CHAPTER 4: Classification of Plastic Packaging under EPR (Categories I–V)

Introduction:

For businesses involved in manufacturing, importing, or branding products having plastic packaging, understanding the distinct categories of plastic packaging under EPR is essential for compliance with the Plastic Waste Management Rules, 2016.

Plastic packaging waste is broadly divided into five categories under EPR regulations, based on composition, physical and chemical properties and recyclability profiles. Understanding the correct classification of plastic packaging waste allows obligated entities to develop targeted action plans for efficient management of plastic packaging waste and ensuring compliance with the recycling targets.

Original Rule Reference

• Schedule II, Rule 5 of the PWM (Amendment) Rules 2022 (G.S.R. 321(E)).
• Amendment 4 CPCB EPR Guidelines 2022 for category-wise targets.
• Rule 9(1) (linking obligations to these categories).

 Plastic packaging under EPR is classified into five categories, each reflecting material structure and recyclability. Obligations vary accordingly.

Category	Description	Typical Examples
I	Rigid plastic packaging	Bottles, caps, drums and any kind of containers etc.   These are further sub-divided based on the capacity of weight or liquid they can handle:   Less than 0.9litres/kg 0.9-4.9litres/kgs Above 4.9 liters/kgs   EPR rules also mandate re-use of plastic packaging for containers over 0.9litres/kg holding capacity.
II	Flexible plastic packaging (single layer or multilayer with same polymer)	Plastic sheets, covers made of plastic sheets, Pouches, sachets, shrink wrap or carry bags, metalized plastics.
III	Multilayered plastic packaging (MLP) with different polymer layers or material combinations	Packaging where one layer is plastic and the others foil/paper, etc.
IV	Plastic sheet or carry bags & used for packaging and commodities made of compostable plastics.	Compostable Carry bags
V	Plastic sheet used for packaging or carry bags and commodities made out of biodegradable plastics.

 
Category 1: Rigid Plastic Packaging

Rigid plastics are hard, durable plastics that maintain their shape and can be easily recycled.

These are generally made out of

• Polyethylene Terephthalate (PET): Commonly used in beverage bottles and food containers.
• High-Density Polyethylene (HDPE): Found in detergent bottles, milk jugs, cartons and caps.
• Polypropylene (PP): Used in jars, personal care product packaging,
• Other thermoplastics such as Poly Vinyl Chloride (PVC) and Polystyrene (PS) may also fall here.

These plastics are highly recyclable due to their thermoplastic nature, which makes it possible to process them by melting and subsequently reshaping with some degradation in their chemical and physical properties. Category 1 plastics constitute a large share of plastic packaging waste and are favored in recycling markets because of their economic value and wide applicability.

The Ministry of Health & Family Welfare (MoHFW) released official notification on May 23, 2025, adopting the Food Safety and Standards Authority of India (FSSAI)'s revised guidelines permitting rPET (recycled PET) in Food Contact packaging (FCM).

Category 2: Flexible Plastic Packaging

Flexible plastic packaging refers to plastic packaging that is single layer or multilayer (more than one layer with different types of plastic), plastic sheets or like and covers made of plastic sheet, carry bags, plastic sachet or pouches.

This includes Metalized plastic packaging - which is a flexible material created by coating polymer films (typically PET, BOPP, or PE) with a microscopically thin layer of vaporized metal, usually aluminum.

This packaging was earlier categorized into category 3 of plastic packaging and since the amendment on 14^th March 2024, it has been excluded from the definition of multi-layer plastics under category 3 and thereby resulting in a re-categorisation to category 2.

Category 3: Multilayered Plastic Packaging (MLP)

Multilayered plastic packaging refers to plastic packaging with at least one layer of plastic and at least one layer of material other than plastic).

It means any material used or to be used for packaging and having at least one layer of plastic as the main ingredients in combination with one or more layers of materials such as paper, paper board, polymeric materials, aluminum foil, either in the form of a laminate or co-extruded structure. Examples are Milk/ juice that come in Tetra packs.

Category 4: Compostable Plastics

Category 4 of plastic packaging includes - Plastic sheet or like used for packaging as well as carry bags and commodities made of compostable plastics.

Compostable plastic mean plastic that undergoes degradation by biological processes during composting to yield CO2, water, inorganic compounds and biomass at a rate consistent with other known compostable materials, excluding conventional petro based plastics, and does not leave visible, distinguishable or toxic residue.

Carry bags and commodities made from compostable plastics are not required to comply with the minimum thickness requirements of 120 microns that is otherwise applicable to carry bags made out of virgin or recycled plastic.

Carry bags and commodities made from compostable plastics shall conform to the Indian Standard: IS/ISO 17088:2021 titled as Specifications for Compostable Plastics.

However, the manufacturers of compostable plastic carry bags or commodities permitted shall obtain a registration from CPCB and ensure that they comply with the marking and labelling guidelines under Rule 11 of the PWM, Rules.

Wherever they have food applications they should also ensure compliance with Food Safety and Standards Authority of India.

BIS shall specify separate colour or marking for plastic packaging and commodities made from compostable plastics.

Each plastic packaging or commodity made from compostable plastics shall bear a label compostable only under industrial composting.

Further, plates, cups, glasses, cutlery such as forks, spoons, knives, straw, trays, wrapping or packing films around sweet boxes, invitation cards, and cigarette packets, plastic or PVC banners less than 100 micron, are banned with effect from 1^st July 2022. However, relaxation on this ban is available if they are made from Compostable plastic. 

While compostable plastics offer environmental benefits by diverting waste from landfills, they require appropriate composting infrastructure to be able to utilize this potential. EPR frameworks often treat these separately to ensure they are not mixed with conventional plastics, which could contaminate recycling streams.

The manufacturer of commodities made from compostable plastics shall report the quantity of such commodities introduced in the market and pre-consumer waste generated to the Central Pollution Control Board

Category 5: Biodegradable or Other Special Plastics

Biodegradable plastic means plastics, other than compostable plastics, which undergo degradation by biological processes in specific environment such as soil, landfill, sewage sludge, fresh water, marine, without leaving any micro plastics or visible or distinguishable or toxic residue, which has adverse environment impact.

Category 5 of plastic packaging refers to plastic packaging such as plastic sheets or the likes of it used for packaging as well as carry bags and commodities made of biodegradable plastics.
For example, Polylactic Acid (PLA), Polyhydroxyalkanoates (PHAs), starch-based blends, and Polybutylene succinate (PBS). These plastics are used in packaging, agricultural films, cutlery, and medical devices.

EPR assigns special management protocols for these plastics, focusing on recovery through composting or similar appropriate waste-to-energy processes. These materials require tracking and specified collection mechanisms to ensure that contamination of recycling streams is prevented. Protocols for Compostable and biodegradable plastic materials are as under:

• Determination of the degree of degradability and degree of disintegration of plastic material shall be as per the protocols of the Indian Standards listed in Schedule I.
•  The compostable plastic materials shall conform to the IS / ISO 17088:2021, as amended from time to time.
• The biodegradable plastics shall conform to the standard notified by the Bureau of Indian Standards and certified by the Central Pollution Control Board.  Until a standard is notified, biodegradable plastics shall conform to tentative Indian Standard IS 17899 T:2022 as notified by the Bureau of Indian Standards. 
• As a transitory measure, provisional certificate for biodegradable plastics, shall be issued by the Central Pollution Control Board, in cases, where an interim test report is submitted, for an ongoing test, which covers the first component of the IS 17899 T:2022 relating to biodegradability given at Sl. No. (i) or Sl. No. (ii) of Table 1 or Sl. No. (i) of Table 2 of the IS 17899 T:2022: Such provisional certificate shall be valid till 30th June 2023 with the condition that production or import of biodegradable plastics shall cease after the 31^st March, 2024.
• The interim test report shall be obtained from the Central Institute of Petrochemical  Engineering and Technology or a laboratory recognised under the Laboratory Recognition Scheme, 2020, of the Bureau of Indian Standards or laboratories accredited for this purpose by the National Accreditation Board for Testing and Calibration Laboratories, and they shall certify the bio-degradation of plastic is in line with IS 17899 T:2022.
• Provided that where testing of biodegradable plastic had commenced prior to the registration of a laboratory, and the report is in conformity with IS 17899 T:2022, the Central Pollution Control Board shall ask the applicant for re-testing and permit the production or usage of such biodegradable plastic, till the period the test report is received from duly recognized laboratory subject to furnishing of bank guarantee equal to the amount of Environment Compensation leviable under rule 18:

Provided further that the bank guarantee shall be forfeited if the result of such test does not conform to IS 17899 T: 2022. The various Categories of plastic are either required to be recycled, reused or co-processed based on the target of the obligated entities. Only registered plastic waste processors can process the plastic packaging waste and then are required to issue digital certificates to the PIBOs / SIMPs on the CPCB portal.

It is pertinent for all obligated entities to compute their plastic footprint. Some of the key points to note in Plastic Footprint Calculation are.

1. Plastic footprint boundaries for EPR must include all three levels of packaging: what reaches the consumer (primary), what groups consumer units (secondary), and what protects loads in logistics (tertiary), wherever these are made of plastic.
2. The total packaging must be classified into the five categories mentioned above (rigid, flexible, multilayered with non‑plastic, compostable and Biodegradable). This is because targets, obligations and portal reporting are defined at this category level.

Primary packaging

• Primary packaging is the first layer in direct contact with the product and is usually the smallest saleable unit (bottle, pouch, tube, wrapper, etc.).

Secondary packaging

• Secondary packaging groups multiple primary units for sale, handling or display (shrink‑wrapped bottle bundles, corrugated boxes with plastic strapping/tape, over‑wraps, etc.).​

Tertiary (transport) packaging – definition and data needs

• Tertiary or transport packaging protects grouped secondary packs in storage and transport (stretch/shrink wrap, pallet top sheets, plastic corner/edge protectors, plastic strapping, etc.).​
• The Obligated entities need to report and classify each of the items into either of the five categories of plastic.
• Category I Plastics such as pallets and trays which can be reused as a part of tertiary packaging are exempted from being accounted for while the computation of targets for the obligated entities. 

 Inter category Set off. 

EPR targets and credits must be met and traded category‑wise (I–V) and obligation‑wise (reuse, recycling, end‑of‑life), with only limited and one‑way offsetting allowed between some buckets as per the PWM Rules, 2016 and EPR Guidelines as implemented through the CPCB portal.

Clause 8 of the Schedule II to the PWM rules, 2016 lays down the guidelines for the offsetting of surplus Extended Producer Responsibility certificates, carry forward and offsetting against previous year Extended Producer Responsibility targets and obligations, and sale and purchase of surplus Extended Producer Responsibility certificates.

The key points to note in this regard are as under:

1. Surplus in one category can only be used for offsetting, carry forward and sale in the same category.
2. Within the obligations, surplus credits of reuse can be offset against the targets of reuse, recycling and end of life disposal.
3. Any surplus recycling credits can be off set against recycling and end of life disposal targets.
4. However, surplus credits of end of life can be adjusted only against end-of-life targets and cannot be used to meet the obligations of reuse or recycling.

The obligated entities can purchase credits from PWPs or surplus credit certificates from other obligated entities or through the CPCB Notified credit exchange portal - EPRETP, as long as the certificates meet the targets and offset guidelines as mentioned above.

All such transactions for the purchase, sale or exchange of credit shall be done only with the centralized portal developed by the CPCB.

 Verification and Documentation

Each category must be declared on the CPCB portal with tonnage split. PWPs upload certificates category-wise. This enables traceability and prevents double counting.

 Summary

Compliance Element	Rule/Notification	Responsible Entity	Verification
Category Declaration	Schedule II	PIBO	CPCB Portal
Recycling Certificate	Rule 9(2)	PWP → PIBO	Digital
Recycled Content Declaration		Producer	Third-party audit

 Categorization under Schedule II brings material science into compliance management. By differentiating rigid, flexible, multilayered, and sheet-based plastics, the Rules align environmental responsibility with technical feasibility. The matrix of collection, recycling, reuse, and recycled content ensures that India’s EPR system moves from mere collection towards a circular economy model for plastics.