India's export packaging landscape has changed significantly in the past three years. The combination of EU deforestation regulations, tightening US FDA import standards, and domestic BIS enforcement has created a compliance environment that catches many Indian manufacturers off-guard — particularly those moving into new export markets. This guide covers the key requirements your packaging supply chain must meet in 2026.
1. DGFT Regulations — Packaging and Labelling
The Directorate General of Foreign Trade (DGFT) prescribes packaging and labelling requirements for various export product categories. Under the Foreign Trade Policy 2023, exporters must ensure packaging is adequate to protect goods during transit and meets the importing country's labelling standards. For packaged food, the Food Safety and Standards Authority of India (FSSAI) export labelling requirements must be met, including ingredient declaration in the language of the destination country.
Practically, this means your paper and board packaging must carry correct country of origin marking, net weight, and batch/lot identification. For pharmaceutical exports, Schedule D of the Drugs and Cosmetics Act requires specific labelling on outer cartons, including shelf life, storage conditions, and licence number.
2. BIS Requirements for Paper and Board
The Bureau of Indian Standards (BIS) has mandatory standards for paper and board used in specific applications. IS 1397 covers duplex board and kraft liner specifications. IS 14927 covers folding box board. While these standards are not always mandatory for domestically-sourced packaging, export-facing procurement departments in major FMCG and pharma companies increasingly require BIS-compliant board as a quality baseline.
Importantly, BIS compliance provides legal protection in the event of a packaging failure. If you can demonstrate that your board met IS specifications at the time of purchase (via mill Certificate of Analysis), you have a defensible position in any quality dispute with your customer or logistics provider.
3. EU Import Standards — What Has Changed
The EU Deforestation Regulation (EUDR), which entered into force in stages from 2024, requires that wood-derived products — including paper and board — be traceable to legally harvested sources. For Indian exporters using imported kraft liner or FBB from European mills, this traceability is typically already in place via FSC or PEFC chain of custody. For boards sourced from non-certified Indian mills, EUDR compliance requires due diligence documentation proving legal timber origin.
Food packaging exported to the EU must comply with EC Regulation 1935/2004 on materials and articles in contact with food. This applies to any paper or board that will be in direct or functional contact with food. Mill-issued food contact compliance declarations are required, and heavy metal migration tests may be requested by EU importers.
4. US FDA Standards for Paper Packaging
For Indian manufacturers exporting food or pharmaceutical products to the United States, the FDA's requirements for packaging materials are codified under 21 CFR (Code of Federal Regulations). Specifically, 21 CFR 176 covers paper and paperboard components for food contact. The board used in direct-food-contact applications must use only FDA-approved substances.
ITC FBB (Cyber Oak, Cyber XLPac, PearlXL) carries US FDA compliance documentation for food contact applications. If you are exporting to the US using Indian-manufactured FBB, request the FDA compliance letter from your board supplier — Pune Global Group provides this documentation routinely for FBB orders.
5. FSC Certification — Now a Commercial Requirement
Forest Stewardship Council (FSC) certification has shifted from a 'nice to have' to a commercial necessity for many export categories. Major UK and EU retailers — Tesco, Marks & Spencer, IKEA, Unilever — require FSC-labelled packaging from their global supply chain. If your packaging carton carries an FSC logo, your board must trace to an FSC Chain of Custody certified supplier.
Pune Global Group holds FSC Chain of Custody certification (FSC C064218). This means we can supply FSC-certified ITC FBB with full chain of custody documentation, enabling our clients to display the FSC logo on their export packaging without separately obtaining their own certification.
6. ISPM-15 — Wood Packaging Material
The International Standards for Phytosanitary Measures No. 15 (ISPM-15) applies to solid wood packaging — pallets, crates, dunnage — used in international trade. It does not apply to paper, board, or PP corrugated packaging. However, if your export shipment uses wooden pallets, those pallets must be heat-treated and marked with the IPPC logo. Failure to comply will result in rejection or fumigation at the destination port at your expense.
Export Packaging Documentation Checklist
- Mill Certificate of Analysis (COA) / Mill Test Certificate (MTC) for board
- FSC Chain of Custody certificate (if FSC logo is displayed)
- Food contact compliance declaration (for food/pharma applications)
- BIS conformity documentation (IS 1397 / IS 14927 as applicable)
- EUDR due diligence documentation (for EU-bound shipments)
- ISPM-15 certificate for wooden pallet/packaging used in transit
- Country of origin declaration for packaging materials
- Packaging validation report (drop test, compression test) for fragile goods
Compliance documentation management is one of the least glamorous but most consequential parts of export packaging procurement. Pune Global Group maintains a document repository for all grades we supply, and we proactively share updated compliance documents with every repeat order.
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