India’s FY26 EPR framework now includes recycled content requirements. Brand owners are expected to meet defined levels of recycled material across plastic packaging.
This changes compliance in a real way. It’s no longer something that sits at the reporting stage. It now directly shapes sourcing decisions, supplier choices, and how much visibility companies have at a material level.
Teams that start building recycled content tracking into procurement early will be better placed, not just to stay compliant, but to do it without disrupting cost or operations.
The shift: from reporting to sourcing
With these requirements in place, compliance doesn’t sit at the end of the process anymore. It begins much earlier, at sourcing itself.
This means materials need to already meet recycled content requirements when they’re being bought, not adjusted later.
Packaging falls into three buckets:
- Category I: rigid plastics
- Category II: flexible plastics
- Category III: multi-layered plastics (MLP)
Each one has its own target, so compliance now depends heavily on how sourcing decisions are made.
Most EPR implementation studies in India point to the same reality, policy is in place, but supplier systems and operational readiness are still catching up.
What the targets look like in FY26
- Category I (Rigid): ~30%
- Category II (Flexible): ~10%
- Category III (MLP): ~5%
These will increase gradually through 2028–29, so early alignment matters.
The key point is how this is measured. It’s based on total packaging placed in the market, not a blended or averaged view. So recycled content has to be tracked across each category, in proportion to volumes.
That’s what shifts it from a year-end correction to something that has to run through ongoing sourcing decisions.
What this looks like on the ground
Category I (Rigid):
Relatively more stable recycling streams, so easier to work with, but still dependent on steady PCR availability.
Category II (Flexible):
Harder to manage because infrastructure is still uneven. Often needs closer supplier alignment or material rethink.
Category III (MLP):
Most difficult. In many cases, the focus moves to reduction, substitution, or redesign rather than direct compliance.
Why This Is a Sourcing Problem
To actually meet FY26 requirements, a few things need to come together:
- Clear mapping of packaging across categories
- SKU-level visibility on recycled content
- Reliable supplier verification, not just onboarding
- Willingness to switch materials where needed
- Alignment between procurement, sustainability, and compliance
At this point, compliance is less about reporting and more about making the right sourcing decisions, backed by data. These challenges are not new. Research on EPR implementation in India consistently highlights gaps in data, policy clarity, and supplier systems, making it harder for companies to take structured sourcing decisions.
Conclusion: from compliance to capability
Recycled content mandates are already changing how packaging decisions get made. Compliance now starts at sourcing, not at reporting.
At Fitsol, the focus is on making this workable, bringing visibility on materials, supplier intelligence, and decision support into day-to-day procurement.
The aim is simple: make recycled content easier to track, sourcing decisions more informed, and compliance stable without adding cost or operational friction.
Over time, this moves compliance from a reactive pressure point to something more structured and manageable.
FAQs
What are recycled content mandates under EPR?
They require brands to include a minimum share of post-consumer recycled (PCR) material in packaging. The idea is to build steady demand for recycled inputs.
Which packaging categories are included?
All three—rigid, flexible, and multi-layered plastics (MLP). Each comes with different targets and sourcing challenges.
Why is this difficult for companies?
Because PCR availability isn’t consistent, supplier data isn’t always reliable, and infrastructure is still evolving. So companies end up balancing cost, quality, and availability at the same time.
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