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The Punjab Pollution Control Board (PPCB) has cleared up an important question for plastic carry bag manufacturers in the state. The 120-micron thickness requirement applies not only to conventional plastic carry bags but also to biodegradable and compostable plastic carry bags.
This means that changing the raw material or marketing a carry bag as biodegradable or compostable does not, by itself, take the product outside the 120-micron requirement referred to in the PPCB clarification.
The issue is also closely linked with pollution-control consent. PPCB has instructed its Regional Offices not to grant, renew or extend Consent to Establish (CTE) or Consent to Operate (CTO) for units manufacturing plastic carry bags below the prescribed thickness. Existing consents for such activities are also covered by the direction.
For manufacturers, the practical question is no longer just what material the bag is made from. The product specification, its thickness and the activity mentioned in the CTE/CTO now need to be looked at together.
| Particular | Details |
| Issuing Authority | Punjab Pollution Control Board |
| Nature of Document | Clarification |
| Date | 25 August 2026 |
| Main Issue | Applicability of the 120-micron condition to biodegradable and compostable carry bags |
| Product Covered | Plastic carry bags |
| Thickness Referred To | 120 microns |
| Categories Covered | Virgin, recycled, biodegradable and compostable plastic carry bags |
| Consent Impact | CTE/CTO grant, renewal and extension |
| Existing Consent | Certain existing consents are directed to be revoked/cancelled |
| Other Products Covered | Prohibited identified Single-Use Plastic items |
| Enforcement | Surprise inspections, including at odd hours |
The clarification follows earlier PPCB instructions as well as the Punjab Department of Local Government notification dated 2 April 2025.
The main point is simple.
A plastic carry bag does not get a different thickness treatment merely because it is made from biodegradable or compostable plastic.
PMIDC, after examining the relevant rules, notifications and PPCB reports, clarified that the notification dated 2 April 2025 applies to all categories of plastic carry bags. The 120-micron requirement is to be applied uniformly to:
This removes a major point of doubt for manufacturers that were treating compostable or biodegradable carry bags differently from ordinary plastic carry bags.
For businesses, the safest reading of the PPCB letter is that material type and thickness are separate questions. A product may be biodegradable or compostable, but that characteristic alone does not remove the thickness condition addressed in the clarification.
Yes. According to the clarification communicated by PPCB, both biodegradable and compostable plastic carry bags fall within the same 120-micron requirement.
PPCB’s letter specifically says the rule applies regardless of whether the carry bag is made from virgin, recycled, biodegradable or compostable plastic.
The present letter did not arise in isolation. PPCB had already issued directions on plastic carry bag manufacturing before the August 2026 clarification.
PPCB Direction of 6 November 2024
Regional Offices were earlier directed not to grant or extend the validity of Consent to Operate for manufacturing compostable, biodegradable and non-biodegradable plastic carry bags.
The earlier communication also dealt with consents that had already been granted or renewed, including through auto-renewal.
Further Direction of 9 December 2024
PPCB then issued another instruction after concerns were raised regarding illegal manufacturing and use of compostable and biodegradable plastic carry bags.
Regional Offices were asked to:
Representation from the Punjab Compostable Association
The Punjab Compostable Association, Amritsar later approached the Board seeking permission to manufacture and sell compostable carry bags in Punjab in accordance with the Plastic Waste Management Rules, 2016.
This led PPCB to seek clarification from the Punjab Municipal Infrastructure Development Company (PMIDC), Department of Local Government, Punjab.
PMIDC’s response answered the central issue: biodegradable and compostable plastic carry bags are also covered by the 120-micron requirement.
| Date | What Happened | Why It Matters |
| 06.11.2024 | PPCB issued earlier consent-related directions | Regional Offices were told not to grant or extend certain consents |
| 09.12.2024 | PPCB issued inspection and enforcement directions | Surprise inspections and checks on prohibited manufacturing were strengthened |
| 02.04.2025 | Department of Local Government issued notification | Plastic carry bags below 120 microns were addressed |
| 06.06.2025 | PPCB circulated the notification | Regional Offices were informed of the position |
| 12.08.2026 | PMIDC issued clarification | Biodegradable and compostable carry bags were clearly brought within the same thickness interpretation |
| 25.08.2026 | PPCB circulated the clarification | Regional Offices were directed to implement the clarified position |
These dates are expressly referred to in the PPCB communication.
The position can be understood quickly from the table below.
| Carry Bag Category | 120-Micron Requirement | CTE/CTO Position Below 120 Micr |
| Virgin plastic | Applicable | Consent not to be granted, renewed or extended |
| Recycled plastic | Applicable | Same treatment |
| Biodegradable plastic | Applicable | Same treatment |
| Compostable plastic | Applicable | Same treatment |
For manufacturers, this means the product cannot be assessed only by its environmental claim or raw-material category. The thickness of the finished carry bag remains a central compliance point under the clarification.
The PPCB letter records that the Department of Local Government notification dated 2 April 2025 prohibited manufacture, stocking, distribution, recycling, sale or use of plastic carry bags below 120 microns within the jurisdiction of Municipal Corporations, Municipal Councils and Nagar Panchayats in Punjab.
The letter, however, separately refers to certain areas.
Areas Mentioned Separately
These are:
The PPCB communication mentions these places in connection with the National Green Tribunal order dated 20 January 2016 and subsequent orders in O.A. No. 442 of 2015.
A business located in one of these areas should therefore avoid relying on a general statewide reading alone. The local position should be checked along with the relevant NGT orders and instructions applicable to that jurisdiction.
The biggest business impact of the clarification is on pollution-control consent.
What is CTE?
Consent to Establish (CTE) is the pollution-control consent generally connected with setting up or establishing an industrial activity.
What is CTO?
Consent to Operate (CTO) relates to operating the industrial unit after the applicable consent conditions have been met.
For plastic carry bag manufacturers, the current PPCB direction is specific.
No CTE/CTO under the Water Act, 1974 and the Air Act, 1981 is to be granted, renewed or extended for a unit manufacturing plastic carry bags below 120 microns, whether the bags are made from:
What This Means for a New Unit
A business proposing to start plastic carry bag manufacturing should make sure that the product described in its consent application matches the PPCB requirement.
The proposed thickness, type of product, and manufacturing activity should be clearly stated.
What This Means at Renewal Stage
A manufacturer applying for renewal cannot assume that an earlier consent will automatically continue on the same basis.
If the activity covered by the consent involves carry bags below the permitted thickness, the present PPCB direction becomes directly relevant.
Why Consent Review Matters
A PPCB consent consultant in Punjab can be useful where a manufacturer needs to check whether the proposed or existing activity matches the conditions that PPCB is currently applying.
Similarly, businesses planning a new unit may seek assistance from a CTE CTO consultant in Punjab before filing so that the product description, plant activity, and consent documents are consistent from the beginning.
The clarification also allows PPCB to seek an undertaking while considering CTE or CTO applications.
The applicant may be asked to confirm that the carry bags proposed to be manufactured will have a thickness of more than 120 microns.
This wording needs to be read carefully.
The PPCB letter does not say that every applicant must submit the undertaking automatically. It says the applicant may be asked to provide it.
1. What is declared in the undertaking
The statement made to PPCB should correctly describe the product that the unit intends to manufacture.
2. What is actually produced
Once production starts, the product manufactured at the unit should remain consistent with what has been declared to the authority.
There is also a drafting distinction in the letter. One part refers to carry bags less than 120 microns, while the undertaking language refers to the manufacture of bags more than 120 microns. Businesses should follow the exact requirement communicated by the concerned Regional Office rather than making assumptions about this wording.
The clarification is equally important for units that already hold pollution-control consent.
PPCB has directed that CTE/CTO already granted or renewed including consent obtained through the auto-renewal process be revoked or cancelled where the unit manufactures:
This means an older consent cannot simply be treated as protection against the clarified position.
Existing Manufacturers Should Review
Where a mismatch exists, businesses should assess it before it becomes an issue during inspection or renewal.
The letter is not limited to carry bags.
PPCB has also directed that CTE/CTO should not be granted for manufacturing prohibited identified Single-Use Plastic items.
The letter gives examples such as:
These examples should not be treated as the complete list of prohibited SUP products.
A manufacturer dealing with another single-use plastic item should separately check whether that specific product falls within an applicable prohibition.
Manufacturers should also pay attention to what PPCB has said about inspections.
Surprise Inspections Will Continue
Regional Offices have been instructed to continue surprise inspections.
The purpose is to check whether manufacturing activity on the ground matches the legal and consent position.
Inspections May Take Place at Odd Hours
The earlier PPCB instruction specifically referred to inspections at odd hours, and the latest letter says Regional Offices should continue surprise inspections to verify compliance and detect illegal manufacturing.
This makes day-to-day compliance more important than preparing records only when an inspection is expected.
Monthly Reporting by Regional Offices
The letter also asks Regional Offices to submit an action-taken report to Head Office every month through the MPR.
The clarification does not prescribe a fixed inspection schedule for each industrial unit.
Compostable carry bag manufacturers are one of the main groups affected by this clarification.
Earlier uncertainty centred on whether a compostable carry bag could be treated differently because of its material or environmental characteristics.
The answer given through PMIDC is clear for the 120-micron requirement: compostable carry bags remain covered.
Manufacturers Should Review
The clarification does not say that all compostable products have been prohibited. Its focus is the application of the 120-micron carry bag requirement and related consent controls.
Biodegradable plastic carry bags are also expressly included in the same thickness interpretation.
For these manufacturers, biodegradable status does not create a separate lower thickness requirement.
The areas that deserve attention are:
Check whether the manufactured bag meets the applicable thickness condition.
The product mentioned in the CTE/CTO should match what is being manufactured at the unit.
A pending renewal should be reviewed in light of the current PPCB direction.
Manufacturers should be able to show that actual production is consistent with consent details and declarations made to the Board.
The effect of the clarification goes beyond paperwork.
| Business Area | Practical Impact |
| Product specification | Thickness may need to be checked or revised |
| Production | Manufacturing below the permitted thickness creates direct consent risk |
| CTE application | Proposed activity must match PPCB's clarified position |
| CTO application | Operating activity and product specification need to align |
| Renewal | Existing activity may be examined against the 120-micron condition |
| Auto-renewed consent | Not protected from the revocation/cancellation direction |
| Quality control | Regular thickness checks become commercially sensible |
| Inspection | Surprise inspections may verify actual plant activity |
| Product portfolio | Prohibited SUP products need separate checking |
For smaller manufacturers, even a seemingly minor mismatch between the product description and actual production can create avoidable regulatory trouble. That makes periodic internal review more useful than waiting until the next consent renewal.
Businesses do not need to turn this into a complicated exercise. A focused review of the unit and its existing approvals is more useful.
1. Check Every Carry Bag Being Manufactured
Prepare a clear list of:
2. Verify Actual Thickness
Do not rely only on the design specification. The manufactured product should be checked against the requirements being applied by PPCB.
3. Compare Production with the CTE/CTO
Look at the existing consent and confirm:
4. Review Auto-Renewed Consent
Where the existing CTE/CTO was renewed automatically, check whether any affected product is still covered.
5. Check for Prohibited SUP Products
A unit manufacturing more than one plastic product should separately review whether any item falls within an identified SUP prohibition.
6. Keep Undertakings Consistent with Production
Where PPCB has asked for an undertaking, the declaration should match the activity actually carried out at the plant.
7. Keep Inspection Records Ready
A manufacturer may consider maintaining accessible copies of:
These are sensible internal controls; the clarification itself does not prescribe this exact record list.
Certain assumptions can now create difficulty.
Assuming Compostable Means Exempt
The current clarification does not support that view.
Treating Biodegradable Bags Separately
Biodegradable carry bags are also included in the 120-micron interpretation.
Relying on an Old CTE/CTO
An existing consent does not override the present PPCB direction where the unit manufactures affected products.
Relying on Auto-Renewal Alone
The letter expressly refers to consents renewed through auto-renewal when dealing with revocation or cancellation.
Manufacturing a Prohibited SUP Product
PPCB has separately reiterated that consent should not be granted for identified prohibited SUP manufacturing.
Ignoring Actual Plant Activity
A consent document and actual production should not tell two different stories.
The letter does not prescribe a specific monetary fine in this clarification. Any discussion of penalties should therefore be based on the applicable governing law rather than guessed from this communication.
From the regulator's side, the clarification gives Regional Offices one clear interpretation. They do not have to decide differently merely because a carry bag is labelled biodegradable or compostable.
For manufacturers, however, the impact depends on what they are already producing.
| Regulatory Side | Business Side |
| One thickness interpretation for different materials | Some products may need modification |
| Less ambiguity for consent decisions | Existing consent may need closer review. |
| Clearer treatment of biodegradable and compostable bags | Manufacturers cannot rely only on material claims. |
| Easier field-level verification | Internal quality checks may need improvement. |
| Stronger control over prohibited manufacturing | MSMEs may face adjustment costs |
For businesses already producing compliant products under matching consent conditions, the clarification mainly provides certainty.
The bigger challenge is for units where the product specification, existing consent or manufacturing practice does not match the position now being applied by PPCB.
A plastic manufacturing unit usually has more than one compliance issue to check. The product, pollution-control consent and plastic-waste requirements need to match the actual activity carried out at the plant.
Corpseed can support manufacturers looking for a PPCB consent consultant in Punjab with consent review, applications and ongoing environmental compliance work.
PPCB Applicability Review
Corpseed can examine the nature of the manufacturing activity and help identify the PPCB requirements that are relevant to the unit.
This can cover:
CTE and CTO Application Assistance
As a CTE CTO consultant in Punjab, Corpseed can support businesses with:
The purpose is to make sure the application reflects the activity the business actually proposes to carry out.
Existing Consent Review
An existing consent should be checked when the plant's products or manufacturing activity have changed over time.
Corpseed can help compare:
This can help identify issues before renewal or inspection.
Plastic Waste Compliance Review
As a plastic waste compliance consultant, Corpseed can assist manufacturers in reviewing the regulatory position of their products and understanding how plastic-waste restrictions affect their business activity.
Pollution Control Compliance Gap Assessment
A compliance gap review can identify differences between:
This can be particularly useful for units operating under older consents.
Documentation and Undertaking Support
Where PPCB asks for declarations or an undertaking during consent processing, Corpseed can assist with document preparation and review.
The wording should be based on the actual activity of the unit rather than a generic template.
PPCB Inspection Readiness
Corpseed's environmental compliance services can also support manufacturers in organising relevant consent and compliance records ahead of a PPCB inspection.
The focus should be on having records that match the actual plant operation.
Ongoing Environmental Consent Support
Businesses may also require assistance after the initial approval.
A pollution control consent consultant can support:
Corpseed does not guarantee the grant or renewal of CTE/CTO. The final regulatory decision remains with the competent authority.
For plastic carry bag manufacturers in Punjab, the August 2026 clarification settles one of the main questions around biodegradable and compostable bags. The material used in the bag does not, on its own, remove the 120-micron condition.
Manufacturers now need to look closely at what is actually being produced, what is stated in the existing CTE/CTO and whether the two match the position being followed by PPCB. Older and auto-renewed consents also deserve attention where affected products are still being manufactured.
Businesses that need help with consent review, fresh applications or ongoing environmental compliance can work with a PPCB consent consultant in Punjab to assess the unit's present position before renewal, modification or inspection.
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