Non-Ferrous Metal Scrap EPR Compliance in India
Preparing for EPR for Scrap of Non-Ferrous Metals (Effective 1 April 2026)
Central Pollution Control Board (CPCB) has introduced a new Extended Producer Responsibility (EPR) framework for scrap of non-ferrous metals through the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025.
These rules establish a structured recycling ecosystem for aluminium, copper, zinc, and their alloys, requiring producers and other stakeholders to ensure environmentally sound management and recycling of scrap generated from their products.
The new compliance regime will come into force from 1 April 2026, introducing registration requirements, recycling targets, digital tracking through an online portal, and a tradable EPR certificate mechanism.
ReCirculytics supports organisations in preparing for and complying with the upcoming non-ferrous metal scrap EPR framework, enabling businesses to establish compliant and audit-ready systems before regulatory enforcement begins.
Understanding Non-Ferrous Metal Scrap EPR
The framework introduces:
- mandatory registration of stakeholders
- defined recycling targets
- a digital EPR certificate system
- traceable recycling transactions through an online portal
- periodic reporting and regulatory oversight
Applicability of the Rules
The EPR framework for non-ferrous metal scrap applies to entities involved in the manufacture, sale, import, collection, refurbishment, and recycling of products made from non-ferrous metals. Entities required to register on the CPCB portal include:
Manufacturers
Entities engaged in manufacturing products or components made from non-ferrous metals.
Producers
Any person or entity, irrespective of the selling technique used that manufactures, sells under its own brand, or imports products made from non-ferrous metals—including their components, consumables, parts, or spares—or imports used products, devices, or scrap containing non-ferrous metals.
Collection Agents
Entities responsible for collecting scrap of non-ferrous metals
Refurbishers
Entities that repair or refurbish used products made from non-ferrous metals to extend their lifecycle.
Recyclers
Facilities engaged in processing non-ferrous metal scrap to produce recycled metals or value-added products.
All obligated entities must obtain registration on the CPCB online portal before undertaking regulated activities.
Products Covered Under the Rules
The rules apply to a wide range of products made from non-ferrous metals.
| S.No. | Products |
|---|---|
| 1 | Cans for beverages, aerosols and other such product |
| 2 | Packaging Foils for food, pharma and other such product |
| 3 | Doors, windows, shutters |
| 4 | Aluminium Composite Panel |
| 5 | Aluminium partitioning, grills and other such product |
| 6 | Utensils (cookware, canisters, storage and other such product) |
| 7 | Furniture tables, chairs, benches, ladders etc. including doorknobs, handles, hardware's |
| 8 | Roofing and Ceiling sheets |
| 9 | Motors, pumps, alternators and other such product (other than automobile grade) |
| 10 | Conductor cables and Wires, strips (other than automobile grade) |
| 11 | Sanitary ware and fittings |
| 12 | Electrical fittings (other than automobile grade) |
| 13 | Aluminium Alloy Bicycle |
| 14 | Transformer (other than automobile grade) |
| 15 | Electric Generator sets |
| 16 | Centralized air conditioning plants |
| 17 | Apparel products e.g. Belt Buckles, Zip, Shoes |
| 18 | Toys |
These products are listed under Schedule X of the rules, which identifies the product categories covered under the EPR framework.
Digital EPR Certificate System
The framework introduces a digital EPR certificate mechanism similar to other EPR regimes in India.
Key features include:
- certificates generated by registered recyclers
- certificates issued through the CPCB online portal
- producers can purchase certificates to meet recycling targets
- certificates issued in defined denominations (100 kg, 200 kg, 500 kg, 1000 kg, etc.)
- certificates have validity of two years from the end of the financial year of generation
This market-based system creates financial incentives for recycling while allowing producers flexibility in meeting their obligations.
Mandatory Registration on CPCB Portal
The rules require all obligated entities to register on an online portal developed by the Central Pollution Control Board (CPCB).
The portal will be used for:
- entity registration
- reporting of production and scrap generation
- generation of EPR certificates
- transaction tracking
- filing of returns
- monitoring compliance with recycling targets
Entities will not be permitted to conduct regulated activities without portal registration.
Reporting and Compliance Filings
Registered entities must submit periodic reports on the portal.
Typical compliance filings include:
- half-yearly returns
- annual returns
- production and recycling data
- scrap collection and processing records
- EPR certificate transactions
For example, annual returns must generally be filed by 30 June of the following financial year.
Minimum Recycled Content in New Products
Manufacturers will also be required to use a minimum percentage of domestically recycled metal in new products, as specified in the rules.
| Sr. No. | Type of Metal | Minimum use of Recycled materials* | |||
|---|---|---|---|---|---|
| 2028-29 | 2029-30 | 2030-31 | 2031-32 | ||
| 1 | Aluminium | 5 | 10 | 10 | 10 |
| 2 | Copper | 5 | 10 | 15 | 20 |
| 3 | Zinc | 5 | 10 | 15 | 25 |
*This percentage is with respect to the total quantity of the non-ferrous metal used in 25 manufacturing of that product.
- encourage domestic recycling
- reduce dependence on virgin metal resources
- strengthen circular material flows within the economy.
Environmental Compensation for Non-Compliance
- environmental compensation charges
- suspension or cancellation of registration
- enforcement actions by pollution control authorities.
Environmental compensation may still be imposed even if the obligated entity subsequently fulfils its obligations.
How ReCirculytics Supports Non-Ferrous Metal Scrap EPR Compliance
ReCirculytics provides end-to-end advisory and operational support for organisations navigating the upcoming EPR framework for non-ferrous metal scrap. Our services include:
Regulatory Applicability Assessment
Identifying whether your products fall under the scope of the new rules.
Product Classification and Scope Mapping
Mapping product categories under Schedule X to determine EPR applicability.
CPCB Portal Registration
Supporting registration and documentation for obligated entities.
EPR Target Calculation
Estimating recycling obligations based on product lifecycles and market placement.
EPR Strategy Development
Designing compliance strategies aligned with operational realities.
Recycler Network Development
Connecting producers with authorised recyclers and scrap collection networks.
EPR Certificate Procurement
Compliance Reporting
Audit and Regulatory Support
Preparing organisations for regulatory inspections and compliance audits.
All obligated entities must obtain registration through the CPCB E-Waste EPR Portal before undertaking regulated activities.
Why Businesses Should Prepare Before April 2026
Organisations that begin planning early will benefit from:
- smoother transition into the EPR framework
- early access to recycling partnerships
- reduced compliance risks
- improved cost optimisation for EPR certificates
- stronger sustainability and circular economy positioning
ReCirculytics helps organisations design and implement structured compliance frameworks ahead of regulatory enforcement.
Our Approach
Assess
Evaluate material streams, scrap generation, and regulatory exposure.
Structure
Design documentation and recycling channel frameworks aligned with compliance requirements.
Execute
Implement authorised channelisation and record management systems.
Monitor
Ensure continuous documentation accuracy and audit readiness.
Prepare for Non-Ferrous Metal Scrap EPR Compliance
The upcoming EPR framework for scrap of non-ferrous metals represents a major regulatory shift in India’s resource management ecosystem.
With structured compliance planning and reliable recycling partnerships, businesses can turn regulatory obligations into circular economy opportunities.
ReCirculytics supports organisations in building transparent, compliant, and future-ready non-ferrous metal scrap management systems.
Connect with our team to prepare your organisation for non-ferrous metal EPR compliance before April 2026.
Frequently Asked Questions
Non-ferrous metals are metals that do not contain significant amounts of iron, including aluminium, copper, lead, zinc, and other high-value recyclable materials.
Non-ferrous metals are highly recyclable and economically valuable. Proper channelisation through authorised recyclers prevents informal processing, environmental contamination, and regulatory risk.
Producers, manufacturers, importers, industrial facilities, and scrap generators handling non-ferrous metal materials may have compliance obligations depending on regulatory applicability.
Common materials include aluminium scrap, copper scrap, lead and zinc scrap, and mixed non-ferrous metal waste generated from manufacturing, dismantling, or industrial processes.
Yes. Proper documentation, including quantity records, authorised recycler receipts, and channelisation proof, is essential to maintain compliance and traceability.
