Non-Ferrous Metals EPR Registration

Introduction

• The Non-Ferrous Metals Extended Producer Responsibility (EPR) Framework introduced through the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025 represents a major regulatory shift in India’s resource management regime. The framework, notified by the Ministry of Environment, Forest and Climate Change with centralized digital oversight by the Central Pollution Control Board, extends statutory EPR obligations to key non-ferrous metals.
• Effective 1 April 2026, the framework moves beyond traditional waste disposal toward a life-cycle, circular economy–based regulatory approach, mandating collection, recycling, refurbishment, and environmentally sound end-of-life management of covered metal

I. Statutory Basis & Regulatory Architecture

The EPR framework is grounded in delegated environmental legislation under the Environment (Protection) Act, 1986. By incorporating non-ferrous metals within the ambit of hazardous and other waste management rules, the Government has elevated metal recovery from a policy preference to a statutory compliance obligation.

Key Legal Characteristics

1. Mandatory Registration Regime
No entity can operate within the regulated value chain without prior registration on the CPCB portal. This transforms EPR compliance into a condition precedent for lawful business operations.

2. Prohibition-Based Enforcement Model
The Rules expressly prohibit:

• Operating without registration
• Engaging in commercial transactions with unregistered entities
• Furnishing inaccurate data or misreporting quantities

3. Digital Compliance Governance
All transactions, certificate generation, adjustments, and reporting must occur through the CPCB online system, creating a traceable compliance ecosystem.

II. Scope of Regulatory Coverage

The framework applies to:

• Aluminium
• Copper
• Zinc
• All respective alloys

Coverage of EPR includes:

• Primary metal manufacturers
• Alloy manufacturers
• Producers placing metal-containing products on the market
• Importers of metals, scrap, or used products
• Manufacturers consuming covered metals
• Recyclers and refurbishers
• Collection agents

These metals are strategically regulated due to their extensive industrial use, high recyclability, and energy-intensive primary production. By covering both metals and alloys, the Rules ensure comprehensive regulation across extraction, manufacturing, recycling, refurbishment, and downstream use.

III. Recycling Targets & Legal Obligation Structure

Recycling targets prescribed under Schedule XI are progressive and legally binding:

Period	Recycling Obligation
FY 2026 - 2028	10 %
FY 2028 - 2030	30 %
FY 2030 - 2032	50 %
FY 2033 onwards	75 %

Special Compliance Clause
Imported scrap and used products attract 100% EPR liability, meaning full recovery responsibility rests with the importer.

IV.  EPR Certificate Mechanism

The framework introduces a regulated certificate-based compliance model specific to non-ferrous metals:

• Recyclers generate EPR certificates based on verified recycling output
• Obligated entities procure certificates to meet recycling targets
• Certificates are metal-specific and governed by CPCB conversion factors and reconciliation rules
• Certificates function as legally recognized compliance instruments within a digitally monitored marketplace.

Refurbishment Provisions

• Refurbishment is recognized as a circular pathway within the non-ferrous metal lifecycle:
• Certified refurbishment extends product life
• EPR liability is deferred during extended use
• 75% liability is reintroduced when the refurbished product re-enters the waste stream

This provision promotes reuse while preserving eventual recycling responsibility.





 

1.  Strong Legal Safeguard

• Ensures full compliance with statutory EPR obligations, reducing exposure to penalties, notices, and regulatory action.

2.  Accountable Recycling Framework

• Creates a structured and traceable system for channelizing non-ferrous metal scrap through authorized recyclers.

3.  Improved Governance & Data Control

• Establishes measurable tracking of quantities placed in the market versus recycled, strengthening internal compliance systems.

4.  Enhanced Sustainability Credentials

• Supports circular economy practices and strengthens ESG reporting and sustainability disclosures.

Step 1: Applicability Assessment

• Determine whether the entity qualifies as a Producer, Importer, or Brand Owner.
• Assess total quantity of non-ferrous metals placed in the market (production/import).
• Identify applicable EPR targets as per notified percentage obligations.

Step 2: Data Compilation & Target Calculation

• Compile production, import, and sales data for the previous financial year.
• Identify metal composition (aluminium, copper, zinc, lead, etc.).
• Calculate annual EPR liability based on prescribed target percentages.
• Prepare the EPR Action Plan outlining waste collection and recycling strategy.

Step 3: Online Registration (CPCB Portal)

• Create login and submit EPR application on the CPCB EPR portal.
• Upload statutory documents and operational details.
• Submit EPR Action Plan and recycler agreements.

Step 4: Scrutiny & Approval

• Respond to CPCB queries or clarification requests, if any.
• Obtain EPR Registration Certificate upon approval.

A. For Producers / Importers / Brand Owners (PIBOs)

• Company PAN & GST Certificate
• Certificate of Incorporation / Partnership Deed
• Authorized Signatory Details & Board Resolution
• Import Export Code (if applicable)
• Product details with metal composition
• Sales data (previous financial year)
• Estimated quantity placed in market
• Agreement / MoU with authorized recyclers
• EPR Action Plan
• Waste channelization mechanism details

B. For Recyclers / Dismantlers

• Consent to Establish (CTE) & Consent to Operate (CTO)
• Authorization under Hazardous Waste Rules
• Factory License
• Pollution control system details
• Installed recycling capacity certificate
• Process flow diagram
• Annual returns and production records

1.  Regulatory Registration Deliverables

Applicability Assessment Report

• Detailed evaluation of EPR liability based on production/import volume and metal category.

EPR Target Calculation Sheet

• Metal-wise obligation calculation aligned with notified percentage targets.

EPR Action Plan Document

• Structured roadmap outlining collection mechanism, channelization strategy, recycler tie-ups, and compliance timeline.

Complete Application Dossier

• Compilation, verification, and submission of all statutory and technical documents on the CPCB portal.

Operational & Implementation Deliverables

• Recycler Identification & Due Diligence Support
• Verification of authorized recyclers’ licenses, capacity, and compliance status.

Drafting of Recycler Agreements / MoUs

• Legally structured agreements ensuring traceability and regulatory alignment.

Waste Channelization Framework

• Documented reverse logistics and material tracking mechanism.

Compliance Calendar

• Annual timeline of reporting obligations, target deadlines, and documentation milestones.