Is a QR code for EPR details mandatory on plastic packaging? What the 2025 rule really says

Search for "EPR QR code" and many pages tell you that a QR code has been mandatory on plastic packaging in India since 1 July 2025.

It is not.

The rule says a producer, importer or brand owner "may" give the required details through a barcode or QR code. I went back to the gazette notification itself, because one word, "may" or "shall", decides whether your next print run is right or wrong. Printing the details on the pack is still a lawful way to comply.

Checked against official sources on 28 October 2026.

I am not a lawyer. Read this as a packaging maker's reading of the gazette text, and check your own case with your EPR consultant.

What rule 11(1) asks you to print

Rule 11 of the Plastic Waste Management Rules, 2016 deals with marking and labelling. Under sub-rule (1), each carry bag, plastic packaging and multilayered packaging must carry these details in English.

1. The name and registration number of the producer or brand owner. This applies to all three kinds of pack.
2. The thickness, for carry bags and plastic packaging. Multilayered packaging needs only the name and registration number.
3. For compostable carry bags, the certificate number of the producer.

This is still the default. If you choose none of the new options, you print these details on the pack, as before.

At Jagannath Polymers we make plastic film and bags, so this rule applies to our own bags too.

What rule 11(1A) added in 2025

The Ministry of Environment, Forest and Climate Change notified the change on 23 January 2025 as G.S.R. 73(E) (gazette copy hosted by the Maharashtra Pollution Control Board). The new sub-rule (1A) says a producer, importer or brand owner "may", with effect from 1 July 2025, provide the sub-rule (1) information in one of three ways.

1. In a barcode or QR code printed on the plastic packaging.
2. In the product information brochure.
3. By printing on the packaging a unique number issued under any other law in force, where the sub-rule (1) requirements are met before that number is issued.

Two provisos follow. The company must inform the Central Pollution Control Board (CPCB) of how it has published the details. CPCB must then publish a list of these companies on its website and update it every quarter.

The same notification added rule 19. Anyone who breaks the rules is liable to a penalty under section 15 of the Environment (Protection) Act, 1986.

Why so many people think it is mandatory

I can see how the confusion started. "From 1 July 2025" reads like a deadline, and a deadline sounds like an order.

In a statute, though, "may" gives you a choice and "shall" gives you a duty. Rule 11(1A) uses "may" for the QR code. The only "shall" that binds the company comes after you have chosen a route: then you shall inform CPCB.

So the QR code is a door you may walk through.

Once you walk through it, you must tell CPCB that you did.

What the QR code must carry

It must carry the information under sub-rule (1). For most packs, that means your name, your registration number and, where it applies, the thickness.

The rule does not say whether that information must sit inside the code as text, or on a web page that the code opens. Here is my advice. I give it as a printer, and a lawyer may add to it.

1. Encode the details as plain text inside the code. It reads on any phone, with no internet, and it cannot break when a website changes. This is the option I would choose.
2. If you prefer a link, keep that page live for as long as any pack is in the market. A pouch printed this month can sit in a warehouse for a year.
3. Do not use a link shortener that can expire, and do not point the code at a page that needs a login.
4. If you already print a GS1 QR code for retail, ask your EPR consultant whether one code can serve both jobs before you put two QR codes side by side. Two look-alike codes confuse shoppers and scanner operators alike.

What the QR route does not cover: the recycled-content label

This is the point the "mandatory QR" pages leave out. Rule 11(1A) lets you move only the sub-rule (1) details into a code. It says nothing about sub-rule (2).

Sub-rule (2) was rewritten on 31 March 2026 by the PWM (Amendment) Rules, 2026, G.S.R. 237(E). It says each recycled plastic packaging or commodity shall conform to IS 14534:2023, shall bear the label and marking shown in the rule indicating the recycled plastic content, and shall also follow FSSAI's marking rules for food-contact use.

My reading is that the recycled-content mark stays printed on the pack.

Copy the mark itself from the 2026 gazette. An old pouch may still carry the earlier wording, which the 2026 text replaced.

Why this matters more from 1 April 2027

The same 2026 amendment raised the minimum recycled content that obligated producers, importers and brand owners must use. The step up on 1 April 2027, the start of FY 2027-28, is the big one.

More recycled content means more packs that need the rule 11(2) mark. If your artwork is due for a change before April 2027 anyway, plan the recycled-content mark into it now and change the cylinders once, not twice.

Two cautions. The targets do not apply where a law or mandatory standard does not permit recycled plastic, such as some food-contact uses, and that exemption must be cited in the annual return. And micro and small brand owners are outside the EPR obligations (micro and small producers still have duties of their own), so check your own Udyam classification and portal status before assuming the table applies to you.

If you choose a QR code: make it scan on film

A QR code on a flat paper proof is easy. On a filled, sealed pouch it is harder, because film stretches, creases and shines.

We print on film ourselves, and these are the checks we would run.

1. Keep the code away from seals, gussets and folds. Creases break the squares.
2. On clear film, print a white patch under the code. Dark squares need a light background behind them.
3. Leave a clear margin round the code. For a QR Code that is 4 modules on every side.
4. Keep the squares big enough. The EPR rule sets no size, but GS1's sizes for retail 2D codes are a sensible floor. Our lesson on adding a GS1 QR code next to your barcode gives the numbers.
5. Scan the finished pack, filled and sealed, with three different phones. Scan a pack from the end of the roll as well as the start.

What to do now

1. Decide your route: print the sub-rule (1) details, or use one of the three rule 11(1A) options. Write the decision down with the date. We would keep that note in the same file as your EPR registration.
2. If you choose a code, brochure or unique number, inform CPCB and keep proof of the intimation. Later, check that your name appears on CPCB's quarterly list.
3. Check every live artwork for the name, registration number and, where needed, thickness.
4. For packs with recycled content, add the rule 11(2) mark from the 2026 gazette and keep your supplier's recycled-content documents for each lot.
5. Before 1 April 2027, list the SKUs whose recycled content must rise, and plan one artwork change for each.
6. Keep one printed sample of every pack design with its print date. When someone asks what was on the pack in 2027, you will have the answer in your hand.

Labels and printed films are made in our group, by Jagannath Labels and Jagannath Polymers. If you are unsure what your next print run should carry, send us the artwork through the contact page. We will tell you what we see missing, and you can take that list to any printer you like.