India, New Zealand and Dubai draw a bag line in microns, Kenya bans the carrier bag at any thickness, and only Kenya has pulled all thin film into licensing

Four markets side by side

Exhibit 2 is the core of this piece. Each row is one regime, read from its own text, with the penalty in its own currency.

Three points stand out. First, only India makes thickness the condition of lawfulness for every plastic carry bag; in New Zealand and Dubai thickness is the condition of being banned, and above the line a bag is outside the rule altogether. Second, Kenya’s ban rests on a ministerial gazette notice and Dubai’s on an Executive Council resolution, while India and New Zealand use regulations made under a parent Act. Third, two of the four markets changed who enforces in 2026, and Kenya added a licence layer for film in 2024.

India: a floor, not a ban

India gets a short section here because Ledger 46 covers it in depth. The official text is G.S.R. 571(E) of 12 August 2021, which amended rule 4(1)(c) of the Plastic Waste Management Rules, 2016 so that a carry bag made of virgin or recycled plastic shall not be less than 75 microns from 30 September 2021 and 120 microns from 31 December 2022. The same notification set a 60 GSM minimum for non-woven plastic carry bags from 30 September 2021 (PR-IN-004).

The floor was later qualified. In the consolidated text as at 14 March 2024, rule 4(1)(h) provides that the thickness provision in clause (c) does not apply to carry bags made from compostable or biodegradable plastics, the change made by G.S.R. 201(E) of that date (UNEP LEAP consolidated text; Ledger 46). A compostable bag is therefore tested by certification and marking rather than by gauge.

Thin film enters through the list, not the floor. Rule 4(2)(b) has banned wrapping or packing films around sweet boxes, invitation cards and cigarette packets, and plastic or PVC banners under 100 microns, since 1 July 2022 (G.S.R. 571(E)). Since 31 March 2026, G.S.R. 237(E) names the concerned local body, Gram Panchayat or district Panchayat as the enforcing authority in its area (rule 12(3A) to (3C)). Penalties come from section 15 of the Environment (Protection) Act, 1986, as recast in 2023.

Kenya: the carrier bag at any gauge

Kenya’s ban is the oldest of the four and the bluntest. Gazette Notice No. 2356, dated 28 February 2017 and printed in the Kenya Gazette on 14 March 2017, records that the Cabinet Secretary for Environment and Natural Resources banned the use, manufacture and importation of all plastic bags used for commercial and household packaging, with effect from six months after the notice (FAOLEX copy). The notice defines a carrier bag as a bag constructed with handles and a flat bag as one constructed without handles, in each case with or without gussets. NEMA dates the effect to 28 August 2017, and the Environment and Land Court upheld the notice on 22 June 2018 (PR-KE-001).

There is no micron figure in the notice. NEMA’s FAQs on the ban define a plastic carrier bag as any bag, regardless of thickness or colour, used in supermarkets, retail stores, shopping malls and grocery stores. That is the decisive difference from the other three markets: a thicker plastic carrier bag is not a route back to market in Kenya.

NEMA sorts bags into four categories (NEMA, plastic bags page). Category 1 is the carrier bag, banned with no exemption; NEMA describes these as the bags commonly known as juala, used as secondary packages in shops and markets. Category 2 is the flat bag, banned outside industrial settings but allowed as primary industrial packaging in direct contact with the product at source, with labels and a NEMA clearance letter. Category 3 covers garbage and hazardous waste liners, exempt under labelling, colour coding and take-back conditions. Category 4 is the duty-free bag, which travellers must leave at entry points.

Non-woven polypropylene was closed off separately. NEMA directed manufacturers, importers, suppliers, distributors and users to stop making, importing, supplying and using non-woven polypropylene bags from 31 March 2019, because low-quality thin bags were being used once and discarded, until the Kenya Bureau of Standards gazettes a quality standard (NEMA). SPI has not yet confirmed whether that standard has been gazetted.

The 250 micron scope. The newer layer is the Environmental Management and Co-ordination (Management and Control of Plastic Packaging Materials) Regulations, 2024, L.N. 181 of 2024, printed in the Kenya Gazette of 6 December 2024 (Ledger 32). NEMA’s brochure says they cover carrier and flat bags of any polymer, laminated or not, woven or non-woven, and plastic packaging including film, which it defines as flexible plastic up to 250 microns thick. Making, importing, exporting, possessing, using or offering these for sale needs NEMA authorisation, applications are processed within 21 working days and licences are not transferable (NEMA brochure; NEMA FAQs). Labelling is mandatory: locally made bags show the product, the product owner and the packaging maker, and imported products show the product, its manufacturer, the Kenyan importer and the country of origin (NEMA FAQs).

New Zealand: a line in 2019, then the produce bag

New Zealand moved in two steps, four years apart. The Waste Minimisation (Plastic Shopping Bags) Regulations 2018, made on 17 December 2018 and in force from 1 July 2019, define a plastic shopping bag as one made wholly or predominantly of plastic less than 70 microns thick, that is new or unused and has handles (LI 2018/270, reg. 3). Regulation 5(1) puts the duty on retailers, and regulation 5(3) treats a bag given away free as sold.

The line is drawn around bioplastics as well. The Ministry’s guidance for businesses says the ban reaches bags made of bio-based, starch-based, degradable, biodegradable and oxo-degradable plastic, and that die-cut handles count as handles (Ministry for the Environment, facts for businesses). Long-life synthetic fabric bags of 45 to 70 microns, in nylon, polypropylene or polyester, are excluded, as are bags that form an integral part of the packaging in which goods are sealed or contained before sale. Bin liners, pet waste and nappy bags, bread bags and bags without handles were outside the 2019 rule.

The 2023 step closed the handle gap at the produce aisle. Since 1 July 2023, SL 2022/69 as amended bans single-use plastic produce bags, which the Ministry describes as unsealed plastic bags provided by the store or retailer to pack fresh fruit and vegetables at the place of purchase. No thickness is given and the Ministry says there are no exemptions; produce bagged before sale, sealed or not, is outside (Ministry guidance, July 2023 bans). Compostable and plant-based plastic versions are caught too (PR-NZ-001).

Who enforces now. The Environment (Disestablishment of Ministry for the Environment) Amendment Act 2026, 2026 No 22, received assent on 2 June 2026 and took effect on 1 July 2026. It disestablishes the Ministry and gives its functions to the Secretary for the Environment, and it amends the definition of Secretary in section 5(1) of the Waste Minimisation Act 2008. The Ministry’s guidance states that it encourages voluntary compliance and follows up complaints made through an online form. Ledger 37 covers the wider New Zealand bans and the levy, which SPI does not repeat here.

Dubai: a line that also catches paper

Dubai’s rule is the newest and the only one of the four that is material-neutral. Executive Council Resolution No. (124) of 2023, issued on 30 December 2023 and effective from 1 January 2024, defines a single-use bag as a biodegradable or other plastic bag, a paper bag or a bag made of plant fibre whose thickness is less than 57 micrometres and which is used to carry and transport commodities (Art. 1). Article 5 then banned plastic bags from 1 January 2024 and non-plastic single-use products, including single-use bags, from 1 June 2024.

The line sits below New Zealand’s and well below India’s floor, but it reaches a paper carrier bag, which none of the other three rules does. It applies across the Emirate, including Special Development Zones and free zones such as the Dubai International Financial Centre (Art. 3). Inspectors may ask a vendor for the identification tag of the bags it offers to consumers (Art. 10), so the tag, not a test, is the first line of proof.

Dubai Municipality’s release of 24 December 2025 summarised the phases as plastic bags in January 2024, all single-use bags in June 2024, a foodservice phase in January 2025 and plates, cutlery including chopsticks and beverage cups with lids from 1 January 2026. The Resolution’s own 2026 list also names single-use plastic food containers (Art. 5(d)). The bag price that preceded the ban, 25 fils from 1 July 2022 under Resolution No. (52) of 2022, and the federal UAE rules are covered in Ledger 40.

What counts as a bag: the definitions decide

Because each market defines the bag differently, the same product can be banned in one and untouched in another. Exhibit 3 sets the definitions against each other.

Ten years of dates

The four regimes were built between 2017 and 2026, and two more steps are already on the calendar (Exhibit 4).

SPI calculation: Kenya gave six months between its notice and its ban, Dubai gave 2 days between issuing Resolution 124 on 30 December 2023 and banning plastic bags on 1 January 2024, India gave 49 days between its notification and the 75 micron step, and New Zealand gave 196 days between making its regulations and their start.

Beyond the bag: thin film

Packaging teams care less about the checkout bag than about film: overwrap, shrink, produce rolls and pouches. Here the four markets diverge most (Exhibit 5).

India’s three named overwrap films are a list, not a principle: shrink film on a ketchup multipack or a biscuit tray is outside rule 4(2) and inside EPR. New Zealand bans a use, not a material: the same film bag is lawful when it is sealed around pre-packed apples and banned when a shopper tears it off a roll in the produce aisle. Dubai’s Article 6 exempts exactly the bag New Zealand bans, the thin roll for fruit and vegetables.

A framework: four ways to draw the line

SPI groups the bag and film rules in these markets into four designs, set by two questions: does gauge decide legality, and does the rule reach beyond plastic or beyond the bag (Exhibit 6)?

The designs carry different costs. Design A raises the cost of each bag but keeps the product category, and ties it to EPR. Design B pushes retailers to long-life bags and, in Dubai, raises the question of what a paper bag above 57 micrometres must look like. Design C removes a product line altogether. Design D is the only one that touches the packaging of goods rather than the carriage of them.

What still passes: exemptions

Exemptions are where most compliance questions arise (Exhibit 7).

Enforcement and penalties, in four currencies

Exhibit 8 sets out who acts and what the law allows. Each amount is in its own currency and is not compared.

Dubai is the only market with a fixed administrative fine set in the bag instrument itself. A vendor may file a written grievance within 10 working days, a committee decides within 10 working days and its decision is final (Art. 11); fines go to the Public Treasury of the Government of Dubai (Art. 9(c)). Article 9(a) preserves any stricter penalty in other legislation.

Kenya’s notice carries no penalty of its own; the 2018 judgment noted that the penalty complained of was set by Parliament in the Act, not by the Cabinet Secretary (PR-KE-001). The Cabinet Secretary for Environment said at World Environment Day 2025 that compliance with the carrier bag ban had passed 80 per cent (Government Advertising Agency, World Environment Day 2025).

Scenarios: what a breach costs, one currency at a time

Two scenario tables put numbers on exposure. Both are SPI calculations from sourced inputs, each in one currency only.

Dubai’s Article 9(b) says the fine is doubled when the same violation is repeated within one year, and that a doubled fine must not exceed AED 2,000. SPI reads that two ways: Reading A, every repeat costs AED 400; Reading B, each repeat doubles the previous fine until the AED 2,000 cap. The text does not settle which applies, so Exhibit 9 shows both for an assumed operator with 10 outlets, each counted as a separate violator.

SPI calculation: under Reading B the cap binds from the fifth breach, since AED 1,600 doubled is AED 3,200, which is above AED 2,000. Under either reading, the money is small next to the cost of withdrawing stock; the larger risk for a Dubai vendor is losing a product line overnight.

Exhibit 10 compares, inside each market, what the law allows with what has been reported or is likely.

What each part of the chain must change

Exhibit 11 turns the four regimes into tasks by role.