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India: prescribed sentences, not a universal recycling label
The Plastic Waste Management Rules 2016, as amended, create category-specific on-pack duties rather than one recycling label for every pack. Producers, importers and brand owners must print registration particulars unless a valid QR or barcode alternative, available from 1 July 2025, is used. Compostable and biodegradable plastics must carry prescribed statutory wording. A seedling logo is not a substitute. EPR on the CPCB portal is a separate reporting regime.
The question this report answers
India is often described as if it had a single recycling label. It does not. Rule 11 of the Plastic Waste Management Rules 2016 is the labelling article, and it is a set of category-specific sentences. Rule 11(1) requires each plastic carry bag, plastic packaging and multi-layered packaging to have, printed in English, the name and registration number of the producer or brand owner, and thickness for carry bags and plastic packaging. Multi-layered packaging requires name and registration number, not thickness. Compostable carry bags require the name and certificate number of the producer under Rule 4(h). Importers of carry bags, multi-layered packaging or plastic packaging must adhere to the same particulars. Provisos exclude plastic packaging used for imported goods, certain Legal Metrology Rule 26 cases after CPCB approval, and cases of technical infeasibility under cited BIS specifications after CPCB approval.
G.S.R. 201(E) of 14 March 2024 added the two sentences that most often go wrong. Rule 11(3): each plastic packaging or commodity made from compostable plastics shall bear “compostable only under industrial composting” and conform to IS/ISO 17088:2021. Rule 11(4): each biodegradable plastic packaging or commodity shall bear “Biodegradable in [specify number of days] only in the [specify recipient environment such as soil, landfill, water etc.]”. There is no PWM home-compostable category. G.S.R. 73(E) of 23 January 2025 inserted Rule 11(1A), allowing producers, importers and brand owners from 1 July 2025 to put the Rule 11(1) particulars in a barcode or QR code, a product brochure, or another unique number issued under law, with a duty to inform CPCB. The compostable and biodegradable wording in Rules 11(3) and 11(4) is not moved into that QR option.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| PIBO name and registration number | mandatory | Rule 11(1)(a)–(b), in English. Thickness for carry bags and plastic packaging. QR or barcode alternative from 1 July 2025 if CPCB is notified. |
| Recycled-plastic statement | if recycled plastic is used | Rule 11(2): “recycled having [percentage] of recycled plastic” plus the prescribed mark, conforming to IS 14534:2023, not the 1998 edition. |
| Compostable wording | if compostable plastic is used | Exactly “compostable only under industrial composting”. CPCB certificate. IS/ISO 17088:2021. The SOP also expects a QR from the CPCB certificate on carry bags and commodities. |
| Biodegradable wording | if biodegradable plastic is used | Days and recipient environment. Plastics other than compostable that degrade in a specified environment without leaving microplastics (Rule 3 as substituted 2024). |
| EPR (Schedule II) | mandatory; off-pack | Portal registration, category I–IV targets, certificate trading. Does not replace Rule 11. |
| Home-compostable claim | not a PWM category | The Rules do not supply a home-compostable sentence in place of Rule 11(3). |
Rule 11 as a labelling system
The obligated party is the producer, importer or brand owner, and for compostable or biodegradable plastics the manufacturer who must hold the CPCB certificate before marketing. Registration is with CPCB if operating in more than two States, otherwise with the State Pollution Control Board or Pollution Control Committee. Printing a recycler’s or converter’s number instead of the producer, importer or brand-owner registration number is a common defect. Thickness exemptions for compostable and biodegradable material under Rule 4(h) are not labelling exemptions. Multi-layered packaging is Rule 11(1)(b) on-pack and EPR Category III off-pack.
CPCB’s August 2022 compostable SOP, which revises 2018 and 2019 versions, additionally expects the label “COMPOSTABLE” IS/ISO:17088 in English and a regional language, the certificate number, and a QR generated from the CPCB certificate. The SOP is the operating procedure for certified compostable goods. It sits on top of the Rule 11(3) sentence rather than replacing it. Rule 10 points biodegradable protocols to a BIS standard as notified, certified by CPCB; until then, tentative IS 17899 T:2022. Rule 10(7) directs BIS to specify a separate colour or marking for compostable and biodegradable packaging. A colour-only differentiator is not, until that specification exists, a substitute for the statutory sentences.
The 2025 QR option, and what it does not swallow
Rule 11(1A) is optional, not a mandate. It may be used from 1 July 2025. CPCB must be informed and is to publish a quarterly list of producers, importers and brand owners using the pathway. Secondary notes describing a “2026 QR mandate” are not a gazette. CPCB’s rules-4 index had not listed the 2025 PDF when checked; the Official Gazette of G.S.R. 73(E) is the primary text. The QR pathway covers the Rule 11(1) name and registration particulars. It does not relocate the industrial-composting sentence or the biodegradable days-and-environment sentence.
EPR under Schedule II — portal registration, category I–IV targets, certificate trading — is a reporting and performance regime. It does not replace Rule 11. A Möbius loop is not the Indian recycled-plastic statement. Imported-goods provisos are not a blanket exemption for an Indian brand owner. The 2024 and 2025 amendments changed the words that appear on the pack. The current consolidated Rules, read with the Gazette of G.S.R. 73(E), are the text that controls.
Primary sources and verification
India. Plastic Waste Management Rules 2016, consolidated through 14 March 2024. UNEP LEAP consolidation
India. G.S.R. 133(E) of 16 February 2022 (EPR guidelines). CPCB PDF
CPCB. SOP for compostable plastic manufacturers (August 2022). SOP
CPCB. Certified manufacturers and sellers. CPCB
CPCB. EPR portal. eprplastic.cpcb.gov.in
CPCB. Rules index. cpcb.gov.in/rules-4
Gazette text controls. G.S.R. 73(E) of 23 January 2025 should be read from the Official Gazette. Last verified: 21 August 2026.