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Pan masala is provided with a special packaging entry by the Food Safety and Standards Authority of India. Food Safety and Standards (Packaging) Amendment Regulations, 2026, include pan masala in Schedule IV of the Food Safety and Standards (Packaging) Regulations, 2018.
The new entry says that paper, paperboard, cellulose, and other naturally derived materials used for pan masala must be free of plastic. They must also be free from aluminium foil and metalized layers. Tin and glass containers are included as other packaging choices.
The notification does not state a separate grace period. Pan masala manufacturers, packers, brand owners, importers, and packaging suppliers should therefore examine every layer and component of their packaging.
Although these rules are brief, their impact on businesses could be more than expected. The bag might appear to be made of paper but actually be made of plastic, aluminium, or metallised films. Businesses require facts about materials, not assumptions based on appearance.
| Particular | Verified detail |
| Issuing authority | Food Safety and Standards Authority of India |
| Governing law | Food Safety and Standards Act, 2006 |
| Regulations amended | Food Safety and Standards (Packaging) Regulations, 2018 |
| Schedule amended | Food Safety and Standards (Packaging) Regulations, 2018 |
| Product covered | Pan masala |
| Main stakeholders | Manufacturers, packers, brand owners, importers and packaging suppliers |
| Main development | Addition of plastic-free, foil-free packaging choices for pan masala |
| Transition period | Not expressly specified |
| Separate compliance deadline | Not expressly specified; the amendment states that it starts on publication |
Food Safety and Standards Act, 2006
The Food Safety and Standards Act, 2006, is Indiaâs main central law for food safety. It created the FSSAI and gave it the authority to make food regulations. The Act covers many matters, including how food is made, stored, distributed, sold, and packaged.
The 2026 notification refers to section 92 of the Act. Section 92 provides the regulation-making process. The final notification states that FSSAI used the power under section 92(2)(k), with the previous approval of the Central Government, to amend the Packaging Regulations.
In simple words, FSSAI did not issue this as an informal suggestion or a news release. It issued amendment regulations in the Official Gazette under the powers conferred by the Act.
Food Safety and Standards (Packaging) Regulations, 2018
The Packaging Regulations establish general standards for packaging materials used to package food products. According to these regulations, primary packaging materials are materials that come into direct contact with the food product. Secondary packaging comes around the primary pack but does not come into direct contact with the food product.
The regulations require food-contact packaging to be food-grade. Packaging must suit the food, storage conditions, filling and sealing equipment, transport conditions, and normal mechanical, chemical, or heat stress. Food must also be packed in a clean, hygienic, and tamper-proof package.
Another important rule concerns evidence. The official FSSAI compendium states that a food business operator must obtain a certificate of conformity from a National Accreditation Board for Testing and Calibration Laboratories (NABL)- accredited laboratory for packaging that directly touches food or is likely to touch it.
Schedule IV gives a product-wise list of suggestive packaging materials. The base regulations describe this as an indicative list and generally do not preclude the use of other materials that meet the specified standards. The new pan masala entry, however, uses direct words such as âshall be free from any plastic.â This means businesses should not read the word âsuggestiveâ as permission to ignore the express plastic-free and foil-free conditions. Where there is uncertainty, a written legal or regulatory view is safer than a broad assumption.
Connection with the Plastic Waste Management Rules, 2016
The amendment does not work alone. It expressly says that clauses (f) and (i) of Rule 4(1) of the Plastic Waste Management Rules, 2016, also apply.
Rule 4(1)(f) says that sachets made of plastic material must not be used for storing, packing, or selling gutkha, tobacco, and pan masala. Rule 4(1)(i) is wider. It states that plastic material in any form, including Vinyl Acetate-Maleic Acid-Vinyl Chloride Copolymer, must not be used in any package for gutkha, pan masala, or tobacco.
This is a vital point. The environmental rules already contained a plastic restriction. The FSSAI amendment now includes a clear entry for pan masala material in the food-packaging schedule and expressly links it to those environmental rules.
The Plastic Waste Management Rules also state that Rule 4 export exemption does not apply to units packaging gutkha, tobacco, and pan masala. Businesses should therefore avoid assuming that an export order automatically removes the packaging restriction.
The change in Schedule IV is directly caused by the introduction of Serial Number 11 for pan masala. This includes three interrelated aspects: approved material categories, excluded material categories, and the link to the Plastic Waste Management Rules.
Addition of Pan Masala to Schedule IV
Before this amendment, the 2025 version of the FSSAI Packaging Regulations listed ten product categories in Schedule IV. Pan masala did not have its own entry in that version. The amendment inserts pan masala after Serial Number 10.
This makes the expected packaging direction easier to find within the FSSAI food-packaging framework. A manufacturer no longer needs to look only at a general environmental ban to understand the basic material position.
Permitted Packaging Materials
The new entry names the following material categories:
Paper, paperboard, cellulose, and other naturally derived materials are not approved without conditions. The notification says these materials must be free of any plastic. It also says they must not contain aluminium foil or metallised layers.
A paper pouch with a hidden polyethylene coating may fail the stated condition. The same concern can arise when a paper pack contains a polyester layer, a synthetic laminate, or a metallised film. The outside appearance of a package is therefore not enough to prove compliance.
Tin and glass are named as container choices. These containers must still meet the general FSSAI rules on food-grade quality, cleanliness, suitability, sealing, and safe food contact. For example, choosing a glass jar does not eliminate the need to assess its closure, seal, and any component that may come into contact with the product.
Prohibited Packaging Materials and Components
The notification says the naturally derived material must be free from any plastic, including but not limited to:
The words âincluding but not limited toâ matter. The list provides examples, but it is not exhaustive. A business cannot treat an unlisted plastic as allowed simply because its chemical name does not appear in the notification.
The phrase âany plasticâ also makes it risky to assume that bio-based, biodegradable, or compostable plastic is acceptable. Such material may still legally be a plastic. The amendment does not create a clear exception for it.
The entry speaks about material used for pan masala packaging and also refers to plastic material âin any formâ through Rule 4(1)(i). A safe compliance review should therefore examine the whole pack, including:
The notification does not explain every small component separately. It also does not clearly state how its new Schedule IV wording applies to secondary transport material that never forms part of the consumer pack. Those questions should be assessed against the exact pack design, the general Packaging Regulations, and the Plastic Waste Management Rules.
Earlier Position vs New Position
| Earlier verified position | New position from 10 August 2026 |
| Plastic was already barred for pan masala packaging under the Plastic Waste Management Rules. Schedule IV had no separate row for pan masala. | Serial Number 11 now names natural material, tin, and glass options and expressly excludes plastic, aluminum foil, and metalized layers from the natural-material format. |
The amendment therefore makes the material direction clearer within the FSSAI framework. It does not mean that plastic was freely allowed before 10 August 2026.
Products and Businesses Covered
The new entry expressly covers pan masala. It does not create a new product definition. Businesses should check the product standard, ingredients, label, and FSSAI license before deciding whether a similar product is covered. Supari or mouth freshener should not be included only because it is sold in a small pouch; equally, changing a product name does not change its true legal classification.
These are the parties who are directly involved: manufacturers, contract packers, brand owners, importers, and packaging suppliers. Distributors and retailers may also require stock information. Imported pan masala intended for India must comply with India's packaging regulations.
The Plastic Waste Management Rules are also important for exporters. Their general Rule 4 export exemption does not extend to units packaging gutkha, tobacco, and pan masala.
Notification, Publication and Effective Dates
The draft notification was released on 28 April 2026. The notification date is 7 August, whereas the gazette date is 10 August 2026. Since the amendment will commence from the date of publication, 10 August 2026 will serve as the date of operation. No other implementation date is stated in the notification.
Is a Transition or Grace Period Available?
There is no explicit mention of any transition, grace period, or phased implementation. Redesign of the package may be difficult, but business difficulty, per se, does not constitute a legal extension.
Existing Packaging and Finished Goods
There is no information in the notification on how much older packaging, produced before 10 August, can be used. The notification does not provide a definite rule for the sell-through of existing packaged goods. Businesses should segregate unused packaging materials, WIP, factory and market stock, and take a document-specific approach.
Closing the Gap Between Paper Appearance and Actual Composition
The Plastic Waste Management Rules have already banned plastic packaging for pan masala. In practice, a pack described as âpaper-basedâ can still be a mixed structure. It may contain a plastic barrier, a heat-seal coating, a synthetic adhesive, aluminium foil, or a metallised layer.
A 2026 Bureau of Indian Standards innovation challenge explained that manufacturers had shifted to multilayer paper-based laminates, but these small mixed-material sachets remained hard to collect, separate, and recycle. It also identified the continued use of plastic-based adhesives and heat-seal coatings as a concern.
The FSSAI amendment gives businesses a clearer material direction: natural material must actually be free from plastic, foil, and metalized layers.
Waste and Litter Concerns
Small sachets are light and easily scattered. Their size makes collection difficult. When several materials are bonded together, separation and recycling become harder. Such packs can escape normal waste systems and become litter in streets, drains, fields, and water bodies.
The final notification does not include a detailed statement of reasons. The waste explanation should therefore be understood as part of the verified policy context, not as extra wording inserted into the legal clause.
Promotion of Workable Alternatives
The amendment does not merely list banned materials. It also names paper, paperboard, cellulose, other naturally derived materials, tin, and glass. This gives manufacturers a starting group of alternatives.
The hard part is performance. Pan masala packaging often needs moisture protection, aroma retention, seal strength, and enough shelf life for distribution. A truly useful alternative must align with environmental goals while keeping food safe and stable.
Impact on Pan Masala Manufacturers
Manufacturers need the exact construction of every pack. âPaper pouchâ is too broad. Quality and procurement teams need layer-wise data, while production teams must check whether the material fills and seals safely on existing equipment.
Impact on MSMEs
MSMEs may face a heavier short-term adjustment because they buy smaller quantities and may have fewer packaging experts. They should not accept an âeco-friendlyâ claim without a composition statement and suitable evidence.
Impact on Packaging Suppliers
Suppliers now have a reason to develop plastic-free, foil-free barriers that still control moisture and aroma. Clear layer information and reliable evidence will matter more than labels such as âgreen laminate.â
Cost and Supply-Chain Impact
The cost may be due to factors such as research, testing, changes in machinery or suppliers, and even stock loss. The use of tin and glass packing materials might also contribute to weight, storage, and damage costs. There will be no cost associated with the notification. The cost may depend on the type of material used, pack size, quantity, machine, and shelf life.
Step 1: Confirm Product Classification
Check the ingredients, food standards, FSSAI license, and label to determine whether the product is classified as pan masala.
Step 2: Complete Package Analysis
Prepare a bill of materials identifying all substrates, coatings, adhesives, seals, caps, labels, etc. Do not limit yourself to the substrate only.
Step 3: Identify Prohibited Material
Check for the presence of polyethylene, polypropylene, polyester, PVC, other polymers, copolymers, plastic laminates, aluminum foils, metallizations, etc. Maintain the status of "unknown" for each material until identification.
Step 4: Selection of Alternative Material
Narrow down your selection to paper, paperboard, cellulose, natural material, tin, glass, etc. Check the moisture resistance, aroma, strength, sealing, storage, and transport conditions. The cheapest material would be useless if it affects the product quality.
Step 5: Confirming the Supplier
A signed composition declaration and technical data sheets for plastic, foil, and metallization must be requested. All papers must be confirmed against the specific grade. Inform us of any alteration in the material.
Step 6: Testing and Validation
Obey FSSAI guidelines for testing and get a certificate of compliance for the packaging material that comes into direct contact. Testing can be carried out for migration, smell, seal strength, leakage, moisture, aroma, transport, and shelf life. Distinguish between mandatory testing and testing associated with product development.
Step 7: Run Machine Trials
Conduct machine trials with the material at normal speed and note any tearing, poor feeding, low seal strength, and rejection rate. Train the operator regarding the parameters.
Step 8: Control Inventory
Reject unknown material, separate the old and new materials, and associate approved packaging codes with the specific product and line.
Step 9: Update Internal Controls
Update purchase specifications, the approved supplier list, incoming inspection, change management, and allocate responsibilities to the regulatory, purchasing, quality, engineering, and warehouse departments.
There is no specific requirement for any documents on pan masala under the notification. In line with the Packaging Regulations, it is necessary to provide a conformity certificate for the food contact package. The required internal documents will be:
Mandatory and recommended controls need to be segregated. It needs to be identified as per the actual commercial grade. The generic brochure is poor evidence because it doesn't show the actual structure purchased.
The biggest technical challenge will be replacing the plastic or foil without exposing the contents to moisture, while maintaining its smell and ensuring a good seal.
Metal and glass packaging can be highly protective, yet more expensive and heavy. Glass packaging can be breakable. Metal containers will require special closure and analysis when handling corrosive products.
Paper and cellulose packaging can be lightweight; however, it might be hard to design a plastic-free barrier and heat-sealing system. The lack of additional time before changes raises certain expectations, especially for MSMEs and companies with stockpiles.
The right response is not to lower food safety. It is to redesign the package with legal, technical, and production teams working together.
The amendment has a valid environmental purpose, but it also creates practical and financial challenges. The following table presents a balanced assessment.
| Assessment area | Why the decision makes sense | Additional burden on businesses | Balanced view |
| Environmental protection | Plastic-free packaging can reduce difficult-to-collect and difficult-to-recycle waste. | Alternative materials may still require technical development and proper disposal systems. | The environmental goal is reasonable, but the alternative must work throughout its full life cycle. |
| Clearer packaging rules | The amendment makes it clear that paper packaging cannot contain hidden plastic, aluminium foil or metallised layers. | Businesses must examine every coating, adhesive, barrier, seal, and closure. | Clear rules reduce confusion, but FSSAI guidance on smaller packaging components would help. |
| Packaging innovation | The rule can encourage the development of paper, cellulose, tin, glass, and other suitable alternatives. | New materials may not yet be widely available or affordable. | Innovation may create long-term value, but businesses need scalable and cost-effective solutions. |
| Food safety and quality | Businesses are encouraged to select packaging that is both compliant and food-grade. | Plastic-free materials may face problems with moisture, aroma retention, sealing, and shelf life. | Environmental compliance should not weaken food safety or product quality. Proper testing remains essential. |
| Cost of compliance | Better packaging controls can improve supplier management and material traceability. | Manufacturers may face costs for testing, machinery, supplier development, and packaging conversion. | Larger businesses may adjust faster, while MSMEs may need technical and financial support. |
| Implementation period | Immediate application can accelerate the move toward compliant packaging. | The notification does not expressly provide a grace period or phased implementation plan. | A reasonable transition period could have reduced disruption without weakening the regulatory objective. |
| Existing stock | Immediate application discourages continued use of potentially non-compliant packaging. | The notification does not clearly explain how unused packaging and already-packed goods should be treated. | Written clarification on old stock and sell-through conditions would improve consistency. |
| Overall business impact | Early compliance may improve reputation and create a market for sustainable packaging. | Short-term costs, material shortages, and production changes may affect business continuity. | The decision is justified in purpose, but its success depends on clear guidance, affordable alternatives, and practical support. |
Balanced Conclusion
This amendment is not just an advantage or disadvantage. The environmental goals of this amendment are justified because it tackles hidden plastics and packaging waste that are difficult to manage. However, manufacturers will pay more due to costs, technology issues, and uncertainty about current stock.
We should get additional clarity from FSSAI on packaging components, evidence, old stock, and implementation. MSMEs might require assistance with testing and materials.
The modification can drive demand in the entire packaging industry.
Paper and Cellulose Materials without Plastic
Companies can manufacture paper and cellulose materials that regulate moisture and odour without using any plastic. Testable claims have to be made.
Packaging Using Tin and Glass Containers
Firms can produce small, light, and safer tin and glass containers. Designing closures will still be critical.
Testing and Technical Assistance
Laboratories can experience increased demand for food contact, material, barrier, seal, and shelf-life testing when using proper techniques.
Machinery and Retrofitting
Equipment manufacturers can provide sealing and filling equipment or adapt machines to handle natural materials.
Compliance and Supplier Services
Packaging audit, supplier assessment, legal validation, and change management services will also be needed. The biggest business opportunities are those that meet three requirements: legal compliance, food safety, and feasibility of mass production.
There is no specific penalty prescribed for pan masala under the 2026 notification. Businesses should not quote any penalty amount as a general rule, since violations must be assessed under the FSSA and environmental laws, taking into account the specific circumstances of each case.
These include questions that may arise during inspections and product testing, the inability to shift stock, decisions on product withdrawal, conflicts with suppliers, production halts, and damage to brand reputation. There may be other risks associated with environmental deception.
Inadequate information is the biggest risk to controls. If the supplier designates a packaging structure as âpaperâ and does not inform you of its plastic coating, the end package will not meet the new requirement. Documentation and change controls are thus fundamental controls.
Examples of controls that can be implemented include the bill of materials, machine trial report, and internal checklists, unless another requirement or license condition necessitates their use. The requirement for a certificate of compliance arises from the general FSSAI Packaging Regulations for food contact packaging.
Corpseed helps pan masala manufacturers, importers, brand owners, and packaging companies understand and follow the new FSSAI packaging requirements. The support is based on the actual product, the materials used in its packaging, and the compliance gaps that need to be addressed.
1. Checking Whether the New Rules Apply
2. Reviewing the Complete Packaging Structure
3. Finding Compliance Gaps
4. Checking Supplier Documents
5. Supporting Packaging Testing
6. Improving FSSAI Records and Internal Controls
7. Providing Ongoing Regulatory Support
Professional support cannot replace correct supplier information or guarantee a regulatory outcome. However, it can help businesses understand their obligations, identify packaging risks, and maintain reliable evidence before starting commercial production.
Pan masala manufacturers, importers, and brand owners may use Corpseedâs FSSAI compliance services for a document-based review of their packaging and implementation plan.
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