World Circular Economy Forum Comes to Gandhinagar: Circularity Moves From Policy to Compliance

In 2023-24, Indian producers put 788,027 tonnes of plastic packaging onto the market. About 71 per cent of it was technically recyclable. The share that actually contained recycled material was one per cent.

That gap is the reason the World Circular Economy Forum landed in Gandhinagar this week rather than in a European capital, and it is the reason recycled content stopped being a marketing line and became a reportable number with a penalty attached.

What Is Happening At Mahatma Mandir

WCEF2026 ran from 15 to 18 September at Mahatma Mandir in Gandhinagar, Gujarat. It is the tenth edition of the forum and the first held in South Asia. Sitra, the Finnish Innovation Fund that started the event in 2017, co-hosted with India's Central Pollution Control Board, with backing from the Ministry of Environment, Forest and Climate Change and the Government of Gujarat.

The theme was "Circular economy: transition for people and prosperity". The main forum occupied 15 and 16 September with four plenaries, sixteen parallel sessions and an exhibition. Accelerator sessions followed on 17 and 18 September. In-person attendance was by invitation; the online stream was free.

Forums do not create obligations. But the choice of host tells you where the regulatory centre of gravity has shifted. India now operates one of the largest mandatory extended producer responsibility systems anywhere, covering plastics, electronics, batteries, tyres, used oil, and since April this year, non-ferrous metal scrap and construction and demolition waste. Roughly a hundred thousand producer registrations sit on the CPCB portal. The scale is not the story. The enforcement is.

The Recycled Content Mandate Indian Producers Are Already Inside

Schedule II of the Plastic Waste Management Rules, inserted in February 2022, set the clock running. Obligations for recycled content in plastic packaging began with the financial year 2025-26, which means the first compliance returns fall due on 30 June 2026 for that year.

The percentages step up annually:

• Category I, rigid plastic packaging: 30 per cent recycled content in FY2025-26, rising to 40 per cent, 50 per cent and 60 per cent by FY2028-29

• Category II, flexible packaging of single or multiple layers: 10 per cent, reaching 20 per cent by FY2028-29

• Category III, multilayered packaging with at least one non-plastic layer: 5 per cent, reaching 10 per cent by FY2028-29, calculated on the plastic component only

• Category IV, compostable and biodegradable plastic sheets used for carry bags: exempt from the recycled content requirement

Reuse targets sit alongside them and attract less attention than they deserve. Rigid containers between 0.9 and 4.9 litres or kilograms must hit 10 per cent reuse in FY2025-26, climbing five percentage points a year to 25 per cent by FY2028-29. Containers of 4.9 litres or kilograms and above start at 10 per cent and reach 15 per cent from FY2028-29.

The Plastic Waste Management (Amendment) Rules dated 31 March 2026 reworked how certificates are generated, how audits run and how shortfalls are treated. Two provisions matter most to anyone currently short.

The first is a carry-forward mechanism for food-contact packaging. From FY2026-27, producers who cannot source compliant food-grade recycled resin may carry a shortfall forward for up to three years, provided they clear at least one third of it each year. This is not a waiver. It is a repayment schedule.

The second is the exemption route. Where the Food Safety and Standards Authority of India, the Central Drugs Standard Control Organisation, the Central Insecticide Board, or an applicable Indian Standard restricts the use of recycled plastic in a given application, the producer can claim relief. The claim has to be documented in the annual return and it has to name the instrument that imposes the restriction. Vague assertions about food safety will not survive an audit.

For food contact specifically, recycled resin must meet IS 14534:2023 and carry FSSAI approval. That approved supply is thin. Producers who assumed they would buy their way to 30 per cent in the final quarter discovered that the compliant material does not exist in the volumes the market needs.

Two Traps In The Indian System

Imported packaging does not count toward your recycled content obligation, whatever the exporter's own recycled share may be. Importers discharge their EPR through purchased certificates instead. Companies that shifted packaging sourcing offshore to chase a lower unit price have quietly increased their certificate exposure.

And unlike the e-waste and battery frameworks, where CPCB set floor and ceiling prices for certificates, plastic EPR certificate prices float. There is no cap. A thin market in a year of tight supply prices shortfalls at whatever the market will bear, which is precisely when producers need to buy.

Environmental compensation runs at 5,000 rupees per tonne for a first-year shortfall, 10,000 for a second consecutive year and 20,000 for a third, under CPCB guidelines issued in April 2024. Payment does not extinguish the underlying obligation.

Traceability tightened too. Since 1 July 2025, producers have had to mark plastic packaging with a barcode, QR code, brochure or unique identification number and register the scheme with CPCB. That marking is the hook on which future product-level data requirements will hang.

The European Overlay Landed In August

Indian exporters supplying the European Union are now inside a second system that measures the same physical product against different rules.

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, began applying on 12 August 2026. It replaced a directive that member states transposed differently with a regulation that applies directly and identically in all of them.

What changed for a supplier outside the EU:

Packaging placed on the EU market must undergo conformity assessment under Annex VII, and the producer or importer must draw up an EU Declaration of Conformity under Annex VIII. Technical documentation has to be retained for five years, or ten for reusable packaging.

Article 45 requires non-EU producers selling into the Union to appoint an authorised representative for EPR in each member state where they place packaging. One representative covering the bloc does not satisfy the article.

Article 16 places an information duty on suppliers up the chain. Article 18 obliges importers to verify that the packaging they bring in carries a compliance declaration and correct labelling. Indian manufacturers will feel Article 18 first, because their EU customers will start demanding the paperwork that lets them satisfy it.

Per- and polyfluoroalkyl substances above defined thresholds are banned in food-contact packaging.

The binding recyclability performance grades and the EU recycled content minimums do not bite until 1 January 2030. That is the date most commentary fixates on. The documentation obligations are live now, and the companies losing contracts this quarter are losing them on paperwork, not on percentages.

Digital Product Passports Are No Longer Hypothetical

The European Commission's Digital Product Passport registry went live on 20 July 2026 under Commission Implementing Regulation (EU) 2026/1778. It is the central infrastructure layer: a registry that stores passport identifiers and routes users to the data carrier on the product.

Nothing is universally mandatory yet. Obligations arrive sector by sector through delegated acts under the Ecodesign for Sustainable Products Regulation, each carrying a transition period of at least eighteen months. Batteries are furthest along, with battery passports required from 18 February 2027 for industrial and electric vehicle batteries above 2 kWh. Textiles, steel, aluminium and electronics are in the queue.

The connection to India is direct and underappreciated. A passport carries data about material composition, recycled content, repairability and end-of-life handling. That data originates at the manufacturing site, not at the importer's desk in Rotterdam. An Indian textile mill or component maker that cannot state recycled content per stock keeping unit, with evidence, will find its European customers moving to suppliers who can.

The CPCB barcode requirement and the EU passport requirement point at the same capability. Building two disconnected systems to satisfy them is an expensive mistake that a number of Indian groups are making right now.

Where ESRS E5 Fits

For Indian subsidiaries and suppliers of EU-reporting groups, circularity has also entered the disclosure layer. ESRS E5 covers resource use and the circular economy: resource inflows including the share of recycled or reused material, resource outflows including durability, recyclability and waste generated, and the policies, actions and targets attached to each.

E5 applies only where resource use and circularity emerge as material under the double materiality assessment. For a packaging manufacturer, a plastics converter, an electronics assembler or a textile producer, that outcome is close to automatic.

The revised ESRS published in 2026 cut datapoint counts substantially across the standards, and the value-chain cap limits what a reporting company can demand from suppliers below certain thresholds. Neither change removes the underlying question. When an EU customer runs its E5 disclosure, the recycled content figure for the components it buys has to come from somewhere, and the value-chain cap governs mandatory demands rather than contractual ones. Purchase agreements are already carrying clauses that the cap does not touch.

Indian companies filing BRSR face a parallel ask. Principle 2 of the BRSR seeks disclosure on recycled input material and on reclaimed products, and BRSR Core includes recycled input as an assured attribute for the top listed entities. A company reporting recycled content one way to CPCB, another way in its BRSR and a third way to its European customer has a reconciliation problem that will surface at assurance.

What To Do Before The June Return

Reconcile the FY2025-26 numbers now. The return for the financial year just ended is due 30 June. If Category I rigid packaging came in below 30 per cent, the shortfall is already fixed. The only remaining decisions concern certificate purchase, documented exemption, or compensation, and certificates get more expensive as the deadline approaches.

Audit every exemption claim against its source instrument. Name the FSSAI, CDSCO, Central Insecticide Board or Indian Standard provision that restricts recycled content in that specific application. If the restriction cannot be cited, the exemption will not hold.

Separate imported packaging in your own records. It sits outside the recycled content calculation and inside the certificate obligation. Procurement teams optimising on landed cost frequently do not know this.

Build the recycled content figure at stock keeping unit level, not at plant level. CPCB reporting, EU customer requests, BRSR Principle 2 and eventual DPP entries all resolve to the product. A plant average satisfies none of them cleanly.

Appoint EU authorised representatives per member state if you place packaging on the EU market directly. Article 45 is jurisdiction by jurisdiction, and appointment takes longer than most companies budget for.

Assemble the PPWR conformity file before a customer asks. Annex VII assessment, Annex VIII declaration, five-year retention. The first EU importer to request it will not accept a promise that it is in progress.

Check whether your material is now in EPR scope at all. Non-ferrous metal scrap, covering aluminium, copper, zinc and their alloys, and construction and demolition waste came into the EPR framework on 1 April 2026. Registration deadlines for these streams are running.

The producers that will come out of this decade in good shape are not the ones who bought the most certificates. They are the ones who know, per product, what went into it and what happens to it afterwards, because every regime converging on Indian manufacturing is asking a version of that single question.

Position as of 18 September 2026. EPR obligations, recycled content percentages and certificate mechanics differ by waste stream, category and state, and the Plastic Waste Management (Amendment) Rules 2026 are being operationalised through CPCB guidelines that continue to issue. EU delegated acts under ESPR are at varying stages. Confirm current requirements against CPCB, MoEFCC, SEBI, the European Commission and your national competent authority, and take professional advice for your circumstances.

Sources

Sitra, Central Pollution Control Board, Ministry of Environment, Government of Gujarat, Plastic Waste Management, Bureau of Indian Standards, Food Safety and Standards Authority of India, E-Waste (Management) Rules 2022, Securities and Exchange Board of India, Regulation (EU), European Commission, European Financial Reporting Advisory Group, Official Journal of the European Union

This article is intended for general professional information and does not constitute legal, financial, or investment advice.