BIS Certification for Recycled Plastic Products and Raw Materials in India

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A plastic recycler produces recycled PP granules and receives a request from a large buyer asking for a “BIS certificate.” The recycler begins preparing an application, only to discover that the first question should have been different: what exact material or product is being certified, which Indian Standard applies, and is certification compulsory at all?

BIS Certification for Recycled Plastic Products and Raw Materials in India

This distinction is central to BIS certification for recycled plastic products in India. BIS develops standards covering plastic recycling, recyclate designation and specific finished products, but the existence of an Indian Standard does not automatically make certification mandatory. Businesses should first identify the product, its intended use and the current Quality Control Order status before applying.

Is BIS Certification Mandatory for All Recycled Plastic Products?

No. There is currently no blanket rule requiring every recycled plastic, recycled granule or recycled-plastic product in India to obtain a BIS licence merely because recycled material is used.

BIS itself states that product certification is basically voluntary. It becomes compulsory where the Central Government brings a product under mandatory conformity assessment, normally through a Quality Control Order or another applicable legal requirement.

This means a recycler should distinguish among three questions:

  1. Is there an Indian Standard relevant to the material?
  2. Is BIS certification available against that standard?
  3. Has compliance with that standard been made compulsory for the specific product?

These are not the same question.

A manufacturer may also seek voluntary BIS certification where a suitable certification standard exists and certification has commercial value, even when no QCO makes it mandatory.

Which BIS Standards Apply to Recycled Plastic?

There is no single Indian Standard covering every recycled plastic product.

The appropriate standard depends on whether the business produces general recyclate, PP/PE mixtures, PET recyclate or a specific finished product.

Indian Standard Main relevance What businesses should understand
IS 14534:2023 Recovery and recycling of plastic waste General recycling guideline
IS 14535:1998 Recycled plastics for manufacturing products Identification and classification of recycled plastic
IS 16591 Part 1:2016 PP/PE recyclate from flexible and rigid consumer packaging Specific designation/specification system with a BIS Scheme-I Product Manual
IS 16630 Part 1:2018 Post-consumer PET recyclates PET recyclate designation and specification basis
IS 16058:2024 Dunnage pallets made from recycled packaging wastes Specific finished-product standard with Scheme-I certification pathway

BIS lists IS 14534:2023 as the second revision of its guideline for the recovery and recycling of plastic waste. Its purpose is broader than product certification: it addresses recycling processes and management of plastic waste.

BIS also identifies IS 14535:1998 as a standard intended to identify and classify recycled plastic materials according to basic properties and applications.

Therefore, neither standard should be presented to a business as automatic evidence that every recycler must obtain an ISI Mark.

BIS Certification for Recycled PP and PE Raw Materials

One of the most relevant technical standards for recyclers is:

IS 16591 Part 1:2016 – Plastics – Mixtures of Polypropylene (PP) and Polyethylene (PE) Recyclate Derived from PP and PE Used for Flexible and Rigid Consumer Packaging – Part 1: Designation System and Basis for Specification.

BIS has issued a Product Manual specifically for certification under Scheme-I against this standard.

The Product Manual shows that certification can involve parameters such as:

  • PP and PE composition
  • colour and material form
  • melt mass-flow rate
  • density
  • optional mechanical properties depending on the declared specification

The manual specifies a sample quantity of 3 kg for grant/change-of-scope/factory-surveillance purposes and sets out grouping according to the recyclate designation claimed by the manufacturer.

The important compliance point is that availability of a Scheme-I certification pathway does not itself mean the product is compulsorily certified.

What happened to the PP and PE Quality Control Orders?

Businesses should be particularly careful with older online articles.

The Government had previously issued Quality Control Orders for:

  • Polyethylene Material for Moulding and Extrusion
  • Polypropylene Materials for Moulding and Extrusion

However, both were rescinded on 12 November 2025.

S.O. 5136(E) rescinded the earlier PE notification relating to Polyethylene Material for Moulding and Extrusion.

S.O. 5138(E) rescinded the earlier QCO relating to Polypropylene Materials for Moulding and Extrusion.

Therefore, a recycler, importer or polymer supplier should not rely on an old article stating that PP or PE moulding material is currently under those former QCOs.

A fresh QCO check should be completed against the precise product immediately before a commercial decision or BIS filing.

BIS Standards for Recycled PET Raw Material

For PET recyclers, BIS lists:

IS 16630 Part 1:2018 – Plastics – Recyclates from Post-Consumer Bottles and Other Forms of Polyethylene Terephthalate (PET) – Part 1: Designation System and Basis for Specifications.

The current BIS programme of work lists this standard for post-consumer PET recyclates.

A PET recycler should therefore establish:

  • source of PET feedstock;
  • whether material is post-consumer or another stream;
  • form of recyclate;
  • intended grade;
  • intended downstream application;
  • applicable testing parameters;
  • whether the buyer requires voluntary BIS conformity;
  • whether another sector-specific regulation applies.

The last point becomes especially important where recycled PET is intended for direct food-contact applications.

Food-Grade rPET Requires a Separate FSSAI Check

A food-contact rPET project should not treat general plastic-recycling compliance as sufficient.

The Food Safety and Standards (Packaging) First Amendment Regulations, 2025 permit products made from recycled PET for packaging, storing, carrying or dispensing food when the applicable standards and guidelines notified by FSSAI are met.

FSSAI subsequently notified its Guidelines for Acceptance of Recycled Polyethylene Terephthalate (PET) as Food Contact Material on 23 May 2025.

Those guidelines apply specifically to recycling processes transforming post-consumer food-grade PET into FCM-rPET resin and include acceptance requirements and approved recycling-technology considerations.

FSSAI also maintains a list of manufacturers authorised for food-grade rPET applications.

Practical distinction

BIS standard compliance, FSSAI food-contact approval and Plastic Waste/EPR registration are different compliance layers.

Receiving one does not automatically replace the others.

What About Finished Products Made from Recycled Plastic?

A second common mistake is to assess only the recycled raw material and ignore the final product.

Suppose recycled packaging waste is converted into a warehouse pallet.

The relevant product may fall under:

IS 16058:2024 – Dunnage Pallets Made from Recycled Packaging Wastes for Warehousing Application.

BIS has a specific Product Manual for certification under Scheme-I. The manual covers pallet types, dimensions, construction, workmanship, density and performance testing, among other requirements.

BIS announced the All India First Licence against IS 16058:2024 in October 2025, confirming active implementation of the certification standard.

The principle is important:

Once recycled raw material becomes a finished product, the relevant BIS question may shift from the recyclate standard to the Indian Standard governing the final product.

The same logic should be applied to pipes, packaging products, containers, sheets, automotive components and other products made partly or wholly from recycled resin.

BIS Applicability Decision Tree for Recycled Plastic Businesses

Before applying, run this five-step check.

Step 1 – Identify what you actually sell

Is it:

  • flakes;
  • granules;
  • pellets;
  • recyclate mixture;
  • compounded resin;
  • sheet;
  • container;
  • pallet;
  • pipe;
  • packaging material; or
  • another finished product?

Step 2 – Define the polymer and source

Determine whether it is:

  • PET
  • PP
  • PE
  • HDPE
  • LDPE
  • mixed PP/PE
  • another polymer
  • pre-consumer recyclate
  • post-consumer recyclate

Step 3 – Identify the applicable Indian Standard

The standard must match the actual product, not simply the fact that recycled plastic is involved.

Step 4 – Check current mandatory status

Search the current BIS compulsory-certification list and the applicable ministry’s latest QCOs.

BIS explicitly directs manufacturers to check whether their product appears in the compulsory-certification list before concluding that a licence is mandatory.

Step 5 – Check additional sector regulations

Ask whether the product is:

  • food contact;
  • drinking-water related;
  • pharmaceutical packaging;
  • an electrical component;
  • an automotive product;
  • EPR-linked packaging; or
  • used in another regulated application.

Only after these five checks should the business determine the certification route.

BIS Certification Process for Recycled Plastic Products

Where Scheme-I certification is applicable, the process normally starts with product-standard verification rather than form filling.

1. Confirm the Indian Standard

Identify the relevant Indian Standard and the exact scope of the product.

A BIS licence is product-, standard- and manufacturing-premises-specific. BIS states that separate applications are required for different products/Indian Standards and separate factory locations.

2. Review the BIS Product Manual

Where available, check the product manual for:

  • product grouping;
  • varieties/designations;
  • sample quantity;
  • testing requirements;
  • required test equipment;
  • Scheme of Inspection and Testing;
  • licence scope;
  • marking requirements.

For IS 16591 Part 1:2016, for example, the manufacturer must declare designation codes proposed for inclusion in the licence scope. BIS may restrict scope according to manufacturing and testing capability.

3. Perform a Factory Readiness Assessment

BIS requires the manufacturer to possess appropriate manufacturing infrastructure, process control, quality control and testing capabilities and to manufacture products conforming to the applicable Indian Standard.

For a recycler, the assessment should therefore examine the entire production chain, including:

  • incoming-feedstock control;
  • segregation;
  • washing or cleaning;
  • shredding/grinding;
  • extrusion;
  • filtration;
  • pelletisation;
  • blending;
  • batch identification;
  • laboratory testing;
  • handling of non-conforming material;
  • finished-product traceability.

4. Establish the Testing Plan

For Scheme-I, testing requirements should be taken from the relevant standard and Product Manual.

For IS 16591, BIS identifies tests covering composition, melt mass-flow rate, density, colour/form and applicable additional properties.

The same product manual expects a Quality Assurance Plan and appropriate routine testing. Certain testing may be subcontracted to a BIS-recognised/empanelled laboratory or another laboratory holding applicable NABL accreditation as described in the Product Manual.

5. Submit the BIS Application

BIS product-certification applications are submitted online through the applicable BIS/Manak Online system.

A technically complete application should have the product scope frozen before submission.

6. Factory Assessment and Product Conformity

BIS states that the licence decision is based on assessment of:

  • manufacturing infrastructure;
  • process control;
  • quality-control capability;
  • testing arrangements; and
  • conformity of the product.

Product conformity may be established through third-party laboratory testing, factory testing or a permitted combination.

7. Grant of Licence and ISI Marking

After successful assessment, the licence permits use of the Standard Mark only within its approved scope.

For IS 16591, the Product Manual requires the Standard Mark to be incorporated legibly and indelibly on each applicable bag and/or unit package containing conforming material.

Manufacturers should never use an ISI Mark on an unapproved material, grade, designation or product merely because another product from the same factory holds a BIS licence.


BIS Requirements for Foreign Recycled-Plastic Manufacturers

A foreign manufacturer exporting a product to India may need the Foreign Manufacturers Certification Scheme (FMCS) where the applicable standard/certification route calls for it.

BIS explains that FMCS grants a licence to foreign manufacturing units for products conforming to the relevant Indian Standard, whether the standard is subject to voluntary or mandatory certification.

The foreign manufacturer must normally have appropriate manufacturing and testing facilities and submit a separate application for each relevant product/standard and manufacturing location.

An Authorised Indian Representative (AIR) is also required. The AIR must be located in India and assumes defined responsibility in relation to compliance with the BIS framework and licence conditions.

Since 1 June 2026, BIS states that FMCS applications are accepted through the online route rather than the previous hard-copy process.

Documents to Prepare Before BIS Application

Exact requirements depend on the applicable standard, scheme and factory, but a recycled-plastic manufacturer should normally prepare a technical dossier covering:

Area Readiness evidence
Business Entity and manufacturing-premises details
Product Exact product name, grade, designation and intended use
Standard Applicable IS and current revision
Production Detailed process flow and manufacturing controls
Raw material Source and specification of feedstock/recyclate
Machinery Manufacturing-machinery list and capacity
Laboratory Test-equipment list, calibration and testing capability
Quality Quality Assurance Plan and batch/control-unit definition
Testing Applicable test reports and sample plan
Factory Plant layout and production-area details
Marking Proposed BIS marking/packaging details
Foreign factory FMCS documentation and AIR nomination, where applicable

The objective is not simply to collect PDFs. The documentation should tell the same technical story as the factory, product samples and test results.

Common BIS Deficiencies for Recycled-Plastic Businesses

1. Selecting a guideline instead of the product standard

IS 14534 is important for plastic recycling, but the final BIS certification question may depend on another material or product-specific Indian Standard.

2. Assuming every recycled granule needs an ISI Mark

The presence of an IS number does not automatically mean compulsory certification.

3. Relying on an old PP or PE QCO article

The former QCOs for PP and PE moulding/extrusion materials were rescinded in November 2025.

4. Applying using an overly broad product scope

For IS 16591, designation, composition, melt-flow and density ranges affect product grouping and licence scope.

5. Weak in-house quality control

BIS certification is based on continued conformity, not simply one passing laboratory report.

6. Confusing CPCB registration with BIS certification

Plastic Waste Processor registration operates under the plastic-waste/EPR framework and allows compliant processors to participate in the formal EPR system. It is not a BIS product licence. CPCB’s PWP SOP separately addresses processor registration and EPR certificates.

7. Ignoring food-contact requirements

A recycled PET resin intended for food-contact applications must be assessed against FSSAI’s specific rPET framework rather than treated as ordinary non-food recyclate.

Surveillance and Renewal After BIS Certification

Certification does not end when the licence is granted.

BIS conducts surveillance to verify that manufacturing infrastructure, process controls, testing capability and product conformity continue to be maintained. Factory and market samples may also be assessed.

The 2026 amendment to the BIS Conformity Assessment Regulations changed Scheme-I licence validity. A licence may now initially be granted for up to five years and renewed for a further period of up to five years. Annual fees and the required production statement remain part of continued operation.

Manufacturers should therefore maintain:

  • batch-wise testing records;
  • production statements;
  • calibrated test equipment;
  • raw-material traceability;
  • non-conformity records;
  • marking controls;
  • current licence scope;
  • annual compliance calendar.

Pre-Application Readiness Test

Before filing, answer these ten questions:

  1. Can you describe exactly what product or raw material you sell?
  2. Have you verified the current Indian Standard?
  3. Have you checked the latest QCO status?
  4. Is the certification voluntary or mandatory?
  5. Have you identified the correct BIS scheme?
  6. Does your proposed licence scope match actual production?
  7. Can your factory perform the required routine testing?
  8. Have you identified an acceptable external laboratory where required?
  9. Does your packaging or product marking meet the applicable requirements?
  10. For an overseas factory, is an eligible AIR in place?

If several answers are “no”, filing immediately can create avoidable queries or testing costs.

Frequently Asked Questions

Is BIS certification compulsory for all recycled plastic granules?

No. BIS certification is not automatically compulsory simply because a material is recycled plastic. The applicable Indian Standard and current QCO/mandatory notification must first be identified.

Which BIS standard applies to recycled PP and PE from packaging?

IS 16591 Part 1:2016 covers mixtures of PP and PE recyclate derived from PP and PE used for flexible and rigid consumer packaging. BIS has issued a Scheme-I Product Manual for the standard.

Which standard applies to post-consumer PET bottle recyclate?

IS 16630 Part 1:2018 addresses the designation system and basis for specifications for post-consumer PET recyclates.

Does IS 14534 mean my recycling plant needs an ISI licence?

Not by itself. IS 14534:2023 provides guidance concerning the recovery and recycling of plastic waste. The BIS certification requirement should be established against the actual material or finished product and its current regulatory status.

Are recycled-plastic pallets covered by a BIS standard?

Yes. IS 16058:2024 applies to dunnage pallets made from recycled packaging wastes for warehousing applications, and BIS has issued a Scheme-I Product Manual for this product.

Do food-grade recycled PET manufacturers only need BIS?

No. Food-contact recycled PET has a separate FSSAI regulatory framework. The FSSAI guidelines cover recycling technologies and acceptance of FCM-rPET resin intended for food-contact materials.

Do foreign manufacturers need an AIR?

For applicable FMCS applications, an Authorised Indian Representative is required.

How Green Permits Can Help

For recycled-plastic businesses, the most valuable work often happens before a BIS application is filed.

Green Permits can assist manufacturers, recyclers, importers and foreign suppliers with:

  • product and Indian Standard identification;
  • current QCO applicability review;
  • Scheme-I/FMCS route assessment;
  • product-scope and designation review;
  • testing and laboratory coordination;
  • factory-readiness assessment;
  • application documentation;
  • BIS observation and deficiency response;
  • Plastic EPR/PWP compliance coordination where separately applicable.

A product-specific assessment is recommended before treating BIS certification as either compulsory or unnecessary.

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