India's New EPR Regime for Non-Ferrous Metal Products: Key Compliance Requirements

On 1 July 2025, the Ministry of Environment, Forest and Climate Change (MoEF&CC) notified the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2025 (G.S.R. 438(E)), introducing Extended Producer Responsibility (EPR) for non-ferrous metal products. The new framework will become effective from 1 April 2026, making it mandatory for specified businesses to fulfil EPR obligations for the environmentally sound management and recycling of non-ferrous metal scrap.

The draft was first published on 14 August 2024 (G.S.R. 499(E)) for public comments, and the final rules come into force on 1 April 2026.

Applicability: The new EPR framework for non-ferrous metal products applies to the following entities, each of which is required to obtain registration from the Central Pollution Control Board (CPCB) under Rule 45.

Manufacturers - Entities engaged in the manufacture of any product, component, or spare specified under Schedule-X.
Producers - Entities that sell Schedule-X products under their own brand, irrespective of whether the products are manufactured in-house, through contract manufacturers, imported, or imported as used products or scrap.
Collection Agents - Entities engaged in the collection and channelisation of non-ferrous metal scrap.
Refurbishers - Entities involved in repairing or refurbishing eligible non-ferrous metal products for reuse.
Recyclers - Entities that recycle non-ferrous metal scrap into secondary raw materials or finished products.

In addition, the framework covers Bulk Consumers - organisations, including e-commerce businesses, consuming 1,000 tonnes or more of Schedule-X products in a financial year. Unlike the entities listed above, bulk consumers are not required to obtain registration from the CPCB, however, they must comply with the specific obligations prescribed for them under the Rules.

Products covered: The EPR framework applies to 18 categories of non-ferrous metal products listed under Schedule-X of the Rules. These include –

Cans
Packaging foils
Doors, windows and shutters
Aluminium Composite Panels (ACP)
Partitions and grills
Utensils
Furniture and hardware
Roofing and ceiling sheets
Electric motors and pumps (other than automobile grade)
Conductor cables and wires (other than automobile grade)
Sanitary ware
Electrical fittings (other than automobile grade)
Aluminium alloy bicycles
Transformers (other than automobile grade)
Generator sets
Centralised air-conditioning plants
Apparel hardware (such as buckles and zippers)
Toys

Compliance Requirements - Entities covered under the EPR framework must comply with the following key obligations, set out entity-wise below:

Entity	Key Compliance Obligations
Manufacturers	Obtain registration from the CPCB, with separate registration required for each applicable category (Rule 45). Procure recycled material only from CPCB-registered recyclers and comply with the prescribed recycled-content targets under Schedule XIII (Rule 51). File half-yearly returns on or before 31 October each year through the CPCB portal. Where compliance with the minimum recycled-content obligation is not possible due to statutory or technical requirements, CPCB may grant an exemption on a case-to-case basis (Rule 51(3) proviso).
Producers	Obtain registration from the CPCB, with separate registration required for each applicable category (Rule 45). Meet the prescribed annual EPR recycling targets based on the quantity of products placed on the market (Rule 46 and Schedule XI). Importers of used products or non-ferrous metal scrap must fulfil EPR obligations equivalent to 100% of the quantity imported during the previous financial year. Purchase EPR certificates proportionately every half-year through the CPCB portal, within the prescribed limits (Rule 49). Utilise refurbishing certificates, where available, to defer a portion of their EPR obligation (Rule 48). Conduct consumer awareness programmes through advertisements, publications, digital media and other communication channels to promote responsible recycling. File half-yearly returns on or before 31 October each year through the CPCB portal. Relaxation for new units: units established on or after 1 April 2026 will become liable to meet EPR obligations only after completing two years of operation. EPR recycling target may be reduced by a factor specified by the CPCB on account of operational losses (Rule 46(2)). Details furnished by producers and registered recyclers are cross-verified on the portal; in case of a mismatch, the lower figure is considered towards fulfilment of the EPR target (Rule 46(4)). Only 75% of the EPR quantity deferred through refurbishing certificates is added back to the EPR target on expiry of the refurbished product's extended life (Rule 48(3)). Purchase of EPR certificates is limited to the current year's liability, plus any carried-forward liability, plus 10% of the current year's liability (Rule 49(1)). EPR certificates may be exchanged on CPCB/Central Government-approved trading platform(s), with the exchange price fixed between 30% and 100% of the applicable environmental compensation (Rule 49(7)-(10)).
Collection Agents	Obtain registration from the CPCB, with separate registration required for each applicable category (Rule 45). Collect and channelise non-ferrous metal scrap only within the registered framework. File half-yearly returns on or before 31 October each year through the CPCB portal. Collect end-of-life scrap from manufacturers, producers and bulk consumers, supply it to registered recyclers, and upload the relevant information on the CPCB portal (Rule 53).
Refurbishers	Obtain registration from the CPCB, with separate registration required for each applicable category (Rule 45). Generate refurbishing certificates for eligible refurbishment, which producers may use to defer a portion of their EPR obligation (Rule 48). File half-yearly returns on or before 31 October each year through the CPCB portal. Ensure environmentally sound refurbishing of eligible products and hand over waste generated during refurbishing to a registered recycler or disposal facility (Rule 54).
Recyclers	Obtain registration from the CPCB, with separate registration required for each applicable category (Rule 45). Generate EPR certificates through recycling activities as per the CPCB-prescribed methodology (Rule 47). Maintain records of scrap received, recycled, processed and disposed of, and regularly upload the details on the CPCB portal. File half-yearly returns on or before 31 October each year through the CPCB portal. EPR certificates generated are valid for 2 years from the end of the financial year of generation and are issued in denominations of 100, 200, 500, 1,000 and 10,000 kg (Rule 47). Ensure the facility and recycling process comply with the Rules, prevent environmental damage during storage/transport/recycling, dispose of residue as prescribed, and send non-recyclable fractions to other registered recyclers (Rule 55).
Bulk Consumers	Establish collection points at their premises and hand over scrap only to registered producers, recyclers, refurbishers or collection agents.
All Registered Entities (Common Obligations)	Pay registration and annual maintenance fees as prescribed by the CPCB. Submit annual returns on or before 30 June following the end of the relevant financial year. Cooperate with audits and inspections conducted by the CPCB or its authorised agencies. Audit fees may be applicable. Registered entities shall not transact business with any entity required to be registered under these Rules unless such entity is also registered (Rule 45(6)). The CPCB portal is to be made functional within 6 months of commencement of the Rules, return-filing timelines may be relaxed by up to 9 months in the public interest (Rule 50).
All Applicable Entities	Ensure that the management and utilisation of non-ferrous metal scrap complies with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 (Rule 64).

Year-wise EPR Recycling Targets (Schedule-XI): Producers must meet the following recycling targets, calculated on the quantity of products placed on the market in year Y-X, where X is the average product life -

Year (Y)	Recycling Target (by weight)
2026-27	10% of quantity of products in year Y-X
2027-28	10% of quantity of products in year Y-X
2028-29	30% of quantity of products in year Y-X
2029-30	30% of quantity of products in year Y-X
2030-31	50% of quantity of products in year Y-X
2031-32	50% of quantity of products in year Y-X
2032-33 onwards	75% of quantity of products in year Y-X

Minimum Recycled Content Requirement (Schedule-XIII): Manufacturers must ensure the following minimum percentage of recycled material (by weight) in new products. This percentage is with respect to the total quantity of the non-ferrous metal used in manufacturing of that product. -

Metal	2028-29	2029-30	2030-31	2031-32
Aluminium	5%	10%	10%	10%
Copper	5%	10%	15%	20%
Zinc	5%	10%	15%	25%

Penalties for Non-Compliance

Environmental Compensation (Rule 60): Entities that fail to comply with the EPR provisions may be required to pay environmental compensation as determined by the CPCB.
EPR Obligation Continues: Payment of compensation does not waive the pending EPR targets, which can be carried forward for up to three years.
Refund for Delayed Compliance: If the pending EPR targets are completed later, the business may receive a partial refund of the compensation, up to 85% if compliance is achieved within one year, 60% within two years, and 30% within three years.
Action Against Certificate Misuse: Businesses that generate fake or excess EPR certificates may face suspension or permanent cancellation of their registration.
Cancellation of Registration: Providing false information or violating the Rules may result in revocation of CPCB registration for up to five years.
Legal Proceedings: Non-compliance may also attract prosecution under Section 15 of the Environment (Protection) Act, 1986, in addition to environmental compensation.
Business Disruption: Since only CPCB-registered entities are allowed to deal with each other, suspension or cancellation of registration can disrupt business operations and prevent companies from legally carrying on their activities.
Compensation Fund Utilisation (Rule 60(7)-(8)): Environmental compensation collected is maintained by the CPCB in a separate account and utilised for environmentally sound remediation, including collection and recycling/disposal of uncollected scrap and addressing contamination caused by unscientific management of non-ferrous metal scrap.

Conclusion - The new EPR Rules for non-ferrous metal products are more than just another regulatory requirement and they represent a shift towards greater accountability and sustainable resource management across the metal industry. Businesses that manufacture, import, sell, recycle, or use covered products should proactively evaluate their obligations and implement the necessary compliance measures.

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