authority of India) and are separate from the EPR/plastic waste framework.

Core requirements for food contact packaging

• Migration limits: Overall migration limit of 60 mg/kg or 10 mg/dm² — the maximum permitted release of non-volatile substances from packaging into food simulants. Specific migration limits apply to certain contaminants.
• Food-grade materials only: All packaging in direct or likely contact with food must be of food-grade quality. This applies to plastics, metals, paper and paperboard, glass, and coatings.
• Indian Standards compliance: Packaging materials must comply with relevant IS standards — Schedule I for paper and paperboard, Schedule II for metal, Schedule III for plastic.
• Printing ink restriction: Printing inks on food packages must conform to standards. There must be no direct contact between the printed surface and food. In reverse-printed flexible packaging (where the print is between laminate layers), the ink must not migrate through to the food contact layer.
• No newspaper wrapping: Food must never be stored or wrapped in newspapers or similar printed materials not approved for food contact.

The printing ink rule — critical for flexible packaging

The restriction on direct contact between printed surfaces and food has specific implications for flexible packaging production. In most flexible packaging laminates, the print is on the inside of the outer film (reverse print) — between the film layers, not exposed to food. However, if there is any possibility of ink migration through the film or adhesive to the food contact layer, FSSAI requirements are violated. This is why:

• Low-migration UV inks are specified for pharmaceutical blister packaging
• Mineral-oil-free offset inks (from suppliers like Flint Group K+E) are growing in adoption
• Siegwerk and other ink companies provide specific food-packaging compliant formulations
• Adhesive systems (DIC, Toyo, Dow ADCOTE) for food packaging laminates must comply with migration limits

Recycled plastic in food packaging — permitted from March 2025

A significant regulatory change effective March 28, 2025: FSSAI's revised Food Safety and Standards (Packaging) Regulations now permit certain categories of food-grade recycled PET (FG rPET) in food packaging, under strict conditions.

Three approved recycling processes

• Super-Clean Recycling Process: Conventional recycling enhanced with an integrated decontamination step — surface treatment, high heat, and/or high vacuum in a controlled environment
• Melt-in Recycling Process: Virgin PET production enhanced to incorporate PET flakes in molten form, decontaminated through high heat and high vacuum
• Paste-in Recycling Process: PET flakes incorporated in paste form via partial glycolysis, with an integrated contaminant removal system

Standard mechanical recycling without decontamination is not permitted for food contact applications. The recycler must be approved by FSSAI (approved list published on FSSAI website).

Testing requirements for FG rPET

• Migration test: Quantitative analysis of substances migrating from PET containers into food simulants
• Challenge test: Validation test exposing virgin PET to surrogate chemicals, processed through the entire recycling process
• Extraction test: Quantitative analysis of substances present in the PET (virgin, rPET, or FG rPET)
• Declaration of Compliance: Business operator must issue a declaration stating how the product complies with applicable food contact standards

Exporting to EU — packaging compliance requirements

India is a major exporter to European markets — pharmaceuticals, FMCG, food, textiles, and industrial goods. European packaging regulations that apply to India's export packaging sector:

EU Regulation 1935/2004 — Food Contact Materials

The baseline EU regulation for any material intended to contact food. Requires that packaging does not transfer its constituents to food in quantities that could endanger human health, bring about an unacceptable change in the composition of the food, or bring about a deterioration in the organoleptic characteristics (taste, smell, appearance). Indian packaging destined for European food retail must comply — this is what drives demand for Iggesund Invercote, Metsä Board Prime, and other European-certified board in India's pharma and food export sector.

EU Plastics Regulation (EU) 10/2011

Specific regulation for plastic food contact materials. Sets positive lists of permitted substances, migration limits, and testing requirements. Being amended in 2024 to increase quality control standards. India's flexible packaging converters producing for European export must use inks, adhesives, and films tested to EU 10/2011 standards.

EU Packaging and Packaging Waste Regulation (PPWR)

The EU's new packaging regulation (replacing Directive 94/62/EC) — phased in from 2024–2030. Key requirements relevant to India's export packaging:

• Recyclability standards: All packaging placed on the EU market must be recyclable by 2030 — graded in classes A–E. Multi-layer laminates face challenges under these rules.
• Recycled content targets: Minimum recycled content in plastic packaging — 30% by 2030, 65% by 2040 for plastic bottles.
• Labelling requirements: Packaging must carry recycling information and material content labels standardised across EU member states.
• Reduced formats: Some packaging formats (sachets, single-serve) face restrictions for certain product categories.

Mineral oil contamination (MOSH/MOAH)

A specific concern for Indian packaging exports to Germany, Switzerland, and Scandinavian markets. Mineral oils (from printing inks, recycled paper, cardboard) can migrate into food. EU trading partners increasingly specify mineral-oil-free offset inks and require documentation. Flint Group's K+E mineral-oil-free offset ink range, and equivalent products from DIC/Sun Chemical and Siegwerk, are specified for EU export food packaging cartons.

Exporting to US — FDA packaging requirements

The US FDA regulates food contact materials under 21 CFR (Code of Federal Regulations). India's pharmaceutical packaging export sector is deeply familiar with 21 CFR — it is the standard referenced for pharma blister foil, SBS board, and packaging materials for FDA-regulated products.

FDA 21 CFR — Food Contact Materials

• 21 CFR Part 176: Indirect food additives — paper and paperboard components. Regulates what substances may be present in paper and board in contact with food.
• 21 CFR Part 177: Polymers — the primary regulation for plastic food contact materials. Lists permitted polymers and additives.
• 21 CFR Part 178: Adjuvants, production aids, and sanitizers — covers processing aids used in paper and board production.

Packaging for US food and pharma exports must use materials from suppliers who can provide 21 CFR compliance documentation. This is why Iggesund Invercote SBS board (which carries full FDA 21 CFR documentation) is specified by India's pharmaceutical packaging converters for export cartons — domestic SBS from ITC PSPD or JK Paper does not always carry the same level of documented international regulatory compliance.

FDA Drug Master File (DMF) and pharma packaging

For pharmaceutical packaging materials (blister foil, bottles, blisters, strips) exported to the US, the material and its manufacturing process must be registered in an FDA Drug Master File (DMF). This is a specialist regulatory area — packaging converters serving India's pharmaceutical export sector maintain DMF registrations with the FDA for their packaging materials and manufacturing processes.

US California Prop 65

California's Safe Drinking Water and Toxic Enforcement Act (Proposition 65) requires businesses to provide warnings before knowingly exposing anyone to a list of chemicals that cause cancer, birth defects, or other reproductive harm. For packaging exported to California retail, any packaging containing listed substances above threshold concentrations requires a warning label. Lead in printing inks (from recycled paper), cadmium in pigments, and DEHP in plasticised PVC are the most commonly encountered issues in packaging.

Complete regulatory timeline — India packaging 2021 to 2030

Compliance checklist for India packaging designers and producers