Pan Masala Packaging Rules in India: What Is Actually Law, and What Is Only Proposed

Plastic packaging for pan masala has been prohibited in India since 2016, not 2026. Rule 4(1)(i) of the Plastic Waste Management Rules, 2016 bans plastic in any form for pan masala packaging, and it is in force today. The FSSAI packaging amendment now filling trade headlines is a draft. It has not been notified, and it carries no compliance deadline.

Both of those statements are uncomfortable, and both are true at the same time. That is why the packaging commentary written about this category serves it so badly. One set of articles announces a ban that has existed, unenforced, for a decade. Another announces a new FSSAI ban that has not actually happened. A packaging manager reading either one comes away with a wrong picture of their own risk.

This page is the map. It separates what is law from what is proposed, cites each instrument by number, date and status, and states plainly where the position is genuinely unresolved.

What packaging is legally permitted for pan masala in India?

Read strictly, no plastic packaging is permitted for pan masala in India. Rule 4(1)(i) of the Plastic Waste Management Rules, 2016 prohibits “plastic material, in any form” in any package for pan masala. Rule 4(1)(f) separately prohibits plastic sachets for storing, packing or selling gutkha, tobacco and pan masala. Both provisions are in force.

The instrument is G.S.R. 320(E), dated 18 March 2016, made by the Ministry of Environment, Forest and Climate Change under the Environment (Protection) Act, 1986. It is not a draft, not a proposal, and not new. It has been binding law for over ten years.

The exemptions elsewhere in Rule 4 do not extend to this. Those exemptions carve out export and SEZ manufacture from other plastic prohibitions, but the rule expressly withholds them from gutkha, tobacco and pan masala.

What is permitted, therefore, is anything that is not plastic: paper, paperboard, cellulose-based structures, tin, glass. That is the legal position on the page.

The commercial position is entirely different, and pretending otherwise helps nobody. Pan masala ships nationwide today in metallised plastic laminate sachets. The prohibition is comprehensively unenforced. Any supplier who tells you the category has already moved is selling you something.

Has FSSAI banned plastic sachets for pan masala?

No. FSSAI has proposed an amendment. It has not notified one. The instrument is the Draft Food Safety and Standards (Packaging) Amendment Regulations, 2026, F. No. RCD-09002/1/2026-Regulatory-FSSAI, dated 28 April 2026, published in the Gazette Part III Section 4 under section 92(2) read with section 23 of the Food Safety and Standards Act, 2006. Consultation closed around the end of May 2026. As at the date of this review it remains a draft.

The headline “FSSAI bans plastic sachets for pan masala” is a media overstatement, and it has been repeated widely enough that it now functions as received wisdom in the category. It is worth being precise about why it is wrong, because the correction is the single most useful thing on this page.

Three things have to be true for a ban to exist. The instrument must be notified. It must be in force. It must prohibit something. The FSSAI draft currently satisfies none of the three.

There is no effective date because there is no notification. Anyone quoting you a switchover deadline for pan masala packaging is quoting something that does not exist.

What does the draft Schedule IV entry actually say?

The draft inserts pan masala at Sl. No. 11 of Schedule IV to the Food Safety and Standards (Packaging) Regulations, 2018. The proposed entry describes packaging made of paper, paperboard, cellulose or other natural materials, completely free from plastic and synthetic polymers, and free from aluminium foil or metallized layers. Tin and glass containers are also named.

Two words in that entry matter more than the rest, and we will come back to them: metallized layers.

Note what the entry is, structurally. Schedule IV of the parent 2018 Regulations is titled “List of suggestive packaging materials”, and it carries a proviso stating that it is “an indicative list not restricting the use of any other packaging material complying with the specified standards.”

A suggestive list is not a prohibition. On its own face, adding an entry to an indicative schedule does not ban anything.

So why does the draft matter at all?

Because of which body would enforce it, not because of what it says. This is the part the coverage misses entirely, and it is the genuinely significant development.

The 2016 prohibition sits in environmental law, enforced by pollution control boards, which have not enforced it against this category in ten years. Moving the same prohibition into food law puts it in front of FSSAI and state food safety officers, who hold something the pollution boards do not: the FSSAI licence that every manufacturer needs in order to operate at all.

Licensing is leverage. That is the change worth planning around.

The honest summary is this. The statutory ban has existed since 2016 and has gone largely unenforced. FSSAI is now proposing to bring the same prohibition into food law, where licensing gives it real teeth. The direction of travel is unambiguous. The timing is not.

Which pan masala packaging rules are actually in force right now?

Five instruments genuinely bind the category today, and one does not. Keeping the sixth separate from the other five is the whole discipline of compliance planning here.

The 2024 amendment is worth dwelling on, because most published commentary on multi-layered packaging still quotes the superseded definition. G.S.R. 201(E) is a final notification, in force from publication. Its own preamble records the draft stage as G.S.R. 744(E) of 16 October 2023 and states that objections were duly considered. Rule 3 of that notification reads: “in clause (n), the words ‘metallised layers or’ shall be omitted.” Clause (n) is the multi-layered packaging definition.

That resolves a wording question that a great deal of secondary commentary still gets wrong. It does not resolve the EPR question that sits behind it, and we say so below rather than let a verified detail drift into a claim it does not support.

Machine registration is the other in-force obligation people forget. Form GST SRM-I (Notification 04/2024-Central Tax, 5 January 2024) requires pan masala manufacturers to register each packing machine with make, model, capacity and electricity consumption, with penalties up to ₹1 lakh and CCTV retention of 48 months. Changing a line has a tax paper trail, which is a real constraint on how quickly anyone can trial an alternative substrate.

Do these rules apply to mouth freshener, mukhwas and saunf?

Not on the face of the instruments. Rule 4(1)(f) and Rule 4(1)(i) name gutkha, tobacco and pan masala. A plain saunf, elaichi or mukhwas mouth freshener that is not pan masala is not named in either provision, and the draft Schedule IV entry is likewise specific to pan masala.

This is the most commercially important distinction in the category and it is almost never drawn.

Two categories that share a shelf, a format, a filling machine and often a customer sit in completely different regulatory positions. A mouth freshener sachet line faces no material prohibition at all. A pan masala line, on paper, faces an absolute one.

That said, product classification is a legal question, not a packaging question. Composition, marketing and labelling all bear on how a product is classified, and a mouth freshener sold alongside or formulated close to pan masala should not be assumed to sit outside the prohibition simply because of the name on the pack. Take that determination from your own counsel, not from a packaging supplier.

The practical consequence for buyers is that the two categories should be specified separately. The permitted material set is different, the EPR exposure is different, and treating a mouth freshener pouch as a pan masala pouch imports a constraint that may not apply to it.

What does EPR mean for a sachet or pouch producer?

Extended Producer Responsibility makes the brand owner, importer or producer financially responsible for collecting and processing the packaging they put on the market. Under the PWM Rules, multi-layered packaging falls in Category III, which carries its own recycled-content trajectory. That target runs from 5% to 10% by 2028-29 under G.S.R. 237(E) of 31 March 2026.

This matters more than the prohibition does, because it is the obligation that is actually enforced. Registration, annual returns and now Registered Environmental Auditors are live administrative requirements with real filing consequences.

There is an argument that a genuinely plastic-free paper structure sits outside Category III, since the multi-layered definition turns on “at least one layer of plastic as the main ingredient”. We are not making that argument here. The definition still hinges on that plastic-layer test, a sealant layer can pull an otherwise paper-based structure back inside the category, and the consolidated post-2024 text of the definition has not been verified against a clean source. It is a question for counsel, not for a blog post, and any supplier who answers it for you without qualification is overreaching.

Our detailed treatment of the same obligations in adjacent categories is set out for tea packaging EPR in India and for paper packaging converters. The registration mechanics are common across all of them.

What can paper-based packaging actually do on barrier today?

Less than metallised structures can, in the applications this category cares most about. Aroma retention is where the honest answer is uncomfortable. Pan masala and mouth freshener are aroma-critical products: menthol, camphor and volatile seed oils migrate readily, and losing them is a shelf-life failure long before any moisture or oxygen number is breached.

The barrier vocabulary here is worth being precise about. MVTR (moisture vapour transmission rate) measures how much water vapour crosses a structure per square metre per day. OTR (oxygen transmission rate) does the same for oxygen. Aroma scalping is the absorption of volatile flavour and aroma compounds into the packaging material itself, a loss into the sealant layer rather than a leak outward. Our tea packaging glossary and paper converter glossary define these and the related production terms in full.

Metallisation is what delivers very low MVTR and OTR in a thin, machinable paper-based structure. Remove the metallised layer and both numbers move in the wrong direction. That is physics, not positioning, and we have written about the same trade-off in our monsoon MVTR benchmarks and in the distinction between compostable, recyclable and biodegradable structures, where the labels are routinely conflated.

The draft Schedule IV entry describes a material class: paper, paperboard, cellulose, free of plastic, free of aluminium foil or metallized layers. Understanding what that class can and cannot do is more useful right now than any product conversation, because that class is what the direction of travel points towards, and its hardest cases are exactly the aroma-critical ones.

Lower-barrier applications are a solved problem for paper today. Dry, low-volatile products with modest shelf-life requirements run well on non-metallised paper structures. The difficulty is specific, and it sits at the volatile end.

Where paper-based structures fit

Start with the constraint, because it is the one that works against us. The draft entry requires material free from aluminium foil or metallized layers. Read literally, flexC’s metallised paper structures would not qualify under the proposed pan masala entry. That is the honest reading, and the legal position on it is open. We have not had a determination, and we are not going to imply one.

flexC is a paper-based compostable flexible packaging material sold as reel stock by GSM, not as finished pouches. Three structures ship today: Bleached Teabag Metalized at 63 ± 2 GSM, Bleached Confectionary Metalized at 90 ± 2 GSM, and Bleached Confectionary Non-Metalized at 70 ± 2 GSM. The metallised structures publish a water vapour transmission rate below 2 g/m²/day tested to ASTM F1249, with GSM to TAPPI T410 and thickness to TAPPI T411.

Two things follow, and both need stating plainly.

There is no pan masala or mouth freshener structure in that range. The non-metallised structure that ships today is published for energy, granola and protein bars, cookies and biscuits, and dry fruits and nuts, not for the aroma-critical applications this category needs. No flexC structure is compliant with, approved under, or qualifying for the FSSAI draft pan masala entry, and we will not claim otherwise while the entry is a draft and the legal read is open.

What is genuinely useful today is the material-class conversation: what paper can hold, what it cannot, and how a line behaves when you run it. If you are evaluating a substrate change, the machine-side realities are set out in our work on paper-based pouch machine compatibility and the cost of switching a line from plastic to paper. Both were written for adjacent categories, and both apply directly to a VFFS sachet line.

What should a packaging manager do now?

1. Separate your SKUs by classification. Pan masala and non-pan-masala mouth freshener sit in different regulatory positions. Specify them separately and take the classification from counsel.
2. Treat EPR as the live obligation. Registration, returns and recycled-content targets under G.S.R. 237(E) are enforced. The 2016 prohibition currently is not.
3. Do not plan against a deadline. There is no notified date for the FSSAI entry. Anyone giving you one is guessing.
4. Watch notification, not commentary. The trigger event is the draft being notified in the Gazette. Track that directly.
5. Trial early on the aroma question. Substrate qualification for volatile products takes months of shelf-life data. If the direction of travel concerns you, the data takes longer to generate than the rule takes to arrive.
6. Account for SRM-I. Machine changes carry a tax registration trail. Build that into any line-modification timeline.

Frequently asked questions

Is plastic packaging for pan masala banned in India?

Yes, under Rule 4(1)(i) of the Plastic Waste Management Rules, 2016 (G.S.R. 320(E), 18 March 2016), which is in force. The ban is absolute on its face and has been law for over ten years. It is also comprehensively unenforced, and pan masala ships in metallised plastic laminate nationwide today.

When do the new FSSAI pan masala packaging rules come into force?

There is no date, because the instrument is a draft. The Draft Food Safety and Standards (Packaging) Amendment Regulations, 2026 (F. No. RCD-09002/1/2026, 28 April 2026) has not been notified. Until it is notified, no effective date exists and none can be quoted.

What packaging material is proposed for pan masala under the FSSAI draft?

Paper, paperboard, cellulose or other natural materials completely free from plastic and synthetic polymers, and free from aluminium foil or metallized layers, together with tin and glass containers. The entry would sit at Sl. No. 11 of Schedule IV, which the parent regulations describe as an indicative list of suggestive materials.

Do plastic packaging rules apply to mouth freshener and mukhwas?

Not on the face of the instruments. Rule 4(1)(f) and 4(1)(i) name gutkha, tobacco and pan masala only, and the draft Schedule IV entry is specific to pan masala. Classification depends on the product’s composition and how it is marketed, so confirm it with your own legal adviser rather than assuming.

Can paper-based packaging hold aroma in a mouth freshener pouch?

It depends entirely on the structure and the product. Metallisation is what delivers very low MVTR and OTR in a thin paper-based laminate, and removing it degrades both. Dry, low-volatile products run well on non-metallised paper today. Menthol-bearing and volatile-oil-bearing products are the hard case, and they need shelf-life trial data rather than a specification sheet.

Last reviewed: July 2026 Regulatory status verified: 24 July 2026. The FSSAI Draft Packaging Amendment 2026 remains a draft and has not been notified, verified against FSSAI’s gazette notification and draft notification listings.

If you are evaluating paper-based structures for a sachet or pouch line and want a straight answer about what the material can and cannot do, our food packaging range carries the published technical specifications for each structure, and the resources library holds the brochures. For an application-specific conversation, including one where the honest answer is that we do not have the structure you need, get in touch.

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