Does India's plastic packaging producer responsibility apply to packaging on goods I export?
Rule 2(3), added in October 2023, says the plastic packaging responsibility in rule 9(1) does not apply to export oriented units, units in special economic zones, and other units making plastic packaging, or using it to pack products, for export against an order for export. Pre-consumer packaging waste from such units stays covered.
What the text says
Rule 9(1) is the rule that makes producers, importers and brand owners fulfil extended producer responsibility (EPR) for plastic packaging under Schedule II. Rule 2(3), inserted in October 2023, says sub-rule (1) of rule 9 shall not apply to export oriented units or units in special economic zones notified under the Special Economic Zones Act, 2005, and to other units manufacturing plastic packaging or on plastic packaging used for packaging products for export against an order for export. The proviso says it does not apply to pre-consumer plastic packaging waste generated by such units.
Two readings, and the one I would use
The sentence could mean that every unit making plastic packaging is outside rule 9(1), or only the packaging made for or used on export orders. The words against an order for export tie the exemption to export orders, so I read it narrowly: packaging that goes out on an export order. This is my reading, not a notice from the Central Pollution Control Board (CPCB). Ask CPCB in writing before you leave an export line out of your return.
What stays in, on my reading
- Packaging on goods sold in India.
- Pre-consumer plastic packaging waste, such as rejects and discards at the packaging maker, from export oriented units and special economic zone units.
- Packaging on goods without an export order behind them, such as stock held for a possible overseas sale.
What to keep
Packaging weight by pack type, split by export order and domestic sales, with the export order or shipping bill reference. Without that split you cannot show which tonnes were left out of the base.
A brand owner with 100 tonnes of rigid packaging, example
- Packaging on shipments against export orders: 30 tonnes. Domestic sales: 70 tonnes
- On my narrow reading, the base for the plastic obligation starts from the 70 tonnes
- Pre-consumer packaging waste from the 30 tonnes of export packaging still counts
The tonnages are examples. The reading is mine, so get CPCB's confirmation.
What Senseible does here
Senseible reads fuel invoices and electricity bills into records, so the diesel, fuel and power your site uses are on file. These rules are filed on government portals, outside Senseible's records.
- How to calculate a plastic packaging obligation
- What BRSR asks about plastic producer responsibility
- Plastic packaging label: registration number
- BRSR reporting
Last reviewed 2026-11-05. The exemption was added in October 2023. Check CPCB for any clarification of how the portal treats export orders.