Come April 1, the environment ministry’s guidelines mandating the use of recycled and reused plastic in packaging will take effect, significantly impacting the FMCG industry, which faces a double challenge—how to meet these norms and, if unable to sustain them, how to protect sales.
According to sources, the FMCG sector has approached the government, seeking relaxation in the guidelines issued by the environment ministry back in February 2022, given the industry’s claim that food-grade plastic recycling and reuse capacities are insufficient to meet requirements.
From as small as a sugar-boiled candy wrapper to pan masala sachets, biscuits, chips, and namkeen, all are sold in plastic packaging. However, since these are food products, the governing authority responsible for ensuring the food-grade safety of recycled or reused plastic packaging lies not just with the environment ministry but also with FSSAI.
Meanwhile, many FMCG majors are already attempting to recycle their plastic packaging but are uncertain about meeting the reuse clause. The environment ministry clearly states that reuse is only feasible for category-I rigid plastic such as PET.
As per the guidelines, since the brand owner handles packaging, the responsibility of compliance lies with them.
By FY26, the brand owner must reuse 10% of packaging for products sold in 0.9L–4.9L sizes and 70% for those above 5L.
According to FSSAI, since 2018, the reuse of plastic packaging below 5 litres has not been permitted in India. Reuse is only allowed for durable, easy-to-clean, and disinfectable containers of 5 litres and above.
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Additionally, the brand owner is required to recycle 50% of plastic packaging waste based on annual sales, though it does not have to be reused for the same products.
This does not mean that the brand owner has to use this recycled plastic waste to re-pack their products, rather the only responsibility is to ensure the right % of waste is collected and is recycled, which can be used in any industry.
Another requirement is that a certain portion of new packaging must be made from recycled plastic. Under these, there are 3 categories, first category states that the brand owner has to use a minimum of 30% of recycled packaging. And the 30% is of the total sales of the rigid plastic, like PET Bottle.
In the second category—10% of flexible plastic, such as wrappers, pouches, milk and oil packets, or chocolate and pan masala wrappers, must be made from recycled material.
Third category pertains to multi-layer plastic packaging – where the brand owner has to use minimum of 5% of recycled plastic sold in the year FY26. This multi-layer plastic is for example – a disposable coffee mug, which is of a paper or board content from outside but has a very thin layer of plastic inside.
For meeting these recy