Glass and metal explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Regulation 4 of the Packaging Regulations, 2018 sets the specific requirements for primary food packaging, material by material. Sub-regulations (1) to (3) cover paper and board, glass containers, and metal and metal alloys; each ties the material to the Indian Standards listed in Schedules I and II.
The text is read as amended up to 28 March 2025 (FSSAI Compendium Version V dated 02.04.2025). FSSAI compendia are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in. Manufacturers who pack in these materials can combine the review with FSSAI registration for food manufacturers.
Paper and board must be of uniform formation, thickness and substance, of food grade where meant for direct contact, and must conform to a Schedule I Indian Standard. Glass containers must be smooth and sound. Rusty containers, chipped and rusty enamelled containers and copper or brass containers that are not properly tinned are deemed to render food unfit for consumption. Metal must conform to a Schedule II standard.
Regulation 4(1): paper and board
Paper and board materials intended to come in contact with food products must meet these conditions.
- (a) They shall be of uniform formation, thickness and substance.
- (b) They shall be clear of visible specks, grease marks, cuts, pinholes and other blemishes.
- (c) Paper used for boxes, cartons, plates, cups and paper lids, or paper meant to be in direct contact with food, shall be of food grade and clear of contaminants.
- (d) Paper and board materials used for making containers for packing or storing food shall conform to either of the Indian Standards specifications in Schedule I.
Schedule I, "Paper and board materials intended to come in contact with food products", lists six standards. As printed: serial 1, grease proof paper, IS 6622; serial 2, vegetable parchment or grease proof paper or aluminium foil laminate, IS 7161; serial 3, aluminium foil laminates for packaging, IS 8970; serial 4, general purpose packing or wrapping paper, IS 6615; serial 5, folding box board, uncoated, IS 1776; serial 6, corrugated fibre board boxes (Part 1), IS 2771. A Note says the wax used for coating paper or board shall be paraffin wax conforming to Type I of IS 4654.
Regulation 4(2): glass containers
Glass containers intended to come in contact with food must meet these conditions.
- (a) As far as possible, they shall be clear of blisters, mould marks, stones and chippings and, as far as possible, of cords, seeds and other visible defects.
- (b) They shall have a smooth surface without cracks, pinholes and sharp edges.
- (c) The sealing surface shall be clear of hairline cracks and prominent seam marks.
Two features: clause (a) is softened by "as far as possible", while clauses (b) and (c) are stated without that qualifier. The sealing surface rule in (c) matters for closures, which the general requirement in regulation 3(6) also covers (sealing material compatible with the product, containers and closure systems). Reused glass bottles must in addition be durable and easy to clean or disinfect under regulation 3(8); see our article on the general requirements.
Regulation 4(3): metal and metal alloys
- (a) A utensil or container made of the following, when used in the preparation, packaging and storing of food, "shall be deemed to render it unfit for human consumption": (i) containers which are rusty; (ii) enamelled containers which have become chipped and rusty; (iii) copper or brass containers which are not properly tinned.
- (b) Appropriate grades of metal and metal alloys, where applicable, shall be used for packing or storing food.
- (c) Metal and metal alloys used for making containers for packing or storing food shall conform to either of the Indian Standards in Schedule II.
Schedule II, "Metal and Metal Alloys intended to come in contact with food products", lists seven standards. As printed: serial 1, cold-reduced electrolytic tinplate, IS 1993/ISO 11949; serial 2, cold reduced electrolytic chromium or chromium oxide coated steel, IS 12591/ISO 11950; serial 3, wrought aluminium and aluminium alloy sheet and strip for general engineering, IS 737; serial 4, aluminium and aluminium alloy bare foil for food packaging, IS 15392; serial 5, crown closures, IS 1994; serial 6, round open top sanitary cans for foods and drinks, IS 9396 (Part 1); serial 7, the same, IS 9396 (Part 2).
The deeming provision in (3)(a) is unusual: it does not say the food "may" be unfit, it says use of such a container "shall be deemed" to render it unfit. The words "properly tinned" are not defined in the Regulations. The Regulations also do not set migration limits for metals in this sub-regulation; migration limits appear for plastics, covered in the article on regulation 4(4).
An invented example: Madhav Pickles packs mango pickle in used enamelled drums whose coating has chipped and rusted, and also in lacquered cans made of tinplate. The drums are caught by 4(3)(a)(ii): food packed in them is deemed unfit. The tinplate cans must conform to a Schedule II standard such as serial 1 or serial 6. Its folding cartons for pickle jars must be made of board conforming to a Schedule I standard, with no visible specks or grease marks.
Certificates and checks
Regulation 3(14) requires a certificate of conformity from a NABL accredited laboratory for packaging material in direct contact with food, which covers paper, glass and metal materials alike. For where to find accredited laboratories see choosing NABL accredited food testing labs. The overview of the packaging rules is in food packaging standards under FSSAI, and the Act's section on packaging is section 23. The suggestive list in Schedule IV is covered in regulation 5 and the Schedules.
Need help with packaging for your product?
Choosing between a glass jar, a tin and a paperboard carton affects cost, shelf life and compliance. Our FSSAI registration for food manufacturers team can help align your packaging with the Regulations as part of licence preparation.
Key takeaways
- Paper and board: uniform, without visible specks or blemishes, food grade for direct contact, conforming to Schedule I.
- Glass: smooth surface without cracks, pinholes or sharp edges; sealing surface clear of hairline cracks.
- Rusty, chipped and rusty enamelled, and improperly tinned copper or brass containers are deemed to render food unfit.
- Metal must conform to a Schedule II standard.
Read next
- Regulations 1–3: general requirements
- Regulation 4(4): plastic and recycled plastic packaging
- Regulation 5 and Schedules I–IV
- Food packaging standards under FSSAI
Disclaimer: Based on the FSSAI regulations named above as consolidated in FSSAI's compendium versions or as published in the Gazette, with the later notifications the article names (consulted on fssai.gov.in on 2-3 October 2026). Later notifications and the Food Safety and Standards Act, 2006 provisions referred to should be checked. This article is general information, not legal advice; check the official text before acting.