Plastic food packaging 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(4) of the Packaging Regulations, 2018 is the plastics provision. It requires plastic food packaging to conform to Schedule III, sets an overall migration limit and specific migration limits (Table 1), lays down rules for packaged drinking water bottles, and provides for recycled polyethylene terephthalate (PET) once standards and guidelines are notified. Multilayer packaging is dealt with in regulation 3(12).
The text is read as amended up to 28 March 2025 (FSSAI Compendium Version V dated 02.04.2025), as amended on 30 August 2022 (migration) and 28 March 2025 (recycled plastics). FSSAI compendia are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in. Manufacturers who pack in plastic can handle this with licensing through FSSAI registration for food manufacturers.
Plastic materials must conform to an Indian Standard in Schedule III. All plastic packaging must pass an overall migration limit of 60mg/kg or 10mg/dm2 tested as per IS 9845 with no visible colour migration, and must not release substances above the specific migration limits in Table 1. Packaged drinking water has its own container rules. Recycled PET may be used as and when standards and guidelines are notified by the Food Authority.
Regulation 4(4)(a): Schedule III and drinking water
Plastic materials used for making containers for packing or storing food shall conform to either of the Indian Standards in Schedule III. A first proviso says drinking water (packaged and mineral water) shall be packed in colourless, transparent and tamper-proof bottles or containers made of one of these:
- polyethylene (PE) conforming to IS: 10146;
- polyvinyl chloride (PVC) conforming to IS: 10151;
- polyalkylene terephthalate (PET and PBT) conforming to IS: 12252;
- polypropylene (PP) conforming to IS: 10910;
- food grade polycarbonate conforming to IS: 14971;
- polystyrene conforming to IS: 10142; or
- sterile glass bottles only.
The transparency of the container shall not be less than 85 percent in light transmittance. A second proviso allows pigments or colorants as in IS: 9833 in plastic containers of five litre and above made of polycarbonate and PET used for mineral water and packaged drinking water, again with transparency not less than 85 percent. A third proviso, inserted by amendment, allows food grade packaging materials as specified in regulation 4(1) to (3), which may or may not contain plastic as a component compatible with the water to be packaged; in such cases the transparency requirement would not apply.
Schedule III lists twenty standards. Examples as printed: serial 1, polyethylene, IS 10146; serial 3, PVC and its copolymers, IS 10151; serial 4, polypropylene and its copolymers, IS 10910; serial 7, polyalkylene terephthalates (PET and PBT), IS 12252; serial 11, polycarbonate resins, IS 14971; serial 12, flexible packaging materials for edible oils, ghee and vanaspati, IS 14636; serial 20, stretch cling films, IS 14995.
Regulation 4(4)(b) and (c): migration
- (b) All packaging materials of plastic origin shall pass the prescribed overall migration limit of 60mg/kg or 10mg/dm2 when tested as per IS 9845, with no visible colour migration.
- (c) Plastic materials and articles shall not release substances in quantities exceeding the specific migration limits in Table 1.
- (d) Pigments or colorants for plastics in contact with food and drinking water shall conform to IS: 9833.
"Overall" and "specific" migration are defined in regulation 2 (see our article on the general requirements). Table 1, "Requirement for specific migration limits of substances from plastic materials intended to be in contact with articles of food", has nine rows with the maximum migration limit in mg/kg. As printed: serial 1, Barium, 1.0; serial 2, Cobalt, 0.05; serial 3, Copper, 5.0; serial 4, Iron, 48.0; serial 5, Lithium, 0.6; serial 6, Manganese, 0.6; serial 7, Zinc, 25.0; serial 8, Antimony, 0.04; serial 9, Phthalic acid, bis (2-ethylhexyl) ester (DEHP), 1.5. Serials 8 and 9 were added by the amendment of 30 August 2022.
Regulation 4(4)(e): recycled PET
Clause (e), inserted by the amendment of 28 March 2025, reads: "Products made of recycled polyethylene terephthalate (PET) may be used for packaging, storing, carrying or dispensing of food products as and when standards and guidelines are notified by the Food Authority and such packaging materials shall comply with national standards or regulations as applicable to such materials." So recycled PET is allowed in principle, but only "as and when" standards and guidelines are notified; the clause on its own does not open the door. FSSAI has issued guidelines dated 23 May 2025 on acceptance of recycled PET as a food contact material; they are guidelines and not part of these Regulations, and nothing from them is stated here. See our overview post on recycled plastics in food packaging.
Multilayer packaging
The Regulations have no separate sub-regulation on multilayer packaging beyond the definition in regulation 2(1)(c) and regulation 3(12): in multilayer packaging, the layer in direct contact with food, or layers likely to come in contact, shall meet the requirements of Schedules I, II and III. In practice, a pouch with a PET outer layer, an aluminium foil middle layer and a polyethylene food-contact layer is judged on the layers that touch the food; see regulation 4(1)-(3) on paper, glass and metal for the other Schedules.
An invented example: Aqua Spring packs 20 litre jars of drinking water in colourless, transparent polycarbonate conforming to IS: 14971, with light transmittance not less than 85 percent, and uses pigments conforming to IS: 9833 only as the second proviso allows (five litre and above, polycarbonate or PET). Aqua's laboratory certificate shows overall migration within 60mg/kg when tested as per IS 9845 and no substance above its Table 1 limit. A neighbouring brand that wants to use recycled PET for edible oil bottles must wait until the Food Authority has notified the standards and guidelines.
Where to go next
The general requirements, including the certificate of conformity, are in regulations 1 to 3; the remaining Schedules are in regulation 5. The overview is food packaging standards under FSSAI, and the Act's rule is in section 23.
Need help with plastic packaging?
Plastic packaging brings test reports, migration limits and, for water, bottle specifications. Our FSSAI registration for food manufacturers team can help you check your packaging file as part of licence preparation.
Key takeaways
- Plastic food packaging must conform to a Schedule III standard.
- Overall migration limit of 60mg/kg or 10mg/dm2 (IS 9845) with no visible colour migration; Table 1 sets nine specific migration limits.
- Packaged drinking water goes in colourless, transparent, tamper-proof bottles of the listed materials, with transparency not less than 85 percent.
- Recycled PET may be used only as and when the Food Authority notifies standards and guidelines.
- For multilayer packs, the food-contact layers must meet the Schedule requirements.
Read next
- Regulations 1–3: general requirements
- Regulation 4(1)–(3): paper, glass and metal packaging
- Regulation 5 and Schedules I–IV
- Recycled plastics in food packaging 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.