# India’s four big FMCG brand owners all say they meet plastic EPR, but each proves it in a different unit > Hindustan Unilever, ITC, Marico and Nestlé India each report full compliance with plastic EPR under Schedule II of the Plastic Waste Management Rules, 2016, yet they disclose it four different ways, and none of them publishes the category-by-category figures that the Rules actually test. Publisher: Strategic Packaging Insights Published: 2026-10-26 Last updated: 2026-10-26 Page: https://www.strategicpackaginginsights.com/insights/india-fmcg-plastic-epr-hul-itc-marico-nestle/ **Hindustan Unilever, ITC, Marico and Nestlé India each report full compliance with plastic EPR under Schedule II of the Plastic Waste Management Rules, 2016, yet they disclose it four different ways, and none of them publishes the category-by-category figures that the Rules actually test.** Strategic Packaging Insights (SPI) read the latest sustainability filings of the four companies against the Gazette texts from 2022 to 2026. Only ITC and Nestlé India publish a recycled tonnage within what they manage, and that split matters more each year as the minimum recycling level for rigid plastic climbs to 80% of the EPR target from 2027-28. ## Executive summary India's plastic packaging EPR has run since G.S.R. 133(E) of 16 February 2022 inserted Schedule II into the Plastic Waste Management Rules, 2016. It sets four plastic categories, a collection target that reached 100% of the eligible quantity in 2023-24, minimum recycling levels that step up every April, recycled-content shares from 2025-26 and environmental compensation for any shortfall. The 2024, 2025 and 2026 amendments added a certificate price band, packaging information rules, exemptions and an importer certificate route (Sources 1 to 4). The four Indian FMCG brand owners in this piece all say they comply. Hindustan Unilever (HUL) bought 261,214 tonnes of EPR credits in FY 2025-26; ITC managed about 72,500 tonnes; Marico reports 28,013 tonnes; Nestlé India about 25,000 tonnes (Exhibit 1). Those numbers are not comparable. One is credits bought, one is waste managed, one is "recycled or disposed" and one is "managed through recycling and other approved recovery". The gap that matters is inside the tonnage. Schedule II requires a minimum share of each category's EPR target to be met by recycling: 60% for rigid plastic in 2025-26, 70% in 2026-27 and 80% from 2027-28. ITC reports about 43% recycled within what it managed in FY 2025-26 and Nestlé India 57.5% in FY 2024-25, while HUL reports its whole quantity as safely disposed because recycling is hard to trace (Exhibit 8). None of the four splits its figures by category, so the test cannot be run from outside. Recycled content is moving, from a low base. HUL reports 9.4% post-consumer recycled plastic in FY 2025-26, up from 6.1%; Marico 14.9%, up from 2.15%; ITC 3.22%, up from 0.44%; Nestlé India 1.5% of input material in FY 2024-25 (Exhibit 9). The statutory shares for 2026-27 are 40% for rigid, 10% for flexible and 5% for multilayer plastic. For leaders, three moves follow. Report EPR by category and by route, as the annual return already requires. Price certificate demand against the band CPCB is to set between 30% and 100% of environmental compensation, because waiting is dearer than buying (Exhibit 11). And plan rigid-pack resin for the 2027-28 step now, since both the recycling floor and the recycled-content share rise on 1 April 2027. ## Key findings 1. All four companies report full plastic EPR compliance: HUL says it is "meeting its EPR obligation in totality at a national level", ITC and Marico report 100% compliance and Nestlé India says it has been plastic neutral since 2020 (Sources 6, 7, 10, 12). 2. HUL bought 261,214 tonnes of EPR credits in FY 2025-26, up 26.2% on 207,005 tonnes in FY 2024-25, and reports all of it as safely disposed rather than recycled (HUL BRSR FY 2025-26; SPI calculation). 3. ITC managed about 72,500 tonnes against 73,762 tonnes of plastic packaging placed in FY 2025-26, with about 31,200 tonnes recycled. **SPI calculation:** that is 43.0% recycled, against a Category I floor of 60% for 2025-26 and a Category II and III floor of 40% (ITC BRSR 2026; G.S.R. 133(E)). 4. Nestlé India's FY 2024-25 BRSR covers 12 months, not 15: the 15-month period was the one before it. Its 24,645 tonnes in FY 2024-25 and about 25,000 tonnes in FY 2025-26 are therefore close to flat, about 1.4% apart (Sources 11, 12; SPI calculation). 5. Recycled content rose at three of the four in their latest year: HUL 6.1% to 9.4%, Marico 2.15% to 14.9% and ITC 0.44% to 3.22%; Nestlé India reports 0.70% to 1.5% across its two latest BRSR periods (company filings). 6. **SPI calculation:** under the certificate price band in the Hindi text of G.S.R. 201(E), a company that pays compensation and closes its gap within a year spends 0.25 times the compensation rate per tonne more than one that buys certificates on time, and 0.60 times more if it takes three years. ## The rulebook: four categories, three target types Schedule II applies to producers, importers and brand owners of plastic packaging, each with its own target clause: 7.2 for producers, 7.3 for importers and 7.4 for brand owners (Source 4). All four companies here file as brand owners; Nestlé India's BRSR states it outright (Source 11). Plastic waste processors register too, but only to generate the certificates the others use. The categories decide everything that follows, because targets, recycling floors and certificates all run category by category (Exhibit 2). Clause 8.2 lets a surplus be used only within the same category, so a company that over-collects flexible film cannot cover a shortfall in rigid bottles (Source 4). Three kinds of target sit on top of the categories. The first is the EPR target itself, a collection duty set as a share of an "eligible quantity". For a brand owner, clause 7.4(a) defines that quantity as the average weight of virgin plastic packaging bought and placed on the market over the last two financial years, plus average pre-consumer waste (Source 4). The target was 25% of it in 2021-22, 70% in 2022-23 and 100% from 2023-24 (Exhibit 3). The second is the minimum recycling level. Clause 7.4(c) requires a rising share of each category's EPR target to be met by recycling rather than by end-of-life disposal such as co-processing in cement kilns or waste-to-energy. Clause 7.2(c) adds that only plastics that cannot be recycled may be sent for end-of-life disposal (Source 4). The Hindi text of G.S.R. 201(E) of 14 March 2024 carries the same levels for Categories I to III, as SPI reads it (Source 3). The third is recycled content. G.S.R. 237(E) of 31 March 2026 restated the category shares in clauses 7.2(d), 7.3(d) and 7.4(e), with a different base for each role: packaging manufactured for producers, imported for importers and used for brand owners (Source 1). The SPI tracker records that the same percentages already appeared in the 2022 Schedule, so the 2026 change is in exemptions, importer certificates and carry-forward rather than in the numbers ([PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/)). Reuse adds a fourth duty for brand owners of rigid packs from 0.9 litres or kilograms, covered in [SPI's guide to the 2026 rules](https://www.strategicpackaginginsights.com/insights/india-plastic-packaging-rules-2026/) and in [PR-IN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-003/). This piece does not repeat it, because none of the four companies reports a reuse share. ## Four notifications since 2022 changed how the duty works The Rules are amended by Gazette notification, not by Parliament. G.S.R. 237(E) lists every amendment to the 2016 Rules in its closing note, from G.S.R. 320(E) of 18 March 2016 to G.S.R. 73(E) of 23 January 2025 (Source 1). Four of them carry the EPR changes that matter to an FMCG brand owner (Exhibit 5). **2024 (G.S.R. 201(E), 14 March 2024, F. No. 17/6/2023-HSM).** The amendment rewrote the definitions of importer, manufacturer, producer and seller, barred manufacturers from selling plastic raw material to an unregistered producer or seller, and set a 30-day deemed approval for registration applications (Source 3). It brought compostable and biodegradable plastics into EPR, with certificates for biodegradable plastics to be issued by local authorities. The recycled-content label must follow IS 14534:2023. For brand owners, the clause with most money attached is new paragraph 8.9: in SPI's reading of the Hindi text, CPCB fixes the highest and lowest prices for EPR certificates at 100% and 30% of the environmental compensation leviable for missed obligations, and paragraph 8.10 confines portal trades to that band. SPI has not yet confirmed the English wording. **2025 (G.S.R. 73(E), 23 January 2025).** A short notification inserted rule 11(1A): from 1 July 2025, the packaging information that rule 11(1) requires may be given by a barcode or QR code on the pack, in a product brochure, or through a unique number issued under another law (Source 2). Producers, importers and brand owners must tell CPCB which route they use, and CPCB publishes and updates the list every quarter. A new rule 19 makes any contravention liable to penalty under section 15 of the Environment (Protection) Act, 1986, which the Jan Vishwas Act of 2023 set at INR 10,000 to INR 15 lakh, plus INR 10,000 a day while it continues ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)). **2026 (G.S.R. 237(E), 31 March 2026, F. No. 17/4/2025-HSM).** The draft, G.S.R. 365(E), was published on 3 June 2025. The final text restated the recycled-content table, exempted packaging where a law or mandatory standard bars recycled plastic, stopped importers counting recycled plastic already in imported material, and allowed unmet 2025-26 recycled-content targets for food-contact packaging to be carried forward for three years at one third or more a year (Source 1). It also defined end-of-life disposal to cover co-processing in cement and steel plants, waste-to-energy, waste-to-oil and road construction, and let a Registered Environment Auditor run the paragraph 12.4 and 13.1 checks. It did not change the collection targets or the minimum recycling levels. ## Compensation and certificates: what a shortfall costs Clause 9 of Schedule II imposes environmental compensation on any unmet target, under the polluter pays principle, with CPCB to lay down the guidelines (clause 9.2). CPCB levies it on entities in more than two states and State Boards on the rest ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)). The rupee rate is not in the Schedule, and SPI has not yet confirmed CPCB's current rate table, so this piece expresses every cost as a multiple of that rate. Compensation does not settle the duty. Clause 9.5 keeps the unmet quantity alive for three years and refunds 75% of the compensation if the gap is closed within one year, 60% within two and 40% within three; after that the amount is forfeited (Source 4). The 2024 price band then ties the certificate market to the same rate (Exhibit 6). The certificates themselves come from processors. Clause 11.5 says only processors registered under the Rules may provide certificates for plastic waste processing, except for plastic used in road construction (Source 4). Surplus certificates can be sold, carried forward or set against a past shortfall, but only within the category that earned them (clauses 8.1 to 8.3). The market is large: the SPI tracker records, from CPCB's 6 July 2026 affidavit to the National Green Tribunal, 3,079 registered processors and 237.95 lakh tonnes of certificates generated since the portal opened, of which 178.48 lakh tonnes had been transferred to obligated companies (SPI Regulation Tracker, India). HUL's BRSR describes this market from the buyer's side. It says it registered on the CPCB portal for EPR credit exchange from financial year 2023-24 and aligns its credit purchase plan with CPCB guidelines (Source 5). The other three describe collection and management rather than purchase, though all three buy through the same portal. ## What each company reports about fulfilment The four filings answer the same BRSR question, the Principle 2 table on products reclaimed at end of life, in different ways (Exhibit 7). Each row below is in that company's own definition. SPI ratios stay inside one company. A ratio under 100% is not a breach. The EPR target is a share of the eligible quantity, a two-year average of past placements, not of the current year's sales (clause 7.4(a)). A brand owner whose volumes grow can therefore meet 100% of its legal target while handling less than this year's tonnage. ITC's plastic packaging rose 4.2% from 70,788 tonnes to 73,762 tonnes in FY 2025-26 (Source 8), so a ratio of 98.3% is consistent with full compliance; its FY 2024-25 ratio was 91.1% on the same arithmetic. A ratio over 100% is not a surplus either. HUL's BRSR says its 261,214 tonnes of credits cover "more than 100% of our total plastic packaging footprint" (Source 5), and its Plastics page says it has collected more than it uses since 2021 (Source 6). Clause 7.4(a) counts virgin plastic only, so the legal base is smaller still than the footprint. Whether the excess is held as carried-forward surplus, offset against past years or never registered as surplus is not stated. In practice: Hindustan Unilever. HUL's Plastics page gives a footprint of about 128,000 tonnes for 2025, against about 125,000 for 2024 and 96,000 for the 2019 baseline year, and a cumulative EPR quantity of about 837,000 tonnes by 2025, up from about 656,000 by 2024 (Source 6). The BRSR for FY 2025-26 reports 261,214 tonnes of plastics reclaimed and safely disposed, after 207,005 tonnes in FY 2024-25, with a note that "a part of the safely disposed plastic is also recycled" but that traceability problems lead it to report the whole quantity as safely disposed (Source 5). **SPI calculation:** the BRSR's FY 2025-26 figure is about 80,000 tonnes more than the step in the cumulative series between 2024 and 2025, so the two series are on different bases. In practice: ITC. ITC's BRSR for FY 2025-26 reports about 31,200 tonnes of plastics recycled and about 41,300 tonnes safely disposed, after about 26,600 and 37,900 tonnes in FY 2024-25, and states that it is in compliance with EPR under the 2016 Rules (Source 7). The ESG Fact Book adds 73,762 tonnes of plastic packaging, 97.6% assessed as technically recyclable and a 2030 goal to recycle at least 60% of collected waste (Source 8). ITC also reports 12,000 tonnes of virgin plastic avoided cumulatively from what the company reports as a FY 2021-22 baseline. ## Recycled or disposed: the split the floor tests The minimum recycling level is the part of the duty most exposed to the end-of-life route. A company can hit 100% of its EPR target with end-of-life certificates from cement kilns and still miss the recycling floor. Exhibit 8 shows how much each company says was recycled. SPI analysis: the shares cannot be set against Exhibit 3 directly, because the floors apply category by category and none of the four publishes its category mix. ITC's 43.0% would clear the 40% floor for Categories II and III in 2025-26 but not the 60% floor for Category I. If most of ITC's plastic is flexible and multilayer, as its biscuit, snack and atta range suggests, the company-level share may be adequate this year and short in 2027-28, when the Category II and III floor reaches 60%. In practice: Nestlé India. Nestlé India's BRSR for the financial year to 31 March 2025 records 14,162 tonnes recycled and 10,483 tonnes safely disposed, against 8,401 and 17,248 tonnes in the previous 15-month period, and says the company is registered as a Brand Owner on the CPCB portal and has filed annual returns (Source 11). **SPI calculation:** the recycled share rose from 32.8% to 57.5%. Its release of 5 June 2026 puts FY 2025-26 at about 25,000 tonnes managed through recycling and other approved recovery, without a split (Source 12). The packaging page reports 59% of the portfolio designed for recycling in 2024 and a cut of more than 900 tonnes of virgin plastic that year (Source 13). ## Recycled content: four bases, one statutory test The statutory recycled-content duty is measured by category against plastic packaging used. The companies publish four different shares (Exhibit 9). Food contact explains part of the spread. The 2026 exemption covers packaging where FSSAI, CDSCO or a mandatory standard bars recycled plastic, and the carry-forward for 2025-26 shortfalls applies to food-contact packaging (Source 1, [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/)). Marico's 32.2% in non-edible products against 14.9% overall, and ITC's rigid 35.5% against 4.5% flexible, both point to a non-food rigid share well ahead of the rest. The [SPI pledge gap analysis](https://www.strategicpackaginginsights.com/insights/recycled-content-pledge-gap/) sets such goals against legal minimums in other markets. In practice: Marico. Marico's ESG Data Book for FY 2025-26 reports 26,306.87 tonnes of plastic packaging, within its FY 2025-26 target of 26,790 tonnes, after 25,514.39 tonnes in FY 2024-25 (Source 9). Recycled content rose to 14.9% from 2.15%, and recyclable plastic packaging was 91.3% of plastic weight. The same book gives 28,013 tonnes of post-consumer plastic "successfully recycled or disposed using EPR guidelines" on one page and 27,191 tonnes managed through EPR on another, without saying how they differ. It sets two 2030 goals: a 60% r-PCR share in non-food packaging, and 100% post-consumer recycled content across the non-edible rigid portfolio. Its BRSR lists EPR compliance at 100% (Source 10). ## Exemptions and carry-forward: where the 2026 text helps G.S.R. 237(E) changed who must meet the recycled-content shares in full. Packaging is exempt where a central law or rule, FSSAI, CDSCO, the Central Insecticide Board or a mandatory Indian Standard does not permit recycled plastic, provided the annual return names the provision relied on (Source 1). Unmet 2025-26 food-contact targets can be carried for three years from 2026-27, with at least one third cleared each year on top of that year's own share. For multilayer packs, Note 3 limits the recycled-content target to the weight of the plastic layers. The four portfolios use those reliefs differently. The SPI Buyers Database profiles place most of Nestlé India's range in food, from noodle and coffee films to confectionery laminates, and most of ITC's plastic in biscuit, snack and atta films (Source 15). HUL's profile in the same database lists home and personal care brands such as Vim, Surf excel, Dove and Sunsilk among those using recycled plastic, alongside one food pack, the Kissan Squash bottle (Source 15). Marico splits between Parachute and hair oils in non-food packs and Saffola in edible oil and food. SPI analysis: the exemption turns the statutory test from a portfolio percentage into a share of non-exempt tonnage, category by category. A food-heavy company may therefore owe far less recycled plastic than its low portfolio share implies, while a non-food rigid portfolio owes the full 40% in 2026-27. The published shares in Exhibit 9 cannot show which applies, because none of the four reports its exempt tonnage or the provisions it relies on. Marico's 32.2% in non-edible products and ITC's 35.5% in rigid packs are the nearest public proxies, and both sit below the 40% Category I share for 2026-27. The carry-forward is not free either. A 2025-26 shortfall carried into 2026-27 adds at least one third of the gap to a year in which the Category I share has already risen ten points, so a company that used the relief faces two steps at once. ## A framework: the EPR evidence ladder To compare disclosure without ranking numbers that do not match, SPI sorts what each company publishes into five rungs, from a bare statement of compliance to the category-level data that the CPCB annual return already holds (Exhibit 10). A higher rung is not a better compliance record; it is more evidence an outside reader can check. The ladder suggests four profiles. **Credit buyers** such as HUL publish footprint and credits bought, and report all of it as disposed. **Full ledgers** such as ITC publish placement, management and a recycled split, plus rigid and flexible recycled content. **Portfolio reporters** such as Marico publish placement, handled tonnage and portfolio shares, with no route split in the sources read. **Neutrality reporters** such as Nestlé India publish handled tonnage and its split, but no placement tonnage, so the neutrality claim cannot be sized from outside. Rung 5 is the gap all four share, and it is the one CPCB already sees. The annual return due by 30 June must show category-wise figures, and since 2026 it also carries rigid pack sales and recycled content ([PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/), [PR-IN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-002/)). Publishing the same table would let investors and customers test the floor and the content share themselves. ## Scenarios: what the next two years cost Three SPI calculations follow. Each uses only sourced inputs, one company or one rate at a time, and states its assumptions. **Scenario 1: buy now or pay and catch up.** Exhibit 11 compares buying certificates on time with paying compensation first and closing the gap later, using the 2024 price band and the clause 9.5 refunds. Everything is per tonne of shortfall, as a multiple of the compensation rate. The premium for delay is fixed by the refund ladder, not by the market: 0.25, 0.40 and 0.60 times the compensation rate for one, two and three years. With certificates capped at the compensation rate, paying compensation is never cheaper than buying on time, unless no certificates in the right category can be found. **Scenario 2: the recycling floor on each company's own tonnage.** Exhibit 12 applies the 2026-27 and 2027-28 floors to the two companies that publish a recycled split, holding their handled tonnage flat and bracketing the unknown category mix. SPI analysis: the step from 2026-27 to 2027-28 is the larger one for both. A company recycling 43% of its handled plastic, as ITC reports, would need its recycled tonnage to rise by about 39% within two years even in the low case. That demand meets a certificate market in which, per CPCB's July 2026 affidavit as recorded in the SPI tracker, three in four certificates generated since launch had already been transferred. **Scenario 3: HUL's virgin plastic arithmetic.** HUL applies Unilever's goal of a 30% cut in virgin plastic by 2026 and 40% by 2028 from a 2019 baseline (Source 6). Its BRSR now gives a recycled share, so the gap can be sized. SPI calculation: to reach the 2026 cap on a 128,000-tonne footprint, recycled plastic would need to be 47.5% of it, five times the FY 2025-26 share. The goal is Unilever's, and HUL reports no progress against it, so the gap measures the distance between the group pledge and the Indian numbers, not a legal shortfall. ## Industry reaction > "Payment of environmental compensation shall not absolve the Producers, Importers & Brand -Owners of the obligations set out in these guidelines." ***Ministry of Environment, Forest and Climate Change** , [G.S.R. 133(E), Schedule II clause 9.5, as annexed in NGT OA 22 of 2022 (SZ)](https://www.greentribunal.gov.in/sites/default/files/news_updates/222022.pdf), Gazette of India, 16 February 2022* The clause explains why Exhibit 11 has no cheap late route: the obligation survives the payment. > "HUL is meeting its EPR obligation in totality at a national level." > > > > **Hindustan Unilever** , [Plastics](https://www.hul.co.in/sustainability/plastics/), company website, consulted 23 October 2026 > > > > "Yes, ITC is in compliance with the requirements of Extended Producer Responsibility (EPR)" > > > > **ITC Limited** , [Business Responsibility and Sustainability Report, Report and Accounts 2026](https://itcportal.com/content/dam/itc-corporate/investors/annual-report-2026/itc-r-and-a-brsr-2026.pdf), 2026 > > > > "your Company is registered as a Brand Owner in the centralized portal operated by CPCB" ***Nestlé India** , [Business Responsibility and Sustainability Report, year ended 31 March 2025](https://nsearchives.nseindia.com/corporate/NESTLEIND1_03062025003115_Nestle_India_BRSR.pdf), NSE filing, 3 June 2025* All three companies frame compliance at the national level, the level of the portal registration, rather than category by category. ## What remains unclear - **Compensation rates.** Schedule II leaves the rupee rate to CPCB guidelines, and SPI has not yet confirmed the current table, so every cost here is a multiple of an unconfirmed INR rate. - **The certificate band in English.** The 100% and 30% band comes from SPI's reading of the Hindi text of G.S.R. 201(E). SPI has not yet confirmed whether CPCB has published band values in rupees. - **The 2022 table text.** The 2022 targets and floors in Exhibit 3 come from an OCR copy annexed to a tribunal filing. SPI has not yet confirmed them against the English Gazette page. - **Audit guidance.** CPCB's recycled-content audit guidelines under Note 2 of G.S.R. 237(E) were due within six months of 31 March 2026. SPI has not yet confirmed that they have been issued. - **Company bases.** HUL's footprint year basis is not stated, Marico's two EPR tonnages are unreconciled and ITC's rigid and flexible shares are not reconciled with its 3.22% overall figure in the source. ## What leaders should do now 1. **Head of sustainability reporting, before the FY 2026-27 BRSR:** publish EPR by category and by route (recycled, end-of-life, reuse), copied from the CPCB annual return the company already files by 30 June. 2. **Head of procurement, by 31 December 2026:** model certificate demand for 2027-28 by category, priced at 30%, 65% and 100% of the compensation rate, and secure Category I recycling certificates first, since that floor reaches 80%. 3. **Packaging development lead, by 1 April 2027:** lock rigid-pack resin contracts sized for 50% recycled content in non-food Category I packs, and keep the exemption file for food-contact SKUs that FSSAI rules bar. 4. **CFO, by the Q3 FY 2026-27 close:** stop treating environmental compensation as a substitute for certificates; book any shortfall at compensation plus certificate cost, as Exhibit 11 shows. 5. **Supplier and converter teams, now:** ask brand-owner customers for category forecasts, because a converter supplying registered brand owners can deduct those quantities from its own producer obligation (clause 10.3, [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/)). 6. **Investor relations, at the next results:** state the basis of every plastic figure, financial or calendar year, credits or collection, so that the numbers in Exhibit 1 can be read without a footnote. ## Questions for your board - Which of our plastic tonnes sit in Categories I, II and III, and does our recycled share clear each category's floor in 2026-27? - How much of our EPR target is met by end-of-life certificates, and what happens to that share when the Category I floor reaches 80%? - What would our 2027-28 certificate bill be at the top of the price band? - Do we hold any surplus certificates, and in which category? - Which SKUs rely on the food-contact exemption, and is the legal basis recorded for each? - Could an investor check our compliance claim from what we publish? ## What to watch - **30 September 2026 (due, not yet confirmed):** CPCB's audit and checking guidelines for recycled content under Note 2 of G.S.R. 237(E), due within six months of 31 March 2026. - **1 April 2027:** 2027-28 levels apply: minimum recycling 80% for Category I and 60% for Categories II and III; recycled content 50%, 20% and 10%. - **30 June 2027:** annual EPR returns for 2026-27 due on the CPCB portal under clause 10.6. - **30 September 2027:** CPCB list of entities that missed their 2026-27 targets due under clause 12.5. - **1 April 2028:** final recycled-content shares from 2028-29: 60%, 20% and 10%. - **31 March 2029:** end of the three-year carry-forward window for 2025-26 shortfalls. ## Methodology - **Data used:** Gazette notifications G.S.R. 133(E) (2022), 201(E) (2024), 73(E) (2025) and 237(E) (2026); SPI Regulation Tracker rule notes [PR-IN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-001/) to [PR-IN-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/india/pr-in-004/) and the India page; the latest BRSR and sustainability reports of the four companies; SPI Packaging Buyers Database profiles. Sources consulted 23 October 2026. - **Counting rules:** each company's figures are used in its own definition and year; ratios are computed within one company only; nothing is added, averaged or ranked across companies. All money is in INR or in multiples of an INR compensation rate. - **Baselines:** where a company gives a baseline year, SPI reports it as the company reports it. - **Scenarios:** Exhibits 11 to 13 use only the published band, refunds, floors and company figures; the 0.65 midpoint, flat tonnages, category brackets and HUL growth and recycled shares are SPI assumptions. - **Cut-off:** 23 October 2026. - **Limitations:** no company publishes category data; the 2022 text and the 2024 band are read from an OCR copy and a Hindi text; CPCB rates are not confirmed. Category placement of packs is SPI's reading. Not legal advice: check with counsel on any specific obligation. ## Sources 1. MoEFCC, Gazette G.S.R. 237(E), 31 March 2026, Plastic Waste Management (Amendment) Rules, 2026 (Maharashtra Pollution Control Board copy), [https://www.mpcb.gov.in/sites/default/files/standing_orders/Plastic_Waste_Management_2026.pdf](https://www.mpcb.gov.in/sites/default/files/standing_orders/Plastic_Waste_Management_2026.pdf), consulted 2026-10-23. 2. MoEFCC, Gazette G.S.R. 73(E), 23 January 2025, Plastic Waste Management (Amendment) Rules, 2025, [https://egazette.gov.in/WriteReadData/2025/260415.pdf](https://egazette.gov.in/WriteReadData/2025/260415.pdf), consulted 2026-10-23. 3. MoEFCC, Gazette G.S.R. 201(E), 14 March 2024, Plastic Waste Management (Amendment) Rules, 2024, [https://moef.gov.in/storage/tender/GSR201(E)-[14032024]-Plastic-Waste-Mangement-Rules-2024.pdf](https://moef.gov.in/storage/tender/GSR201(E)-[14032024]-Plastic-Waste-Mangement-Rules-2024.pdf), consulted 2026-10-23. 4. MoEFCC, G.S.R. 133(E), 16 February 2022, Schedule II, Guidelines on Extended Producer Responsibility for Plastic Packaging, as annexed (Annexure R-13/1) in a filing in NGT OA 22 of 2022 (SZ), [https://www.greentribunal.gov.in/sites/default/files/news_updates/222022.pdf](https://www.greentribunal.gov.in/sites/default/files/news_updates/222022.pdf), consulted 2026-10-23. 5. Hindustan Unilever, Business Responsibility and Sustainability Report FY 2025-26, [https://hul-performance-highlights.hul.co.in/performance-highlights-fy-2025-2026/brsr/pdfs/BRSR26.pdf](https://hul-performance-highlights.hul.co.in/performance-highlights-fy-2025-2026/brsr/pdfs/BRSR26.pdf), consulted 2026-10-23. 6. Hindustan Unilever, Plastics, [https://www.hul.co.in/sustainability/plastics/](https://www.hul.co.in/sustainability/plastics/), consulted 2026-10-23. 7. ITC Limited, Report and Accounts 2026, Business Responsibility and Sustainability Report, [https://itcportal.com/content/dam/itc-corporate/investors/annual-report-2026/itc-r-and-a-brsr-2026.pdf](https://itcportal.com/content/dam/itc-corporate/investors/annual-report-2026/itc-r-and-a-brsr-2026.pdf), consulted 2026-10-23. 8. ITC Limited, ESG Fact Book FY 2025-26, [https://www.itcportal.com/content/dam/itc-corporate/pdfs/itc-publications/itc-esg-factbook-2026.pdf](https://www.itcportal.com/content/dam/itc-corporate/pdfs/itc-publications/itc-esg-factbook-2026.pdf), consulted 2026-10-23. 9. Marico, ESG Data Book FY 2025-26, [https://sustainability.marico.com/uploads/1790752760463-esg-data-book-marico-2026-final-pdf.pdf](https://sustainability.marico.com/uploads/1790752760463-esg-data-book-marico-2026-final-pdf.pdf), consulted 2026-10-23. 10. Marico, Business Responsibility and Sustainability Report FY26, [https://sustainability.marico.com/uploads/1784613925468-business-responsibility-and-sustainability-report-fy26-pdf.pdf](https://sustainability.marico.com/uploads/1784613925468-business-responsibility-and-sustainability-report-fy26-pdf.pdf), consulted 2026-10-23. 11. Nestlé India, Business Responsibility and Sustainability Report, year ended 31 March 2025 (NSE filing, 3 June 2025), [https://nsearchives.nseindia.com/corporate/NESTLEIND1_03062025003115_Nestle_India_BRSR.pdf](https://nsearchives.nseindia.com/corporate/NESTLEIND1_03062025003115_Nestle_India_BRSR.pdf), consulted 2026-10-23. 12. Nestlé India, press release, Nestlé India reinforces commitment to a waste free future on World Environment Day, 5 June 2026, [https://www.nestle.in/media/pressreleases/allpressreleases/nestl%C3%A9-india-reinforces-commitment-waste-free-future-world-environment-day](https://www.nestle.in/media/pressreleases/allpressreleases/nestl%C3%A9-india-reinforces-commitment-waste-free-future-world-environment-day), consulted 2026-10-23. 13. Nestlé India, Packaging, [https://www.nestle.in/csv/environment/packaging](https://www.nestle.in/csv/environment/packaging), consulted 2026-10-23. 14. SPI Regulation Tracker, India: PR-IN-001 to PR-IN-004 and India page (citing the CPCB compliance affidavit of 6 July 2026 in NGT OA 993 of 2024 and the Jan Vishwas (Amendment of Provisions) Act, 2023), /data/packaging-regulation-tracker/india/, consulted 2026-10-23. 15. SPI Packaging Buyers Database: [Hindustan Unilever](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/hindustan-unilever/), [ITC](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/itc/), [Marico](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/marico/) and [Nestlé India](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/nestle-india/) profiles, /data/packaging-buyers-database/, consulted 2026-10-23.