India keeps plastic waste targets intact, but eases path to compliance

India’s latest amendment to its Plastic Waste Management Rules leaves headline recycling targets unchanged, but introduces a series of provisions that allows companies to shift their compliance deadlines.

These provisions include allowing companies that fail to meet their targets in 2025–26 to carry forward the shortfall for up to three years, provided they make up at least a third of the deficit annually. Prior to this, companies were bound to comply annually.

“The unfulfilled target for the year 2025–26 may be carried forward for three subsequent years starting 2026–27… provided that at least one-third of the unfulfilled target is met in each of those years, until the entire carried-forward target is achieved,” says a gazette notification by the Environment Ministry dated March 31.

The rules also formalise a system of tradable certificates, enabling companies to meet their obligations by purchasing credits from others that exceed their targets. While this creates flexibility and may reduce compliance costs, it also means firms are not necessarily required to recycle their own plastic footprint.

Targets also do not apply where other regulations — for example, food safety standards — restrict the use of recycled plastic. This could exclude significant segments of packaging from the mandate, particularly in the food and beverage sector.

The 2026 amendment retains a phased set of targets for recycled content and reuse in plastic packaging, continuing the trajectory first introduced under the Extended Producer Responsibility (EPR) framework in 2022, which for the first time specified collection targets for plastic waste producers and users of plastic packaging.

For 2025–26, producers, importers and brand owners must ensure that rigid plastic packaging (Category I) contains at least 30% recycled material, rising to 60% by 2028–29. Flexible plastics (Category II) are subject to a 10% requirement in 2025–26, increasing to 20% thereafter, while multi-layered plastics (Category III) must meet a 5% threshold, rising to 10%. In parallel, the rules mandate reuse obligations for rigid packaging: 10% for smaller containers (0.9–4.9 litres), 70% for large water packaging, and 10% for large non-water packaging in 2025–26, with incremental increases over time.

Category 1 includes PET water or soft drink bottles or HDPE milk bottles / shampoo bottles. These are the easiest to collect.  Category 2 includes Plastic carry bags / grocery bags, snack or chips packets (single-layer flexible film). Category 3 or multi-layered plastic, such as Tetra Pak cartons, foil snack wrappers, are the hardest to collect.

India’s plastic waste rules require companies to collect and process the equivalent of 100% of the plastic they introduce into the market by 2024–25, marking the final phase of the Extended Producer Responsibility (EPR) rollout. However, there is no public evidence to suggest that this target has been fully achieved in practice. No comprehensive public dataset or official assessment demonstrates system-wide compliance, and much of the reporting continues to rely on self-declarations through a centralised portal.

The Environment Ministry has said that, while recycling has scaled up significantly under EPR, it is still far from complete coverage. Since the framework came into force in 2022, over 20.7 million tonnes of plastic packaging waste have been recycled. However, annual generation remains high — about 4.13 million tonnes in 2022–23 alone.

The Central Pollution Control Board (CPCB) in 2023 had unearthed more than 6,00,000 fake pollution-trading certificates from audits at four plastic-recycling companies in Gujarat, Maharashtra and Karnataka.