Does packing tape count in India's EPR recycled-content target from 1 April 2027?

If you buy packing tape for a brand that files plastic EPR returns, the question in 2027 is a simple one. Does the tape count?

From 1 April 2027, the recycled plastic that obligated brands must use in flexible plastic packaging doubles, from 10% to 20%. Tape is plastic, it goes on every carton, and it is bought by the tonne. So it matters.

The honest answer is that the Rules do not say.

Tape is not named anywhere in the Plastic Waste Management Rules, 2016, or in the amendments up to March 2026. Neither the Ministry nor CPCB has published a clarification on tape that I know of. Read plainly, a BOPP tape fits the definition of plastic packaging and looks like Category II. If it counts, the target sits with the brand owner on its whole Category II total, not on each roll.

Checked against official sources on 28 October 2026.

We have been making BOPP tape in Jaipur since 1997. I have written this for brand owners who buy tape, so that the EPR consultant and the purchase team start from the same text. I am not a lawyer, and on a point the regulator has not answered, nobody can give you a final answer.

What the Rules actually say

Three definitions decide the question. These quotes are from the consolidated text of the Rules as amended to 14 March 2024, published on the UNEP Law and Environment Assistance Platform.

1. Rule 3(oa): "Plastic Packaging" means "packaging material made by using plastics for protecting, preserving, storing, and transporting of products in a variety of ways".
2. Rule 3(p): "plastic" means material which contains as an essential ingredient a high polymer, and the list of examples includes polypropylene.
3. Schedule II, paragraph 5.1: Category II is "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". Category III is multilayered packaging with "at least one layer of plastic and at least one layer of material other than plastic".

A BOPP tape is polypropylene film with an adhesive layer. It is used to protect and transport products. On the words alone, that is plastic packaging, and flexible film with more than one plastic layer reads like Category II.

I read it that way, and I would plan on that basis until CPCB says otherwise.

Settled and unsettled, side by side

The step-up on 1 April 2027

The Plastic Waste Management (Amendment) Rules, 2026, G.S.R. 237(E), were notified on 31 March 2026. The Gazette copy is hosted by the Maharashtra Pollution Control Board. They rewrote the recycled-content tables. The same percentages apply to producers, importers and brand owners:

For Category III, the target applies only to the weight of the plastic layers.

The amendment also says the targets do not apply where a law, a regulation or a mandatory Indian Standard does not permit recycled plastic, for example under FSSAI rules. The brand must cite that law in its annual return. A tape on the outside of a food carton does not touch the food, so I do not see which law would forbid recycled plastic in it. Do not lean on that exemption for carton tape without your adviser's agreement.

The annual return for FY 2026-27 is due by 30 June 2027 under paragraph 10.6 of Schedule II. Deadlines have been extended in past years, but no extension for this one exists yet.

Who would carry the target for tape

If tape counts, the Rules point to the brand owner first.

We see this from both ends, because a tape maker is itself a producer under the same Rules.

1. A brand owner is "a person or company who sells any commodity under a registered brand label or trademark" (Rule 3(b)). Its recycled-content target is a percentage of the plastic packaging used in the year. Tape on its own cartons is packaging it uses.
2. A producer is a person engaged in manufacturing plastic packaging (Rule 3(t)), so a tape maker is a producer. When a producer works out its EPR target, it subtracts the quantity it supplied to obligated brand owners in the previous year. Its recycled-content target, though, is written as a percentage of the plastic packaging it manufactures.
3. Brand owners and producers that are micro or small enterprises are outside the obligated list in paragraph 4 of Schedule II. Under paragraph 7.8, the EPR target of a micro or small producer is met by its resin supplier, but the recycled-content target "shall be fulfilled by such producers" themselves.
4. Importers are never exempt, and recycled plastic inside imported material does not count towards their target.

The "small" limits changed on 1 April 2025 under S.O. 1364(E): investment up to ₹25 crore and turnover up to ₹100 crore. Check your own Udyam classification rather than guessing.

The Rules give both the producer and the brand owner a recycled-content target, and they do not spell out how the portal treats the same roll of tape at both ends. That is a question for your EPR consultant.

Get the answer in writing.

The target is on the total, like a monthly ration

A joint family does not budget each packet on the kirana list. It budgets the month. The recycled-content target works the same way.

Example 6 in the Annexure to Schedule II shows it. A brand with 100 tonnes of Category II packaging in 2025-26 needs 10 tonnes of recycled plastic in that packaging, across the category. The same logic gives 20% from 2027-28.

So counting tape does not mean every roll must carry 20% recycled plastic. It means the tape tonnage joins the Category II total. A worked example, with assumed figures: if a brand uses 50 tonnes of Category II packaging and 2 tonnes of it is tape, counting the tape adds 0.4 tonnes to its 2027-28 recycled-content need. That extra can come from other Category II packaging where recycled content is easier to use, such as some courier bags or liners.

How to put a tonnage on your tape

You need one number: the net weight of tape you bought in the year.

I would not wait for CPCB to decide before you work it out.

1. Take five full rolls of each tape you buy. Weigh them together on a scale that reads to 1 gram.
2. Keep the five cores as those rolls finish, and weigh them together.
3. Subtract and divide by five. That is your net tape weight per roll.
4. Multiply by the rolls bought in the financial year, from your purchase register.

If your supplier gives grams per square metre for the backing and the adhesive, multiply by the roll width and length in metres as a cross-check. The tape data sheet guide explains how to read those lines.

What to do before 1 April 2027

1. Decide your position on tape with your EPR consultant or auditor, write it down, and apply it the same way every year.
2. Work out your tape tonnage for FY 2025-26 and FY 2026-27, so the decision rests on a number.
3. If you count tape, plan the 20% on the whole Category II total, not roll by roll.
4. Ask your tape supplier for its CPCB registration number, the category it declares tape under, and any recycled content with evidence. Recycled plastic packaging must meet IS 14534:2023 and carry the marking set out in Rule 11(2).
5. Trial a paper tape on lines where it holds well. Ask for the layer structure, because a paper tape with a plastic layer may still be counted as Category III.
6. Watch for the CPCB guideline on audit and verification of recycled content. The 2026 amendment asked CPCB to issue it within six months of notification.

Marking is the next question behind this one. Rule 11(1) asks for the name and registration number of the producer or brand owner, and the thickness, on plastic packaging. Rule 11(1A) lets this be given through a QR code or barcode instead. How that applies to a roll of tape has not been clarified either.

A word about our own certificate. Our GRS certificate covers only packing sacks and bags made with 50 to 100% post-consumer recycled polyethylene. It does not cover tape. Those bags are one way to carry a Category II total, but I will not promise a recycled-content tape on this page. Ask us what we can document for the exact tape you buy.

If you buy tape from us, write to us through the contact page with the product names and your yearly roll count. We will send the net weight per roll and the layer structure, so your EPR team can put a real tonnage on tape before the April 2027 step-up.