TaxTMI 
TaxTMI 
FROM PLASTIC TO PAPER: FSSAI PUSHES PAN MASALA MAKERS TOWARD GREENER PACKAGING
X X X X Extracts X X X X
X X X X Extracts X X X X
....ROM PLASTIC TO PAPER: FSSAI PUSHES PAN MASALA MAKERS TOWARD GREENER PACKAGING<br>By: - YAGAY and SUN<br>Other Topics<br>Dated:- 20-8-2026<br>Introduction The packaging of pan masala is entering a significant regulatory transition. The Food Safety and Standards Authority of India (FSSAI) has proposed an amendment to the Food Safety and Standards (Packaging) Regulations, 2018, which would move pan masala packaging away from plastic, synthetic laminates, aluminium foil and metallised layers and towards paper, paperboard, cellulose and other naturally derived materials. Tin and glass containers would also be permitted under the proposed framework. A legal clarification is important at the outset. As of August 17, 2026, FSSAI's official notifications archive identifies the pan masala measure as a draft Food Safety and Standards (Packaging) Amendment Regulations, 2026, rather than a final notified amendment. The draft was published on April 28, 2026, under Section 92 of the Food Safety and Standards Act, 2006, and invited objections and suggestions from stakeholders. Therefore, references to the "new rules" should presently be understood as referring to the proposed regulato....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ry framework unless and until FSSAI publishes the final notification. Nevertheless, the proposal has considerable legal significance because it brings food-safety regulation and India's plastic-waste-management framework closer together. What Is FSSAI Proposing? The proposed amendment would insert a new entry, Serial No. 11, into Schedule IV of the Food Safety and Standards (Packaging) Regulations, 2018, specifically dealing with pan masala. Under the proposal, pan masala could be packed in: Paper Paperboard Cellulose Other naturally derived materials, provided they are completely free of plastic and synthetic polymers Tin containers Glass containers The proposed provision is significant because it specifically excludes polyethylene, polypropylene, polyester and PVC, as well as synthetic polymers, copolymers and laminates. It would also exclude aluminium foil and metallised layers from paper- or cellulose-based packaging. The proposal therefore represents more than a conventional shift from plastic to paper. It seeks to change the material composition of the packaging itself. The Legal Foundation: Food Safety and Standards Act, 2006. The F....
X X X X Extracts X X X X
X X X X Extracts X X X X
....SSAI's authority over food packaging flows primarily from the Food Safety and Standards Act, 2006. Section 23 of the Act provides the statutory foundation for regulating the packaging and labelling of food. The broader objective of the Act is to ensure that food is safe and that its manufacture, storage, distribution and sale do not compromise consumer safety. The proposed amendment has been issued under Section 92(2), read with Section 23, of the Food Safety and Standards Act, 2006. The draft notification was published to provide affected stakeholders with an opportunity to submit objections and suggestions before the regulations are finalised. This consultation process is legally important because a draft regulation is not the same as a final regulation. Businesses should therefore monitor FSSAI's final notification and its effective date rather than treating the April 2026 draft as an immediately enforceable final amendment. Environmental Law Already Restricts Plastic Packaging for Pan Masala. The proposed FSSAI amendment does not operate in isolation. India's environmental legislation already contains specific restrictions concerning plastic packag....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ing for pan masala, gutkha and tobacco products. The Plastic Waste Management Rules, 2016, framed under the Environment (Protection) Act, 1986, contain restrictions on the use of plastic material for packaging gutkha, tobacco and pan masala. • Rule 4(1)(f) provides that sachets using plastic material shall not be used for storing, packing or selling gutkha, tobacco and pan masala. • Rule 4(1)(i) further restricts the use of plastic material in packages used for packaging gutkha, pan masala and tobacco in all forms. The proposed FSSAI amendment reinforces this environmental-law position by expressly addressing plastic, synthetic polymers, copolymers, laminates, aluminium foil and metallised layers. This creates an important regulatory connection between food safety law and environmental law. Why Plastic-Laminated Pouches Are a Major Concern? Flexible pouches have traditionally provided several commercial advantages to manufacturers. They are lightweight, relatively inexpensive, easy to transport and capable of providing barriers against moisture, oxygen and light. However, many flexible pouches are composite structures. A single pouch may con....
X X X X Extracts X X X X
X X X X Extracts X X X X
....tain plastic film, adhesive layers, metallised film or aluminium foil. Such multilayer packaging can create challenges at the end of its useful life because separating its different components can be difficult. This can reduce recyclability and contribute to plastic waste. The proposed FSSAI language therefore goes beyond a simple prohibition of conventional plastic bags. It addresses synthetic polymers, copolymers, laminates, aluminium foil and metallised layers. For manufacturers, this means that changing only the visible outer layer of a package may not be sufficient. The complete packaging structure must be assessed. The Environmental Law Dimension: Extended Producer Responsibility India's plastic-waste-management framework has increasingly adopted the principle of Extended Producer Responsibility (EPR). Under the Plastic Waste Management Rules and the EPR framework, producers, importers and brand owners have responsibilities relating to the environmentally sound management of plastic packaging waste. The Central Pollution Control Board (CPCB) operates the plastic-packaging EPR framework and provides a registration and compliance mechanism for covered entities. ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....However, an important legal distinction must be made: EPR is not a substitute for a prohibition on plastic packaging. Where plastic packaging is prohibited for a particular product, a manufacturer cannot argue that such packaging becomes permissible merely because the company is willing to meet its EPR obligations. EPR concerns the management of permitted plastic packaging. It does not, by itself, legalise a packaging material that is otherwise prohibited by law. Paper Packaging Does Not Automatically Mean Compliance. The proposed shift from plastic to paper should not be interpreted as meaning that every paper-based package would automatically comply with the proposed FSSAI requirements. The draft specifically requires paper, paperboard, cellulose and naturally derived materials used for pan masala packaging to be free from plastic and synthetic polymers, copolymers and laminates. It also excludes aluminium foil and metallised layers. Consequently, a manufacturer cannot simply purchase a conventional "paper-look" pouch and assume that it satisfies the proposed requirements. Packaging companies will need to establish the actual composition of the material, including:....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Coatings Adhesives Barrier layers Laminations Synthetic polymers Other components forming part of the packaging structure This is particularly important because packaging that looks like paper on the outside may contain plastic or metallised layers underneath. Food Safety Cannot Be Sacrificed for Sustainability. While environmental sustainability is an important regulatory objective, packaging also performs an essential food-safety function. Pan masala packaging must protect the product from contamination, moisture and deterioration. An alternative package that is environmentally preferable but fails to protect the product adequately may create a separate food-safety concern. Manufacturers will therefore need to balance three objectives: • Compliance with the material restrictions; • Food-contact safety and product integrity; and • Environmental sustainability. FSSAI's packaging framework requires food-contact materials to be safe and suitable for their intended use. Therefore, the transition to paper or naturally derived materials cannot come at the expense of food safety. The concept of "green packagi....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ng" should consequently not be limited to the appearance of the package. Regulatory compliance requires assessment of the actual material, its composition and its suitability for food contact. What the Proposed Rules Mean for Pan Masala Manufacturers? The proposed framework could have significant operational consequences for manufacturers currently using plastic or metallised flexible packaging. Manufacturers may need to review: Existing packaging specifications Packaging machinery Pouch-forming and sealing systems Raw-material suppliers Packaging coatings and adhesives Barrier properties Printing systems Quality-control procedures Product shelf-life Food-contact safety Documentation establishing regulatory compliance Packaging suppliers may also face increased pressure to disclose the precise composition of their materials. For large manufacturers, the transition could require significant capital investment in new packaging machinery and production systems. For smaller manufacturers, the availability and cost of compliant packaging materials could become a more immediate concern. At the same time, the proposed changes could cr....
X X X X Extracts X X X X
X X X X Extracts X X X X
....eate opportunities for manufacturers producing paper-based, cellulose-based, tin and glass packaging. A Wider Shift in India's Environmental Policy The proposed pan masala packaging amendment forms part of a broader movement in India's environmental policy towards reducing plastic pollution and strengthening accountability throughout the packaging lifecycle. The Ministry of Environment, Forest and Climate Change has continued to strengthen India's plastic-waste-management framework through amendments to the Plastic Waste Management Rules and the development of the EPR system. The overall policy direction is increasingly focused not merely on how products are manufactured and sold, but also on what happens to packaging after consumption. The proposed FSSAI amendment takes this approach further by addressing the packaging material at the point at which the pan masala product is placed on the market. Compliance Steps for Manufacturers Although the FSSAI amendment remains a draft according to the regulator's notification archive, manufacturers should consider preparing for the proposed changes. • Conduct a Packaging-Material Audit - Manufa....
X X X X Extracts X X X X
X X X X Extracts X X X X
....cturers should identify every component of their existing packaging, including plastic films, polymers, adhesives, coatings, aluminium and metallised layers. • Obtain Supplier Documentation - Manufacturers should obtain detailed technical specifications and declarations from packaging suppliers concerning the composition of proposed alternative materials. • Test Alternative Packaging - Alternative packaging should be assessed for food-contact safety, durability, moisture resistance, shelf-life and overall product integrity. • Review Environmental Compliance - Companies should separately examine their obligations under the Plastic Waste Management Rules, EPR framework and other applicable environmental laws. Compliance with an FSSAI requirement should not automatically be assumed to satisfy every environmental obligation. • Monitor the Final FSSAI Notification - Manufacturers should closely monitor FSSAI's official notifications because the April 2026 document is a draft. The final regulation could contain changes, transitional provisions or a specific implementation period. Conclusion The proposed transition from plastic....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... to paper in pan masala packaging is significant because it demonstrates the increasing convergence of India's food-safety and environmental regulatory frameworks. The legal framework rests on two complementary pillars. The Food Safety and Standards Act, 2006 and the Food Safety and Standards (Packaging) Regulations, 2018 regulate food packaging from the perspective of safety and suitability, while the Environment (Protection) Act, 1986 and the Plastic Waste Management Rules, 2016 address the environmental consequences of plastic packaging. The proposed FSSAI amendment would bring these regulatory approaches closer together by identifying permissible materials for pan masala packaging and reinforcing restrictions on plastic-based packaging. For manufacturers, packaging can no longer be viewed simply as a commercial or branding decision. Material composition, food-contact safety, environmental obligations and compliance documentation are becoming interconnected aspects of regulatory compliance. At the same time, the legal position must be reported accurately. As of August 17, 2026, FSSAI's official notification archive identifies the pan masala packaging measure as ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....a draft amendment rather than a final notified regulation. The direction of regulatory policy, however, is clear. Pan masala manufacturers are being pushed towards packaging formats that reduce reliance on plastic, synthetic laminates, aluminium foil and metallised layers. The transition from plastic to paper may therefore become more than an environmental initiative. It could represent a fundamental change in how pan masala manufacturers design, source, test and document their packaging in order to meet India's evolving food-safety and environmental requirements. *** SOURCES AND REFERENCES • Food Safety and Standards Authority of India (FSSAI) • Draft Food Safety and Standards (Packaging) Amendment Regulations, 2026. • Official FSSAI document dated April 28, 2026. • Food Safety and Standards Authority of India (FSSAI) • Official Notifications - Regulations. • Available through the FSSAI official website. • Food Safety and Standards Act, 2006 • Act No. 34 of 2006. • Government of India legislation establishing the statutory framework for food safety a....
X X X X Extracts X X X X
X X X X Extracts X X X X
....nd regulation of food packaging. • Food Safety and Standards (Packaging) Regulations, 2018 • Regulations issued by the Food Safety and Standards Authority of India under the Food Safety and Standards Act, 2006. • Environment (Protection) Act, 1986 • Act No. 29 of 1986. • Principal environmental legislation under which the Plastic Waste Management Rules, 2016 were framed. • Plastic Waste Management Rules, 2016 • Ministry of Environment, Forest and Climate Change, Government of India. • Relevant provisions include restrictions concerning plastic packaging of gutkha, pan masala and tobacco products. • Plastic Waste Management (Amendment) Rules, 2022 and subsequent amendments • Ministry of Environment, Forest and Climate Change, Government of India. • Relevant to the Extended Producer Responsibility framework for plastic packaging. • Central Pollution Control Board (CPCB) • Plastic Packaging Extended Producer Responsibility (EPR) Portal. • Relevant to registration, reporting and EPR compliance for covered p....
X X X X Extracts X X X X
X X X X Extracts X X X X
....lastic-packaging entities. • Ministry of Environment, Forest and Climate Change (MoEFCC) • Annual Report 2024-25 and official materials concerning plastic-waste management and EPR. • FSSAI - Food Packaging Guidance • Official guidance concerning food-contact materials, packaging safety and sustainable food packaging. IMPORTANT LEGAL DISCLAIMER This article is intended for general informational and educational purposes only and does not constitute legal advice. The regulatory position may change through final notifications, amendments, circulars, government orders or judicial decisions. Before taking any commercial or compliance decision, pan masala manufacturers and other stakeholders should verify the latest notification issued by FSSAI and the applicable provisions of the Food Safety and Standards Act, 2006, the Food Safety and Standards (Packaging) Regulations, 2018, the Environment (Protection) Act, 1986, and the Plastic Waste Management Rules, 2016. =============<br> Scholarly articles for knowledge sharing by authors, experts, professionals ....