<h2><strong>Policy & Regulation Radar</strong></h2>.<p><strong>The divergence</strong></p><p>The EU and US are retreating on ESG mandates. SEBI is not. India is moving in the opposite direction, a signal of where this regulatory environment is heading long-term. Indian exporters should note that while CSRD scope has narrowed dramatically, EU carbon border tariffs (CBAM) remain fully in force for cement, steel and aluminium.</p>.<h2><strong>Sector Snapshot: FMCG</strong></h2>.<p>The Plastic Waste Management Amendment Rules, notified by Ministry of Environment, Forest and Climate Change of India in April 2026, land squarely on this sector. Rigid plastic packaging must now contain 30% recycled content, rising to 60% by 2028-29. Over 60,000 producers, importers and brand owners are registered under Extended Producer Responsibility (EPR), but compliance quality is uneven. Fake EPR certificates have been flagged in large numbers and the Central Pollution Control Board is tightening digital traceability on its portal.</p>.<h3><strong>The Gap</strong></h3><p>The companies above are the outliers. The majority of India's FMCG sector, particularly mid-sized and regional players, remains well behind target. Three areas where the gap is widest and greenwashing risk is highest:<br></p><ul><li><p><strong>Cost barriers: </strong>Switching to sustainable packaging costs 25-50% more than conventional materials. Smaller brands absorbing input cost pressures are unlikely to invest beyond the minimum required.</p></li><li><p><strong>Multi-layered plastics: </strong>The sachets and pouches that dominate mass-market FMCG remain largely unrecyclable in India. Recycling infrastructure for these materials does not exist at scale.</p></li></ul><p><strong>EPR certificate fraud: </strong>Fake EPR certificates have been flagged in large numbers. The portal-based system allows companies to purchase recycling credits without verifying that actual recycling has taken place.</p>.<h3><strong>The Open Question</strong></h3><p>India’s largest FMCG companies are making genuine progress on their own operations and packaging. But the real sustainability footprint of this sector lives in the supply chain - in the thousands of contract manufacturers, small suppliers and informal waste collectors that the headline numbers rarely capture. As BRSR assurance expands and Scope 3 reporting matures, will Indian FMCG companies be willing to shine a light on their full value chain, or will sustainability continue to be a story told only about the parts they control?</p>.<h2><strong>Data Point of the Month</strong></h2>.<h2><strong>DID YOU KNOW?</strong></h2><p><strong>EPR compliance does not mean your packaging is being recycled.</strong></p><p>Under India’s Extended Producer Responsibility framework, brands meet their plastic waste obligations by purchasing credits on the CPCB portal, not by ensuring their packaging is physically collected and processed. A company can be fully compliant on paper while none of its plastic ever reaches a recycler. The CPCB has flagged thousands of fake EPR certificates in the system and the portal still runs largely on self-declaration with limited traceability.</p><p><em>As BRSR assurance expands, auditors will increasingly scrutinise EPR claims. ‘EPR compliant’ is not the same as ‘our plastic is being recycled’ and that distinction is about to matter a great deal more.</em></p>.<h2><strong>Actionable Tools</strong></h2>
<h2><strong>Policy & Regulation Radar</strong></h2>.<p><strong>The divergence</strong></p><p>The EU and US are retreating on ESG mandates. SEBI is not. India is moving in the opposite direction, a signal of where this regulatory environment is heading long-term. Indian exporters should note that while CSRD scope has narrowed dramatically, EU carbon border tariffs (CBAM) remain fully in force for cement, steel and aluminium.</p>.<h2><strong>Sector Snapshot: FMCG</strong></h2>.<p>The Plastic Waste Management Amendment Rules, notified by Ministry of Environment, Forest and Climate Change of India in April 2026, land squarely on this sector. Rigid plastic packaging must now contain 30% recycled content, rising to 60% by 2028-29. Over 60,000 producers, importers and brand owners are registered under Extended Producer Responsibility (EPR), but compliance quality is uneven. Fake EPR certificates have been flagged in large numbers and the Central Pollution Control Board is tightening digital traceability on its portal.</p>.<h3><strong>The Gap</strong></h3><p>The companies above are the outliers. The majority of India's FMCG sector, particularly mid-sized and regional players, remains well behind target. Three areas where the gap is widest and greenwashing risk is highest:<br></p><ul><li><p><strong>Cost barriers: </strong>Switching to sustainable packaging costs 25-50% more than conventional materials. Smaller brands absorbing input cost pressures are unlikely to invest beyond the minimum required.</p></li><li><p><strong>Multi-layered plastics: </strong>The sachets and pouches that dominate mass-market FMCG remain largely unrecyclable in India. Recycling infrastructure for these materials does not exist at scale.</p></li></ul><p><strong>EPR certificate fraud: </strong>Fake EPR certificates have been flagged in large numbers. The portal-based system allows companies to purchase recycling credits without verifying that actual recycling has taken place.</p>.<h3><strong>The Open Question</strong></h3><p>India’s largest FMCG companies are making genuine progress on their own operations and packaging. But the real sustainability footprint of this sector lives in the supply chain - in the thousands of contract manufacturers, small suppliers and informal waste collectors that the headline numbers rarely capture. As BRSR assurance expands and Scope 3 reporting matures, will Indian FMCG companies be willing to shine a light on their full value chain, or will sustainability continue to be a story told only about the parts they control?</p>.<h2><strong>Data Point of the Month</strong></h2>.<h2><strong>DID YOU KNOW?</strong></h2><p><strong>EPR compliance does not mean your packaging is being recycled.</strong></p><p>Under India’s Extended Producer Responsibility framework, brands meet their plastic waste obligations by purchasing credits on the CPCB portal, not by ensuring their packaging is physically collected and processed. A company can be fully compliant on paper while none of its plastic ever reaches a recycler. The CPCB has flagged thousands of fake EPR certificates in the system and the portal still runs largely on self-declaration with limited traceability.</p><p><em>As BRSR assurance expands, auditors will increasingly scrutinise EPR claims. ‘EPR compliant’ is not the same as ‘our plastic is being recycled’ and that distinction is about to matter a great deal more.</em></p>.<h2><strong>Actionable Tools</strong></h2>
