Stretch film and strapping under India's EPR in FY 2027-28: who carries the 20% recycled content?

Most factories buy stretch film the way they buy diesel: by the kilo, from whoever delivers on time, with nothing on paper beyond the invoice.

From 1 April 2027, that kilo carries a new question. Who has to show that 20% of it is recycled plastic?

Checked against official sources on 28 October 2026.

My short answer: India's Plastic Waste Management Rules put stretch film in Category II, flexible plastic packaging. The recycled-content target for Category II doubles from 10% to 20% on 1 April 2027. The company that makes the film is a "producer" and has a target on everything it manufactures. A brand owner has its own target on the plastic packaging it uses. What the Rules do not say in plain words is whether wrap and strap that a brand owner puts on its own outgoing pallets count as packaging it "uses". I have not found a CPCB clarification on that. So settle it in writing with your supplier, and keep evidence either way.

I am writing this as a film maker. We run blown film lines in Jaipur, so we are one of the parties this question is about. I have kept to the text of the Rules, and I have marked clearly where the text stops.

What changes on 1 April 2027?

The Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E), notified on 31 March 2026, gazette copy hosted by the Maharashtra Pollution Control Board) rewrote the recycled-content tables in Schedule II. The percentages are the same for producers, importers and brand owners.

What each party is measured against is different. Read the column headings in the gazette carefully.

1. A producer's target is a percentage "of plastic packaging manufactured for the year" (para 7.2(d)).
2. An importer's target is a percentage "of imported plastic packaging for the year" (para 7.3(d)). Recycled plastic inside the imported material does not count.
3. A brand owner's target is a percentage "of plastic packaging used in the year" (para 7.4(e)).

The targets do not apply where a law, a regulation or a mandatory Indian Standard does not permit recycled plastic. Anyone claiming that must cite the law in the annual return on the CPCB portal.

Which category is stretch film?

Schedule II para 5.1 defines Category II as "Flexible plastic packaging of 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".

Stretch film is flexible polyethylene, single layer or co-extruded. It fits Category II.

Strapping is less clear. The Rules do not name PP or PET strap, and they do not define "rigid". Ask your strap supplier which category it reports strap under on the CPCB portal. Then use the same category in your own records, so the two declarations match.

Who is a producer, a brand owner and an importer?

You might expect Schedule II to define these. It did, once. Its para 3, "Definitions", was deleted in 2022, and para 1.4 says the definitions in the Rules apply. These are the Rule 3 definitions, as shown in the consolidated text on the UNEP law database (as amended to 14 March 2024). The 2026 amendment did not change them.

1. "Producer" means "a person engaged in manufacturing of plastic packaging". It also covers makers of intermediate material for plastic packaging, and contract manufacturers working for a brand owner (Rule 3(t)).
2. "Brand owner" means "a person or company who sells any commodity under a registered brand label or trademark" (Rule 3(b)).
3. "Importer" means a person who imports for commercial use any plastic packaging, any commodity with plastic packaging, plastic sheets, resin or intermediate material (Rule 3(k)).

Two more lines of Schedule II matter here.

1. Para 1.3 says EPR "shall be applicable to both pre-consumer and post-consumer plastic packaging waste".
2. Para 4 leaves producers and brand owners that are micro or small enterprises out of the list of obligated entities. Importers get no such exemption.

Since 1 April 2025, a small enterprise is one with investment up to ₹25 crore and turnover up to ₹100 crore (S.O. 1364(E)). Check your own Udyam classification before you decide you are outside.

Three common cases

1. You make stretch film or strap. You are a producer, and the 20% runs on what you manufacture. If you are a micro or small enterprise, your EPR target passes to your resin supplier. But para 7.8 adds that "the target for use of recycled plastic content shall be fulfilled by such producers". So small film makers still owe the recycled content.
2. You import stretch film, or goods that arrive wrapped in it. You are an importer for that packaging. Recycled plastic in the imported film does not count, and you meet the target by buying certificates from others who exceeded theirs.
3. You buy film and strap from an Indian maker and wrap your own dispatches with them. If you sell under a registered brand or trademark and you are not micro or small, you are an obligated brand owner. This is the case the text leaves open.

Where the Rules stop, and CPCB has not answered

I want to be plain about this part.

A confident guess here can cost you a year of wrong returns.

1. A brand owner's target is measured on "plastic packaging used in the year". The text does not exclude transport packaging, and para 1.3 covers pre-consumer waste as well as post-consumer. But it does not name pallet wrap or strap that a brand owner applies to its own outgoing loads. I have not found a CPCB notice or published answer that says whether it counts.
2. A producer's EPR target subtracts the quantity supplied to brand owners (the "C" in its formula, para 7.2(a)). There is no matching subtraction in the recycled-content clause. The Rules do not say whether the film maker and the brand owner can both claim the same recycled tonne.
3. The 2026 amendment told CPCB to issue guidelines for audit and verification of recycled content "within a period of six months" from notification. That points to about the end of September 2026. I have not found them published.
4. The category for strapping is not stated.

So what do you do with an open question? Ask CPCB or your State Pollution Control Board in writing, and keep the reply with your annual return papers. A written answer from the regulator is worth more than any consultant's reading, mine included.

What to ask your film or strap supplier

Send these questions before you place film orders for FY 2027-28.

1. Your CPCB EPR registration number as a producer, and the category you report this film under.
2. The recycled plastic percentage in each grade you sell us, batch by batch, and how you measure it.
3. Whether that recycled plastic is post-consumer, or comes from factory scrap. The Indian table simply says "recycled plastic", but export buyers in the EU will want the post-consumer share separately.
4. The registered recyclers you buy from, and the certificates generated on the CPCB portal.
5. How the film will meet Rule 11(2): conformity with IS 14534:2023 and the recycled-content label and marking.
6. A written line on who reports this film's recycled content on the portal, you or us.

The last question is the most useful one. If both of you claim the same film, one claim is wrong. If neither of you does, both of you may be short.

Before you switch to recycled film, test it

Recycled polyethylene does not always behave like virgin resin. ExxonMobil, a resin maker with its own products to sell, says in its factsheet on recycled content in machine wrap that post-consumer feedstock usually contains LDPE, which can reduce stretch, and usually has gels, which can create holes. In ExxonMobil's own test, a C4-LLDPE film with 20% recycled content broke earlier than the same film without it.

Three checks on your own floor tell you most of what you need.

1. Cling. Wrap a pallet and look again after a few hours. The tail should still be stuck, and the film should not have lifted at the corners.
2. Puncture at the edges. Count holes and film breaks per shift against your current film, and note where on the load they start.
3. Weight per metre. Weigh a measured length and compare it with your current film. Our guide to stretch film, pre-stretch and film per pallet shows how.

For a fuller plan with lab tests and transit trials, see our guide on EU recycled-content rules for stretch film from 2030. If you export, one well-recorded trial can serve both rules.

Dates for your 2027 calendar

1. 1 April 2027: Category II recycled content goes to 20%, Category III to 10% and Category I to 50%.
2. 30 June 2027: the date in the Rules for filing the FY 2026-27 annual return on the CPCB portal (Schedule II para 10.6). Past deadlines have been extended, but no extension for this one had been announced by 28 October 2026.
3. All through FY 2027-28: keep supplier certificates and batch records. The FY 2027-28 return, due by 30 June 2028 under the same rule, is where the 20% will be checked.

If you buy stretch film or strap for your own dispatch, tell us your monthly usage through our contact page. We will tell you honestly what recycled-content paperwork we can and cannot give with it.

This is general information on the Plastic Waste Management Rules as amended up to 31 March 2026, not legal advice. Please confirm your own position with an EPR adviser or lawyer, and with CPCB in writing.