Schedule II 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.
Paragraph 7 of Schedule II is the working centre of plastic packaging EPR. It sets, for producers, importers and brand owners separately, the EPR target, the minimum level of recycling, the rules on end of life disposal, the obligation to use recycled plastic content and, for brand owners, the reuse obligation. The 2026 amendment substituted the recycled-content and reuse provisions. Paragraph 8 deals with surplus certificates, carry-forward and trading.
These Rules are current as amended up to the Plastic Waste Management (Amendment) Rules, 2026 (G.S.R. 237(E), 31 March 2026). Later amendments, CPCB guidelines and notifications should be checked. If you need a category-wise obligation sheet for your packaging, our compliance documentation team can build it from the printed tables.
Targets are worked category-wise on an eligible quantity of packaging (para 7.1). Recycled content must be used as per tables for Categories I to III that run to 2028-29 and onwards (para 7.2(d), 7.3(d), 7.4(e), substituted in 2026), and brand owners using rigid Category I packaging have a reuse obligation (para 7.4(b), substituted in 2026). Surplus certificates can offset a shortfall, be carried forward or be sold in the same category (para 8).
Paragraph 7.2: the producer
EPR target (7.2(a))
The eligible quantity (Q1) is the average weight of plastic packaging material, category-wise, sold in the last two financial years (A), plus the average quantity of pre-consumer plastic packaging waste in the last two financial years (B), minus the annual quantity (C) supplied to the entities covered under sub-clause 4(c) in the previous financial year. The 2026 amendment changed the reference from "4 (iii)" to "4 (c)" in this clause. The target is a percentage of Q1, category-wise:
| Year | Target (as a percentage of Q1) |
|---|---|
| 2021-22 | 25 per cent |
| 2022-23 | 70 per cent |
| 2023-24 | hundred per cent |
The table as printed runs to 2023-24. Paragraph 7.6 says the obligations for reuse, recycling and recycled content shall be reviewed every five years based on available technologies. The target in tonnes, category-wise, is given by the producer as part of its Action Plan on the portal.
Recycling (7.2(b)) and end of life disposal (7.2(c))
The producer shall ensure a minimum level of recycling, excluding end of life disposal, of the plastic packaging waste collected under its EPR target, as a percentage of that target:
| Category | 2024-25 | 2025-26 | 2026-27 | 2027-28 and onwards |
|---|---|---|---|---|
| I | 50 | 60 | 70 | 80 |
| II | 30 | 40 | 50 | 60 |
| III | 30 | 40 | 50 | 60 |
| IV | 50 | 60 | 70 | 80 |
For Category IV the minimum level of recycling means processing for composting through industrial composting facilities. Only plastics that cannot be recycled go to end of life disposal, such as road construction, waste to energy, waste to oil or cement kilns (co-processing), under relevant Indian Road Congress or CPCB guidelines, and only through the methods in rule 5(1)(b) (7.2(c)).
Recycled plastic content (7.2(d), substituted in 2026)
The 2026 text requires the producer to ensure use of recycled plastic in plastic packaging, category-wise, as a percentage of plastic packaging manufactured for the year:
| Category | 2025-26 | 2026-27 | 2027-28 | 2028-29 and onwards |
|---|---|---|---|---|
| I | 30 | 40 | 50 | 60 |
| II | 10 | 10 | 20 | 20 |
| III | 5 | 5 | 10 | 10 |
Three further points are printed with the table:
- Exemption. The targets do not apply where use of recycled plastic in packaging is not permitted under a law, regulation or rule notified by the Central Government or by statutory bodies such as the FSSAI, the Central Drugs Standard Control Organisation or the Central Insecticide Board, or any mandatory Indian standard in force, or any other statutory requirement specified by the Central Government. A producer claiming it must submit the law, regulation, rule or standard in its annual return on the portal.
- Notes. The CPCB is to prescribe audit and verification guidelines for recycled content within six months from the date of notification of the 2026 Rules. For Category III the target is limited to the weight of the plastic layers.
- Carry-forward. A producer may carry forward the unfulfilled target for recycled content in food contact applications for 2025-26 for up to three consecutive years starting from 2026-27, over and above the target for those years, with at least one third of the carried-forward target fulfilled in each year.
Paragraph 7.3: the importer
The importer's eligible quantity (Q2) follows the same formula, using plastic packaging material and packaging of imported products imported and sold. The target, recycling and end of life provisions mirror the producer's. The recycled-content table in 7.3(d), as substituted in 2026, has the same percentages, applied to imported plastic packaging for the year. Recycled plastic already in imported material is not counted; the importer meets its obligation by purchasing a certificate of equivalent quantity from entities that exceeded theirs, through the CPCB's portal mechanism. The same exemption and carry-forward apply.
Paragraph 7.4: the brand owner
- Target (7.4(a)). Q3 is the average weight of virgin plastic packaging material, category-wise, purchased and introduced in the market in the last two financial years (A) plus the average quantity of pre-consumer plastic packaging (B). The target table (25, 70, hundred per cent) is the same.
- Reuse (7.4(b), substituted in 2026). A brand owner using Category I rigid packaging has a minimum reuse obligation, as a percentage of Category I rigid packaging in products sold annually:
| Rigid packaging | 2025-26 | 2026-27 | 2027-28 | 2028-29 and onwards |
|---|---|---|---|---|
| 0.9 litre or kg or more but less than 4.9 litres or kg | 10 | 15 | 20 | 25 |
| 4.9 litres or kg or more, for drinking water | 70 | 75 | 80 | 85 |
| 4.9 litres or kg or more, products other than drinking water | 10 | 10 | 15 | 15 |
The reuse target does not apply where reuse of Category I rigid packaging is not permitted under a law, regulation, rule or mandatory Indian standard, with the document submitted in the annual return. A brand owner may carry forward an unfulfilled 2025-26 reuse target for up to three consecutive years from 2026-27, with at least one third fulfilled each year. Responsibility for product quality, authenticity and implementation of mandatory standards lies with the brand owner. The brand owner furnishes total sales and virgin and recycled plastic content in rigid packaging in its annual return (7.4(b)(III)).
- Recycling and end of life (7.4(c), (d)). The same recycling table and end of life rules apply.
- Recycled content (7.4(e), substituted in 2026). The same table, as a percentage of plastic packaging used in the year, with the same exemption, notes and carry-forward.
Paragraphs 7.5 to 7.8
Targets in tonnes go on the portal in the Action Plan (7.5) and obligations are reviewed every five years (7.6). Paragraph 7.8, as substituted in 2024, makes the raw material manufacturer or importer carry the EPR of the micro and small producers it supplied, with a minimum recycling table of its own.
Paragraph 8: surplus certificates, carry-forward and trading
| Clause | Content |
|---|---|
| 8.1 | A brand owner that has met its targets, category-wise, can use the surplus to offset a previous year's shortfall (subject to para 9.5), carry it forward, or sell it to other producers, importers and brand owners |
| 8.2 | Surplus in a category can be used only in the same category; surplus under reuse can be used against reuse, recycling and end of life disposal; surplus under recycling against recycling and end of life disposal; surplus under end of life disposal cannot be used for reuse or recycling |
| 8.3 and 8.4 | Entities can meet obligations by buying surplus certificates of the same category, with transactions recorded in annual returns |
| 8.5 to 8.7 | The CPCB issues guidelines for authorising agencies to set up electronic platforms for trade of certificates; the number of platforms may be restricted; operation is per CPCB guidelines after Central Government approval |
| 8.8 and 8.9 | The CPCB fixes the highest and lowest price at hundred per cent and 30 per cent respectively of the environmental compensation leviable under rule 18, and exchange on the portal must lie between them |
Paragraph 15A, inserted in 2023, lets the CPCB allow purchase of certificates across categories where surplus exists, and says it ceases to apply at the end of 2025-2026.
Example
Sparkle Home Care Limited sells detergent in rigid 1-litre bottles and in Category II pouches. For the pouches it uses the Category II row of the 2026 table; for the bottles it checks the Category I recycled-content row and the reuse row for packaging of 0.9 litre or more but less than 4.9 litres. Where a statutory body bars recycled content in a pack, it files that rule with its annual return to claim the exemption.
Need help with plastic EPR targets?
The tables are printed, but applying them needs category data, supplier records and a record of exemptions. Our compliance documentation team can help you build a category-wise workbook and keep the supporting records for audit.
Key takeaways
- Targets are category-wise and based on eligible quantities; the printed EPR target table ends at 2023-24.
- Recycling levels rise to 80 per cent for Categories I and IV and 60 per cent for Categories II and III from 2027-28 onwards.
- The 2026 amendment substituted the recycled-content tables and the brand owner reuse tables, with a statutory exemption and a three-year food contact carry-forward.
- Importers cannot count recycled content already in imported material.
- Surplus certificates are category-specific and priced between 30 and 100 per cent of the rule 18 compensation.
Read next
- Schedule I and Schedule II paragraphs 1 to 6: coverage and registration
- Schedule II paragraphs 9 to 18: compensation, roles, portal and committee
- Rules 8 and 9: PIBO responsibilities
- Plastic Waste Management Rules: the amendments from 2018 to 2026
Disclaimer: Based on the environment rules, guidelines and notifications named above as published in the Gazette of India, read with every amendment notified up to 3 October 2026 that the article names (consolidated reading texts from the CPCB 2021 compilation and the Goa State Pollution Control Board 2025 compilation were checked against the amending notifications), as consulted on 3 October 2026. Later amendments, CPCB guidelines, State Board orders and fees should be checked. This article is general information, not legal advice; check the official text before acting.