India's single-use plastic ban names three packaging films and every carry bag under 120 microns, and leaves the rest of the pack to EPR

The ban list, item by item

The 2021 notification is short, and its list sits in two clauses (Exhibit 2). Rule 4(2)(a) covers “ear buds with plastic sticks, plastic sticks for balloons, plastic flags, candy sticks, ice-cream sticks, polystyrene [Thermocol] for decoration”. Rule 4(2)(b) covers “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, stirrers” (G.S.R. 571(E)).

The opening words of rule 4(2) set the reach: “The manufacture, import, stocking, distribution, sale and use of following singleuse plastic, including polystyrene and expanded polystyrene, commodities shall be prohibited with effect from the 1st July, 2022”. Rule 3(va) defines a single-use plastic commodity as “a plastic item intended to be used once for the same purpose before being disposed of or recycled” (G.S.R. 571(E)). The ministry’s release of 13 August 2021 gave the reason: the listed items “have low utility and high littering potential” (PIB).

Two readings in Exhibit 2 need care. The first is the film entry. SPI reads “wrapping or packing films around sweet boxes, invitation cards, and cigarette packets” as one entry about film around three things, which is how the SPI rule note for PR-IN-004 and the ministry’s 2022 explainer treat it; the explainer’s own bullet list, however, sets out “invitation cards” and “cigarette packets” as separate lines, which a reader could take as a ban on the cards and packets themselves. SPI has not yet confirmed a CPCB clarification that settles the point, and for packaging it matters little: either way, the plastic film around the box, card or packet is caught.

The second is the material test. The list names items, not polymers, and rule 4(2) adds polystyrene and expanded polystyrene versions expressly. So a polypropylene tray, a polystyrene tray and an expanded polystyrene tray are all inside it, while a paper tray is outside it. SPI has not yet confirmed any CPCB guidance on paper or board items with a plastic coating or lining, which is where the English and Welsh bans read in “partly” plastic items (see England and Wales’s single-use plastic bans).

Carry bags: 50, 75, then 120 microns

The thickness floor is older than the list and moved in two steps (Exhibit 3). G.S.R. 571(E) replaced “fifty microns in thickness” in rule 4(1)(c) with “seventy five microns in thickness with effect from the 30th September, 2021 and one hundred and twenty (120) microns in thickness with effect from the 31st December, 2022”. The ministry’s 13 August 2021 release said the floor would rise from 50 to 75 microns and then to 120, and that thicker bags would allow reuse (PIB).

SPI calculation: the 120 micron floor is 2.4 times the 50 micron floor it replaced and 1.6 times the 75 micron interim step, and the gap between the two steps was 457 days. The interim step came only 49 days after notification, which left little time to retool; the second gave converters about 15 months.

Non-woven bags have their own test, by weight rather than thickness. The 2021 text inserted the clause “non-woven plastic carry bag shall not be less than 60 Gram Per Square Meter (GSM) with effect from the 30th September, 2021”, and rule 3(na) defines a non-woven plastic bag as one “made up of plastic sheet or web structured fabric” of entangled fibres or filaments bonded mechanically, thermally or chemically (G.S.R. 571(E)). The ministry’s Rajya Sabha reply of 25 July 2024 restated that non-woven carry bags under 60 GSM have been banned since 30 September 2021 (PIB).

The floor is not a ban on bags. A plastic carry bag of 120 microns or more stays lawful, and it is then plastic packaging under EPR: the 2022 EPR Guidelines define carry bags as “covered under Category II of plastic packaging”, and put carry bags made of compostable plastics in Category IV (G.S.R. 133(E), as annexed in NGT OA 22 of 2022). The EPR targets for those categories are covered in Ledger 08, and SPI does not repeat them here.

A framework: five reach groups

SPI sorts every item a packer, retailer or caterer handles into five groups by how rule 4 reaches it (Exhibit 4). The groups come from rule 4(1) to 4(4) as amended, and from the PR-IN-004 rule note; each group needs a different action.

Group A, listed packaging film. This is the group that brand owners most often miss, because the item is not the product but the wrap around it. A sweet maker that packs boxes in plastic overwrap for the festival season, a printer that seals wedding card sets in film and a cigarette maker that overwraps its packs are all in the group. The PR-IN-004 brand owner duty in the SPI tracker reads it simply: remove plastic film overwrap from sweet boxes, invitation cards and cigarette packets sold in India.

Group B, listed serving items. These are listed as items, not as packaging, but they ride with packed food: a spoon inside an instant noodle cup, a straw on a juice carton, a tray inside a sweet box. India’s list has no packaging test, so a plastic tray is caught whether it is sold empty or filled. Compostable plastic versions are allowed under rule 4(3).

Group C, listed items with no exception. Candy sticks and ice-cream sticks are part of a food product, and they sit in list (a), which has no compostable route. A confectioner must use another material, such as wood or paper.

Group D, carry bags. These are not banned as a class; they must pass a thickness or weight test. The 2024 amendment adds a separate route for compostable and biodegradable bags.

Group E, outside rule 4. Most packaging tonnage sits here. These items stay lawful and are reportable under EPR, and rule 4(4) means that any future ban on them would be notified ten years before it applies.

The compostable and biodegradable route

The exception was drawn in 2021 and widened, for bags, in 2024 (Exhibit 5). Rule 4(3) reads: “The provisions of sub-rule (2) (b) shall not apply to commodities made of compostable plastic.” It covers list (b) only, so a compostable plastic tray, spoon or sweet box film may be sold, while a compostable plastic ice-cream stick may not (G.S.R. 571(E)).

G.S.R. 201(E) substituted rule 4(1)(h) to read that “the provision of thickness under clause (c) shall not apply to carry bags or commodities made from compostable plastic or biodegradable plastics”, and that compostable carry bags and commodities “shall conform to the Indian Standard: IS/ISO 17088:2021”. It inserted rule 4(1)(ha), under which the carry bags and “commodities covered under sub rule (3)” may be made from compostable or biodegradable plastics “subject to mandatory marking and labelling”, with the food safety regulator’s rules applying to food contact uses, and manufacturers “shall obtain a certificate from the Central Pollution Control Board before marketing or selling” (G.S.R. 201(E), 14 March 2024).

The same notification replaced the definition of biodegradable plastics. They are now plastics, “other than compostable plastics”, that degrade by biological processes in a specific environment such as soil, landfill or water “without leaving any micro plastics or visible or distinguishable or toxic residue” (G.S.R. 201(E)). It also added a duty in new rule 4(3A) for makers of compostable or biodegradable commodities to report quantities to the CPCB.

CPCB built a certificate system before the ban started. Its June 2022 release said it had “already issued one-time certificates to around 200 manufacturers of compostable plastic” and that the certificates “do not require renewal” (CPCB; PIB, 18 June 2022). Since March 2024 the certificate is a condition of marketing in the Rules themselves.

What the amendments since 2021 changed

Four amendments to the Rules followed G.S.R. 571(E), and SPI read each one for changes to the list, the bag floors and the exception (Exhibit 6). None changed rule 4(2) or the 120 micron figure.

Two of these matter more than they look. G.S.R. 73(E) inserted rule 19, under which anyone who fails to comply with the Rules “shall be liable to a penalty in accordance with the provisions of section 15 of the Act” (Gazette of India, 23 January 2025). Before it, the penalty link ran only through the parent Act; now the Rules state it.

G.S.R. 237(E) settled who acts on the ground. New rule 12(3A) provides that “The concerned Local Body in its jurisdiction shall be the authority for enforcement” of the restrictions and prohibitions, with the urban local body taking precedence where its area overlaps with a local authority, and rules 12(3B) and 12(3C) give the same role to the Gram Panchayat and the district-level Panchayat (G.S.R. 237(E), 31 March 2026). The SPI India note reads this as moving day-to-day policing to the body closest to the site.

Rule 4(4) is the provision that governs what comes next. It says any notification prohibiting “carry bags, plastic sheets or like, or cover made of plastic sheets and multilayered packaging and single-use plastic, including polystyrene and expanded polystyrene, commodities, issued after this notification, shall come into force after the expiry of ten years, from the date of its publication” (G.S.R. 571(E)). SPI analysis: on that text, a ban on, say, multilayer sachets notified on 27 October 2026 would not apply before 27 October 2036. A packaging team can plan against the current list with unusual certainty.

India against England: a wider net, a shorter list

India’s ban reaches further down the chain than England’s, but over fewer packaging formats (Exhibit 7). England bans supply to an end user; India bans manufacture, import, stocking, distribution, sale and use. England exempts plates, trays and bowls that are packaging; India has no packaging test, so a tray is caught whether filled or empty. England prices carrier bags; India sets a thickness floor.

Enforcement: control rooms, an app and the numbers so far

The enforcement design was set out in June 2022, before the start date. The ministry said “national and state level control rooms will be set up and special enforcement teams will be formed”, and that “States and Union Territories have been asked to set up border check points to stop inter-state movement of any banned single use plastic items” (PIB, 28 June 2022). CPCB’s release of 18 June 2022 listed supply-side steps: directions to petrochemical companies not to supply raw material to makers of banned items, revision or withdrawal of their consent to operate by State Boards, a request to customs to stop imports, and new local trade licences that bar the sale of banned items (PIB; CPCB).

Citizens were given a channel. CPCB’s release said a public grievance app had been launched by the Environment Minister and that “The app has geotagging features with facility to track complaints” (PIB, 18 June 2022). State authorities report through a separate SUP compliance monitoring portal, and the ministry’s Lok Sabha reply of 13 February 2023 names three platforms: a national dashboard, the CPCB monitoring module and the CPCB Grievance Redressal App (PIB). SPI has not yet confirmed any published count of complaints filed through the app.

Local adoption was partial at the start. The ministry’s explainer of 1 July 2022 said 2,591 of 4,704 urban local bodies had reported notifying the ban, with the rest asked to do so by 30 June 2022 (MoEFCC). SPI calculation: that is 55% of urban local bodies on the eve of the start date. The same explainer cited CPCB’s estimate of 3.5 million tonnes of plastic waste a year for 2019-20.

The first national campaign ran from 1 to 31 July 2022, followed by special drives from October to December 2022 (PIB, 13 February 2023). The ministry then reported cumulative totals twice to the Rajya Sabha (Exhibit 8).

SPI calculation: on the 2024 figures, 40% of inspections found a violation, the average fine was about INR 223 an inspection and about INR 553 a violation, and about 2.3 kg was seized an inspection. Between the two replies, inspections rose by 7,908, or 0.9%. SPI cannot tell from the replies whether that reflects fewer drives or a reporting lag, since neither gives a period.

States: earlier bans that still sit alongside

Many States banned carry bags or single-use items before the national list, and their notifications still apply alongside the Rules (Exhibit 9). The ministry’s reply of 25 July 2024 says “States/UTs have issued notifications/orders to introduce regulations pertaining to complete or partial ban” and annexes a State-by-State table (PIB).

The annex shows how early some States moved. By SPI’s reading, Sikkim’s entry is dated 4 June 1998, Rajasthan’s 21 July 2010, Karnataka’s 11 March 2016, Maharashtra’s 23 March 2018 and Tamil Nadu’s 25 June 2018, while Telangana is listed as not banned (PIB, 25 July 2024). The same reply says all 36 States and UTs have set up Special Task Forces chaired by the Chief Secretary or Administrator.

Penalties and scenarios, in INR

The penalty sits in the parent Act. Section 15 of the Environment (Protection) Act, 1986, as substituted by the Jan Vishwas (Amendment of Provisions) Act, 2023, provides a penalty for each contravention “which shall not be less than ten thousand rupees but which may extend to fifteen lakh rupees”, and an additional “ten thousand rupees for every day during which such contravention continues” (Jan Vishwas Bill as passed by the Lok Sabha). The Act received assent on 11 August 2023; SPI has not yet confirmed the date from which the recast section 15 applies, though rule 19 has pointed to it since 23 January 2025.

SPI ran four cases for a sweet chain with 20 outlets, each found using banned plastic film on sweet boxes (Exhibit 10). The outlet count and the 30 days of continuing breach are SPI assumptions for illustration; an authority decides how many contraventions it pursues and how it assesses them.

SPI calculation: the base case is 31 times the low case, because the daily amount for a continuing breach outweighs the minimum after one day. That makes speed of correction the main lever on cost: a chain that removes the film within a day of a notice stays near the low case.

What each part of the chain must change

Because rule 4(2) bans use and stocking as well as manufacture and sale, every role in the chain carries a duty (Exhibit 11).