Introduction
In India, an EPR policy for the management of non-ferrous metal has been introduced through the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025. These Amendment Rules were passed on 1st July 2025 and came into effect from 1st April 2026.
These EPR Rules apply to non-ferrous metal products and related activities covering Aluminium, Copper, Zinc and their alloys. They make it mandatory for producers, manufacturers, recyclers, refurbishers and collectors of non-ferrous metal waste to manage their waste efficiently. It is therefore essential for anyone involved in the import, recycling, manufacture, collection or refurbishing of non-ferrous metal waste to understand these latest EPR Rules.
What is Non-Ferrous Metal EPR?
EPR (Extended Producer Responsibility) is an environmental regulation which makes producers responsible for the environmental impact of their products after the end of the product lifecycle.
Non-ferrous metals covered include:
- Aluminium
- Copper
- Zinc
- Metal alloys
The following non-ferrous metal products are covered under the EPR scheme:
- Packaging & Cans
- Aluminium Foils
- Doors & Windows
- Aluminium Composite Panels
- Partitions & Grills
- Utensils
- Furniture
- Roofing & Ceiling Sheets
- Motors
- Pumps
- Cables & Wires
- Sanitary Ware
- Electrical Fittings
- Transformers
- Generators
- Air-Conditioning Plants & Other Products
The Non-Ferrous Metal EPR scheme mandates all the above-mentioned covered entities to register themselves through the designated CPCB EPR portal.
Note: EPR Registration is a regulatory requirement and not a business license.
What is the Need for EPR for Non-Ferrous Metal?
EPR aims at moving the liability for waste management away from the Government and waste management systems to the producers of the covered products. It is critical for organisations to ensure EPR compliance since it enables them to:
Ensure Legal Compliance
Entities covered by this amendment have an obligation to be registered and to comply with the corresponding obligations. Failure to register can lead to regulatory action.
Comply With Recycling Obligations
There are recycling targets for producers which are set progressively every year.
Support the Circular Economy
The mechanism ensures that valuable metals such as aluminium, copper and zinc are recovered and recycled rather than being disposed of into the uncontrolled waste stream.
Achieve EPR Certificate Compliance
Registered recyclers that meet the relevant criteria are able to issue EPR certificates, while producers can utilise the corresponding EPR certificates to meet their EPR requirements.
Ensure Business Continuity
Timely registration and ongoing compliance help businesses avoid regulatory disruption to imports, production and sales.
Eligible Entities
The scheme defines the below-mentioned categories as eligible to register:
- Manufacturer
- Producer
- Recycler
- Refurbisher
- Collector
In case an entity carries out more than one of the activities listed above, it has to register itself individually under each of those categories.
Best Fit For
- Recyclers of aluminium scrap
- Recyclers of copper scrap
- Recyclers of zinc scrap
- Importers of non-ferrous metal scrap
- Manufacturers of covered non-ferrous metal products
- Producers / Brand Owners
- Collectors
- Refurbishers
- Entities handling end-of-life non-ferrous metal products
EPR Requirement for Scrap Importers
A special case of the EPR requirement for scrap importers has been provided in the framework. The EPR obligation for year Y is determined based on 100% of the non-ferrous metal content of the imports of year Y-1. It is particularly applicable to entities importing scrap of aluminium, copper, zinc or their alloys into India.
Documents Required
The documentation depends on the kind of applicant and the activities to be conducted. The following details and documents are generally required:
Company Documents
- Certificate of Registration
- PAN
- GST Registration
- Details of Authorised Person
- Phone Number & Email ID
- Address Proof of Unit
Regulatory Documents
- Consent to Establish (if any)
- Consent to Operate
- Hazardous Waste Consent (if any)
- Pollution Control Consents already available
- Other Statutory Consents (if any)
Technical Documents
- Manufacturing / Recycling Process Flow Chart
- Details of Plant & Machinery
- Processing Capacity — Installed / Actual
- Product Details
- Raw Material Details
- Non-Ferrous Metal Scrap Details
- Recycling Process Details
- Material Balance
- Waste / Residue Generation Details
- Unit Photograph
Commercial Information
- Product Manufacturing Details
- Quantity in Market
- Production / Sales Details of the Previous Year
- Import Details (if any)
- Scrap Details Procured
- Recycling Production Details
- Collection / Recycling Details
CERTILIZE assists its clients in identifying the necessary documents for their category before making an application.
Step-by-Step EPR Registration Process
Step 1 — Determination of EPR Applicability
We look at the nature of business, product, material and role of the entity to decide whether Non-Ferrous Metal EPR is applicable.
Step 2 — Identification of Category
We find out whether the applicant should register as a Manufacturer, Producer, Recycler, Refurbisher or Collection Agent. If the business entity carries out more than one activity, separate category criteria are considered.
Step 3 — Documentation Review
We review all technical, commercial and legal documentation for completeness and accuracy.
Step 4 — Creation of EPR Application
We gather all relevant information relating to products, quantity, capacity, recycling operations and more.
Step 5 — CPCB Online Portal Registration
The application is filed through the prescribed online EPR portal.
Step 6 — Scrutiny & Clarification
In case clarification or additional information is needed by CPCB, we help in submitting it.
Step 7 — EPR Registration
Following scrutiny, EPR registration is granted after completion.
Step 8 — Compliance Management
Registration is followed by EPR target calculation, certificate management, data management and returns filing.
EPR Recycling Targets
The framework provides progressively increasing recycling targets for producers:
| Financial Year | Recycling Target |
|---|---|
| 2026–27 | 10% |
| 2027–28 | 10% |
| 2028–29 | 30% |
| 2029–30 | 30% |
| 2030–31 | 50% |
| 2031–32 | 50% |
| 2032–33 onwards | 75% |
The applicable obligation is linked to the quantity of non-ferrous metal placed on the market and the prescribed average life of the relevant product.
EPR Certificate for Non-Ferrous Metal Recycling
One of the important features of the framework is the EPR certificate mechanism. Registered recyclers may generate EPR certificates based on eligible recycled output.
The certificate quantity is calculated using:
QEPR = Qp × Cf
Where:
- QEPR = Quantity eligible for EPR certificate
- Qp = Quantity of recycled end product
- Cf = Applicable conversion factor
The conversion factor is determined based on the applicable technology and recycling requirements. Producers can purchase eligible EPR certificates through the online portal to fulfil their applicable obligations.
Timeline
The timeline for EPR registration depends on:
- Completeness of documents
- Correctness of technical information
- Portal processing
- CPCB scrutiny
- Clarifications, if any
- Additional information required by the authority
CERTILIZE provides end-to-end support from document verification to registration and subsequent compliance.
The actual approval timeline is subject to CPCB processing and therefore should not be treated as a guaranteed fixed period.
Fees and Costs
The total cost of EPR compliance generally consists of:
Government / Portal Fees
A one-time registration fee is payable at the time of registration on the EPR portal. The applicable fee depends on the handling capacity and the type of entity:
| Capacity (TPA) | Manufacturer / Producer | Recycler | Refurbisher | Collector |
|---|---|---|---|---|
| Up to 500 | ₹2,500 | ₹1,500 | ₹1,000 | ₹500 |
| 500–1,000 | ₹5,000 | ₹3,000 | ₹2,000 | ₹1,000 |
| 1,001–5,000 | ₹25,000 | ₹15,000 | ₹10,000 | ₹5,000 |
| 5,001–10,000 | ₹50,000 | ₹30,000 | ₹20,000 | ₹10,000 |
| 10,001–20,000 | ₹1,00,000 | ₹60,000 | ₹40,000 | ₹20,000 |
| 20,001–50,000 | ₹3,75,000 | ₹2,50,000 | ₹1,50,000 | ₹1,00,000 |
| 50,001–1,00,000 | ₹7,50,000 | ₹5,00,000 | ₹3,00,000 | ₹2,00,000 |
| More than 1,00,000 | ₹10,00,000 | ₹7,50,000 | ₹5,00,000 | ₹3,00,000 |
Professional Fees
CERTILIZE’s professional fee depends upon:
- Applicant category
- Nature of business
- Number of products
- Processing / manufacturing capacity
- Import activity
- Existing approvals
- Complexity of EPR calculation
- Scope of ongoing compliance required
Additional Costs
Where applicable, separate costs may arise for:
- Laboratory testing
- CA certification
- Technical documentation
- Site-related documentation
- EPR certificate procurement
- Other third-party services
A customised commercial proposal can be provided after reviewing the client’s business details.
Penalties for Non-Compliance
EPR registration is not merely a documentation exercise. Covered entities are required to comply with the applicable registration, recycling, record-keeping and return-filing requirements.
Non-compliance may result in:
- Regulatory notices
- Directions from the competent authority
- Suspension, cancellation or other action concerning registration
- Restrictions on continued compliance activities
- Environmental compensation or other applicable financial consequences
- Other action under applicable environmental laws and rules
The rules also require covered registered entities to deal with other applicable entities that are registered under the framework. Therefore, businesses should not wait until a regulatory notice is received before assessing their EPR obligations.
EPR Return Filing & Annual Compliance
EPR registration is an ongoing compliance requirement. Manufacturers, producers, collection agents, refurbishers and recyclers are required to file:
- Half-yearly Return — by 31 October
- Annual Return — by 30 June following the relevant financial year
CERTILIZE can assist with:
- Production data compilation
- Import data reconciliation
- Sales / market data
- EPR obligation calculation
- Recycling data
- EPR certificate reconciliation
- Portal reporting
- Half-yearly returns
- Annual returns
Why Choose CERTILIZE?
End-to-End Compliance Assistance
We help from the applicability evaluation to the registration of EPR and subsequent periodic returns.
Industry Experience
Our professionals collaborate with companies engaged in metal recycling, scrap processing and waste treatment.
Documentation Assistance
We help you prepare the documentation necessary for the EPR application.
Assistance in Calculation of EPR
We help companies understand which EPR targets apply to them, along with the special criteria for scrap importers.
Recyclers and Producers
Whether you are a producer wishing to meet your EPR obligations or a recycler willing to generate EPR certificates, we can help you with that.
Periodic Compliance Assistance
Our assistance is not restricted to registration only — it extends to further returns and ongoing EPR responsibilities.
Get Professional Assistance for Non-Ferrous Metal EPR
If you conduct any business involving Aluminium, Copper, Zinc or non-ferrous metal scrap, do not treat EPR as a mere registration requirement. You may have continuing obligations in relation to recycling targets, EPR certificates, record keeping and return filing.
CERTILIZE offers complete Non-Ferrous Metal EPR compliance assistance in India — from determination of applicability and CPCB registration to EPR target calculation, certificate management and return filing. Get in touch with CERTILIZE to determine your Non-Ferrous Metal EPR applicability and compliance requirements.
Frequently asked questions
What is Non-Ferrous Metal EPR?
Non-Ferrous Metal EPR is a regulatory framework mandating the covered entities to perform certain requirements in relation to the recycling and environmentally sound management of products or waste containing covered non-ferrous metals.
What metals are covered?
The scheme covers non-ferrous metals such as aluminium, copper, zinc and their alloys.
Who should have Non-Ferrous Metal EPR Registration?
Manufacturers, Producers, Recyclers, Refurbishers and Collection Agents falling under the relevant framework are required to register.
Does an aluminium scrap importer require EPR compliance?
Importers of non-ferrous metal scrap are covered by provisions dealing with producer requirements. The relevant EPR requirement is based on the content of the non-ferrous metal imported in the previous year.
What is the EPR target for 2026-27?
The recycling target for 2026-27 is 10%. It will increase gradually and reach 75% by 2032-33.
Can an EPR target be achieved by purchasing EPR Certificates?
Yes. Producers may purchase eligible EPR Certificates through the online system from registered recyclers, subject to applicable provisions.
Can recyclers create EPR Certificates?
Yes. Registered recyclers may generate eligible certificates based on the recycled output and the applicable conversion factor.
For how many years is an EPR Certificate valid?
An EPR certificate is valid for two years from the end of the financial year in which it is generated, unless it expires earlier as per the relevant framework.
Is EPR registration a one-time compliance procedure?
No. After registration, there are continuing obligations like record keeping, achievement of the applicable EPR target and filing of returns.
What is the requirement for filing EPR returns?
As per the framework, the half-yearly return is due on or before 31 October and the annual return is due on or before 30 June following the relevant financial year.
Should an entity conducting recycling and manufacturing check more than one EPR category?
Yes. In case an entity conducts more than one activity covered by the framework, the requirements for registration in respect of each such activity are to be considered.
Can CERTILIZE assist in EPR return filing after registration?
Yes. CERTILIZE provides support in calculation of EPR targets, data reconciliation, EPR certificate compliance and filing of half-yearly and annual returns.