India Revises Plastic & Battery Labelling Mandates: Impact on Producers

The changes introduced are as follows:

• Exemption from display of EPR registration number

The mandate requiring producers to ensure that all battery or battery packs (including battery used as a component in products) produced are marked with the Extended Producer Responsibility (EPR) registration number on or before March 31, 2025, will not apply to packaging covered under Rule 26 of the Legal Metrology (Packaged Commodities) Rules, 2011. This is in accordance with the proviso added to clause (ia) in paragraph (2) of Schedule I to the Rules.

Consequently, the mandate will not apply to packaging containing fast food items packed by restaurants or hotels, commodities sold by weight or measure with net weight or measure equal to or less than 10g or 10ml, etc.

• An alternative method to display the EPR registration number

Clause (ib) has been added in paragraph (2) of Schedule I, which states that to comply with the mandate regarding the display of the EPR registration number, producers may:

• • print a barcode or QR code containing the EPR registration number on any of the following:
    • battery or battery pack
    • equipment having a battery or battery pack
    • packaging of battery or battery pack
    • packaging of the equipment having battery or battery pack
    • bulk packaging of batteries or battery packs, not for retail sale

• • print the EPR registration number on the product information brochure.

The above is subject to providing the information in writing to the Central Pollution Control Board (CPCB), which will publish a consolidated list of such producers on the centralised online portal and update their details every quarter.

Prior to the amendment, the EPR registration number had to be displayed directly on the battery or battery packs. Last year, the Ministry clarified that in the case of imported batteries or battery packs, the display of the EPR registration number on the equipment (having battery or battery pack) or packaging of the equipment (having battery or battery pack) as well would imply compliance.[2] Well before the approaching deadline (March 31, 2025), the government has now notified amendments bringing in relaxations.

• Exemption from the display of chemical symbols

The marking of batteries with the chemical symbol ‘Cd’ or ‘Pb’ is not required if the metal concentration of Cadmium in the battery is less than or equal to 0.002% (20 parts per million) or Lead in the battery is less than or equal to 0.004% (40 parts per million) by weight. This is in accordance with the proviso added to clause (v) in paragraph (2) of Schedule I.

Plastic Waste Management (Amendment) Rules, 2025

Earlier this year, on January 23, 2025, the Ministry notified amendments[3] to the Plastic Waste Management Rules, 2016, which are summarised below:

• Manner of providing information

With effect from July 1, 2025, the information to be printed on plastic packaging under Rule 11(1) may be provided by the producer, importer or brand owner by using any of the following modes:

• • in a barcode or QR code printed on the plastic packaging;
  • in the product information brochure;
  • print on the plastic packaging the unique number issued under any law for the time being in force, wherein the provisions of sub-rule (1) are required to be fulfilled before issuance of such a number.

The above is in accordance with the newly added sub-rule (1A) in Rule 11. The provisos added to this sub-rule specify that the details of the mode opted have to be informed to the CPCB, which has to publish the list of such producers, importers or brand owners on its website and update the same every quarter.

• Penalty for contravention

Any contravention under the Rules will result in a penalty ranging from Rs.10,000 to Rs.15 lakh. In case of continued contravention, an additional penalty of Rs.10,000 will apply for every day during which such contravention continues. This is as per new Rule 19 of the 2016 Rules read with Section 15 of the Environment (Protection) Act, 1986.

Conclusion

While these changes are a positive step toward sustainability and greater producer responsibility, their true impact will depend on practical implementation and execution. Without a well-structured approach, these regulations risk resembling a return to the license raj, turning ease of doing business into just another slogan.