Most talk about the 2026 plastic rules has been about recycled PET in bottles. But the same amendment also brings in reuse targets for rigid plastic packaging. For drinking water packs of 4.9 litres and above, which covers the familiar 20-litre jar, the target is set much higher than for any other kind of pack.
This guide explains what the rule says, as reported so far, and what it means for plants that fill and deliver returnable jars.
The notification
The Ministry of Environment, Forest and Climate Change notified the Plastic Waste Management (Amendment) Rules, 2026 as G.S.R. 237(E) dated 31 March 2026, amending the Plastic Waste Management Rules, 2016 (reported by Corporate Professionals on 7 April 2026 and LiveLaw on 12 April 2026).
Alongside the recycled-content targets we covered in our 40% recycled PET guide, the amendment sets minimum reuse obligations for brand owners using Category I (rigid) plastic packaging.
Reuse targets at a glance
The figures below are as reported by Corporate Professionals (7 April 2026), with the drinking water figures also reported by LiveLaw (12 April 2026) and Packaging Insights (15 April 2026).
| Category I rigid packaging | FY 2025-26 | From FY 2028-29 |
|---|---|---|
| Drinking water packaging, 4.9 litres/kg and above | 70% | 85% |
| Rigid packaging, 0.9 to 4.9 litres/kg | 10% | 25% |
| Other packaging, 4.9 litres/kg and above | 10% | 15% |
The reports we checked give the starting and final figures. They do not give the in-between years, so check the year-wise schedule in the gazette text before you plan.
Carry-forward, verification and responsibility
Carry-forward: As reported, a shortfall against the minimum reuse obligation can be carried forward for up to three years from FY 2026-27, provided at least one-third of the shortfall is made good each year.
Verification: The amendment allows verification by CPCB-designated agencies or by a new class of Registered Environment Auditors. The CPCB was to issue audit and verification guidelines within six months of notification. Check the CPCB EPR portal for whether those guidelines are now out.
Quality stays with the brand owner: Corporate Professionals reports that brand owners keep full responsibility for product quality and regulatory compliance when packaging is reused.
What this means for water plant owners
- Work out who the brand owner is. Reuse obligations sit with the brand owner. If you fill jars under your own brand, the obligation is yours. If you fill for another brand, your contract should say who reports what.
- Count your jars. To show reuse, you will need records of jars issued, returned, refilled and scrapped. Many jar plants already run a deposit or exchange system; turn it into written, dated records.
- Keep washing and inspection logs. Packaged drinking water is in FSSAI's high-risk food category (order of 29 November 2024), with pre-licence and annual risk-based inspections. Reusing more jars means your jar washing, inspection and rejection records matter even more. See our high-risk category guide.
- Keep testing on schedule. The FSSAI Scheme of Testing has been compulsory since 1 January 2026, with monthly microbiological testing and records kept for five years.
- Register and file on the CPCB EPR portal. Reuse and recycled-content figures go into your EPR annual return, with supporting documents.
- Check your other approvals. If you are adding a washing line or more capacity to handle returned jars, check whether your Pollution Control Board consent, FSSAI licence and CGWA NOC still cover what you do.
How ClearPath Compliance India can help
We help packaged drinking water plants with Plastic EPR registration and annual returns, jar reuse record-keeping formats, FSSAI licence and inspection readiness, Pollution Control Board CTE/CTO, CGWA NOC and the full approval checklist for a new plant. Send us an enquiry with your current licences and packaging details and we will tell you what applies to your unit.
This article is general information only, not legal advice. Rules are as reported on the dates stated above and may change; check the official MoEFCC gazette notification G.S.R. 237(E), the CPCB EPR portal and the FSSAI website before acting. Brand names, where mentioned on this site, are trademarks of their respective owners and are used for identification only. This article is not sponsored or endorsed by any brand.