Fresh bread loaves stacked in plastic crates for transport, where outer packaging never touches the bread

A Bread Company Was Afraid of Recycled Plastic. Here Is What Happened.

A large food company came to us with a simple worry. They make bread, and they sell a lot of it. Under India's plastic EPR rules they now have to use recycled plastic in their packaging, and the share goes up over the next few years.

Their fear was performance.

They thought a bag with recycled plastic would tear, split at the seal or look dirty on the shelf.

We supplied them bags with 30% PCR LDPE for the packaging that does not touch the bread. We made them on our own blown film lines in Jaipur.

The bags performed like their old virgin bags.

This post explains how I think about it, and where recycled plastic can go, where it cannot, and what to check before you try it.

First, the rule that decides everything: food contact stays virgin

The bag that touches the bread must stay virgin plastic.

The law decides this, and we follow it without exception.

In 2025 FSSAI amended its packaging regulations to allow recycled plastic in food contact, but only recycled PET, and only from approved recycling processes with a decontamination step (FSSAI's guidelines on recycled PET as a food contact material, May 2025). There is no such route for recycled LDPE or recycled PP. So the inner bread bag, the one the slice actually touches, stays virgin.

We say this upfront to every food customer. If a supplier offers you "recycled" bags for direct food contact in polyethylene, ask them which FSSAI approval they are working under.

So where does recycled plastic go?

Into the packaging that never meets the food. A bread company uses a lot of it:

  1. outer bags that hold several bread packs together,
  2. liners for the plastic crates that go to shops,
  3. bundling and transport bags in the warehouse,
  4. any secondary bag where the bread is already sealed inside its own virgin pack.

For this customer the PCR bags went into all three uses: outer bags holding several packs, crate liners and bundling bags. The food inside was always in its own virgin pack. You can see our virgin food-grade range on the bread packaging bags page.

What the EPR rules ask for

As per the Plastic Waste Management Rules, flexible plastic packaging falls in Category II. Brand owners must use a minimum share of recycled plastic in it. The CPCB's standard operating procedure of June 2024 lays out the targets from the 2022 EPR notification, and the 2026 amendment kept the same figures.

Financial year Minimum recycled plastic, Category II
2025-26 10%
2026-27 10%
2027-28 20%
2028-29 onwards 20%

Two points that people miss, and I see them missed often.

First, the 2026 amendment, as reported in the legal press, exempts packaging where the law restricts recycled content, for example some food uses. That sounds like relief for a food company. In practice it means the recycled share has to come from the non-contact layers, because the contact layer cannot carry it.

Second, the recycled content has to be provable. A supplier saying "this has recycled plastic" is not enough for an EPR return. Brand owners report their use of recycled plastic on CPCB's centralised EPR portal, and that claim rests on certificates from registered plastic waste recyclers. Your EPR consultant will know which papers your own return needs.

People often mix this up with GRS (Global Recycled Standard), so let me be exact. We are GRS certified, but our GRS scope covers packing bags made with 50% to 100% post-consumer recycled PE. This customer's 30% bags sit below that, so they were outside GRS. GRS is also not the EPR proof in India. If a buyer wants GRS as well, we make the bag with 50% or more PCR, and the shipment can then carry a GRS transaction certificate. Our certificates are on the certifications page.

Why they were scared, and why it was fair

I understood their fear. It was not silly.

Recycled LDPE is different from virgin, and we see the difference every time we run it.

  1. It can carry small gels and specks from the old plastic.
  2. It is not as clear as virgin film, so a bag can look a little hazy or off-white.
  3. Its strength can vary from lot to lot, because the waste going into it varies.

Put too much of it in, or buy it from an unreliable recycler, and you will get the weak, blotchy bag they were afraid of. I have seen such bags in the market. They give recycled plastic a bad name.

This is why 30% made sense for them. At 30% PCR, the other 70% is virgin LDPE, and the virgin part carries most of the strength. Think of it like mixing old and new rice in the same pot. A cook can blend some old rice in without spoiling the dish, but nobody fills the whole pot with it and hopes for the best.

30% is also above the 20% target that applies from 2027-28, so these bags already meet the highest Category II figure on the current table.

The trial

We did not ask them to switch all their bags on day one. I never ask a customer to do that. They started the trial with one bag on their own packing line: a 45 cm x 60 cm outer liner for their masala range.

They checked three things: how well the bag sealed, its strength, and how it looked. The bags held up.

Performance stayed the same as their old virgin bags, which was the whole point. Their worry going in was that recycled would mean weaker. It did not.

I will be honest about one limit. A PCR bag will not look exactly like a virgin bag. If you want a glass-clear, sparkling outer bag, 30% PCR may show a slight tint. For crate liners and outer bags nobody minded, but for a bag that sits on a premium shelf, you should see a sample first.

What to ask your supplier before you try PCR

  1. What proof will the supplier give for the recycled share, and will your EPR consultant accept it?
  2. If you also want GRS, is that exact bag inside the supplier's GRS scope, and will each shipment carry a transaction certificate?
  3. What percentage of PCR is in the bag, and is it written on the invoice?
  4. Which layer or which bag will carry the recycled content? It must never be the food-contact one.
  5. Can they run a trial lot before you change your full order?
  6. What thickness and seal strength will they guarantee at that PCR level?

Short answers to common questions

Can recycled LDPE touch bread or other food?

No. Today FSSAI allows recycled plastic in food contact only for PET from approved processes. Recycled LDPE belongs in secondary packaging.

Does using 30% PCR bags settle a company's whole EPR target?

Not by itself. The target is counted on the brand's total Category II packaging, so the PCR bags help raise the overall share. Your EPR consultant should do the final calculation.

Is PCR LDPE weaker than virgin?

It can be, if the PCR share is high or the recycled material is poor. At 30% with good material, this customer saw no change in performance.

If you are a food or FMCG company working out your recycled-content plan, send us a list of your secondary packaging with sizes and current thickness. We will tell you which items can carry PCR LDPE, at what share, and which must stay virgin.

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