Air pillows and bubble wrap with recycled content: what the April 2027 EPR step-up means

On 1 April 2027, the recycled plastic requirement for flexible plastic packaging in India doubles, from 10% to 20%.

Air pillows and bubble wrap are flexible plastic packaging. So if you are a brand owner covered by plastic EPR, they are inside that 20%. The good news is that the target applies to your total use for the year, not to every pack. You can decide where the recycled plastic goes.

Checked against official sources on 28 October 2026.

This article is about protective film: air pillows, bubble wrap, and the bubble lining in padded mailers. We make air cushion systems and their film at our plant in Jaipur, so this question reaches our own production floor too.

If you are not sure whether EPR applies to you at all, start with the section on who owes the target.

What changes on 1 April 2027?

The Plastic Waste Management (Amendment) Rules, 2026 were notified on 31 March 2026 as G.S.R. 237(E). The Maharashtra Pollution Control Board hosts a copy of the gazette. They rewrote the recycled-content tables. The same table applies to producers, importers and brand owners:

For Category III, the percentage applies only to the weight of the plastic layers.

Do air pillows and bubble wrap count?

Yes. The rules define plastic packaging as material made of plastic for protecting, preserving, storing and transporting products. Protection and transport are exactly what cushioning does.

The category follows the build of the film:

1. Bubble wrap and air pillows made only of polyethylene are Category II.
2. Air cushion film with a nylon layer for air retention is still Category II. The definition covers multilayer film made of different types of plastic.
3. A paper mailer lined with bubble film is Category III, because it combines plastic with paper. Only the bubble lining counts towards the 10%.

Who has to meet the 20%?

Under Schedule II of the rules, the obligated entities include:

1. Brand owners, including online marketplaces and retail chains, other than micro and small enterprises.
2. Producers of plastic packaging, other than micro and small enterprises.
3. All importers of plastic packaging, including importers of packaged products.

There is a catch here. Micro and small producers are exempt from the EPR target, because their resin supplier carries it. But the rules say the recycled-content target "shall be fulfilled by such producers". So even a small firm that makes bubble wrap or air cushion film still owes the recycled share on what it makes.

Importers have their own twist. The 2026 rules say recycled plastic used in imported material does not count. An importer meets the target by buying certificates from others who used more recycled plastic than they had to.

"Small" now means investment up to ₹25 crore and turnover up to ₹100 crore, under the MSME limits in force since 1 April 2025. Many D2C brands fall back inside that line. Check your own Udyam classification, and do not assume.

Is it per pack, or for the year?

For the year, by category. The table is headed as a percentage of the plastic packaging used in the year. The worked example in the rules (Example 6 in the annexure) takes 100 tonnes of Category II packaging at a 10% target. The answer is simply that 10 tonnes of it must be recycled plastic.

Read that again with your own packaging list in mind.

Your Category II total probably includes poly mailers, courier bags, liners, stretch film, bubble wrap and air pillows. The law asks for 20% across all of it. It does not ask for 20% in each item.

So you can choose where the recycled plastic goes. My advice is to put it first where a defect costs least, and to keep air pillows for last.

The reason is simple physics. A gel is a small lump of plastic that did not melt and mix properly. In a thick film, a gel is mostly a cosmetic mark. In a thin film that has to hold air through a whole courier route, it is a weak spot. That is the part I would test hardest.

What changes in the film when you add recycled plastic?

Recycled polyethylene comes from mixed waste, so it varies more than virgin resin. Even the resin makers say so.

Borealis, one of the large polyolefin makers, sells a 100% post-consumer recycled LDPE grade for high-end blown film. Its product data sheet (Borcycle PE T1003, edition 1, February 2026) says three useful things:

1. Colour can vary between batches, because of the nature of recyclates.
2. The grade is "gel-reduced" and filtered at 60 microns. That tells you gels are the known enemy in recycled film.
3. A small amount of virgin LLDPE "significantly boosts" its mechanical performance. So expect a blend, not 100% recycled, in any film that has to be strong.

The same sheet lists it for non-food-contact film only.

For protective film, I would expect four changes, and I would check each one rather than take anyone's word:

1. Colour. A grey or yellow tint, and some difference from one lot to the next.
2. Specks and gels. Hold the film up to the light.
3. Smell, especially when film is warm from the sealing bar.
4. Strength and air holding. This is where air pillows can fail.

I will not give you a burst-strength figure for recycled air pillow film. It depends on the recyclate, the blend and the line it runs on. Any single number would mislead you.

How to trial recycled air pillows or bubble wrap

Run this before you switch, and run it again on a second lot:

1. Get two samples from the same supplier: your current film and the recycled blend, with the recycled percentage written on the delivery note.
2. Make 20 air pillows from each. Mark them. Put a flat board on each set with a 1 litre water bottle on top, and leave them for seven days. Count the flat pillows each morning.
3. Pull a few seals apart by hand. A good seal tears the film next to it. A weak one peels open along the seal line.
4. Run a full roll through your air cushion machine. Count the pillows that burst or do not seal, and note any smell.
5. For bubble wrap, count the bubbles in a 10 cm square, weigh a measured piece, and leave a loaded piece overnight. Our guide to bubble wrap grades explains each check.
6. Pack real orders in both films and drop them, as in our warehouse drop test.
7. Look at the open box the way your customer will. Decide whether a grey tint is acceptable for your brand before you buy a year of it.

If the recycled film passes on the first lot and fails on the second, you have learned the most important thing about that supplier.

What proof and labels do you need?

The 2026 amendment rewrote Rule 11(2). Every recycled plastic packaging item must conform to IS 14534:2023, "Plastics - Recovery and Recycling of Plastics Waste - Guidelines". It must also carry the label and mark shown in the rule, indicating its recycled content. Food-contact items must meet the FSSAI marking rules as well.

Rule 11(1) still asks for the name and registration number of the producer or brand owner, and the thickness, on plastic packaging. Since 1 July 2025 this information may be given through a QR code or barcode instead, after informing CPCB. That is an option, not a duty.

Your EPR annual return also asks for the recyclers who supplied your recycled plastic. So ask your film supplier for these, for every lot:

1. The recycled percentage on the invoice.
2. The name and CPCB registration of the recycler.
3. A statement that the film conforms to IS 14534:2023.
4. The thickness in microns.
5. Whether the film is cleared for food contact. Do not assume it is.

One honest note about our own paperwork. Jagannath Polymers holds a GRS certificate, but its scope covers only packing sacks and bags with 50 to 100% post-consumer recycled polyethylene. It does not cover air cushion film or bubble wrap. If a supplier waves a certificate at you, read the scope line.

What if you fall short?

A shortfall attracts environmental compensation under CPCB guidelines. The August 2024 guidelines set ₹5,000 a tonne for Category II, doubling for a second default and tripling for a third. They also say the rates are reviewed every six months, so check for a newer figure before you plan on it.

The three-year carry-forward in the 2026 rules applies only to food-contact packaging. Protective film for parcels does not get it.

What to do before 1 April 2027

1. Confirm whether you are an obligated brand owner, producer or importer. Start with your Udyam classification.
2. Add up your FY 2026-27 Category II use, item by item, in kilos.
3. Work out 20% of that total. That is your recycled plastic need for FY 2027-28.
4. Decide which items carry it. I would start with the thicker films and keep air pillows for last.
5. Trial recycled film from November to February, well away from your busy season.
6. Collect the supplier documents above for every lot, starting with the first.
7. Update the artwork on anything printed, so the Rule 11 details and the recycled-content mark are correct.

If you send us your monthly kilos of air pillow film, bubble wrap and mailers, we will help you work out where the 20% is easiest to place.