On this page
- What is Non-Ferrous Metal EPR?
- Who Needs Non-Ferrous Metal EPR Registration?
- Who Is Not Required to Register?
- Which Products Are Covered?
- Documents Required for Non-Ferrous Metal EPR Registration
- Steps for applying for EPR Registration for Non-Ferrous Metals?
- Non-Ferrous Metal EPR Compliance Timeline
- What Is the Role of CPCB?
- What if you fail to comply?
- Conclusion
Non-Ferrous Metal EPR registration is an important compliance requirement for companies in India that deal with certain aluminium, copper, zinc, and alloy products. The Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025 introduced these requirements, which came into effect on 1 April 2026.
What is Non-Ferrous Metal EPR?
EPR means that producers are responsible for managing the waste from products covered under the EPR rules. For non-ferrous metals, this includes products made from aluminium, copper, zinc, and their alloys. The focus of the scheme is on scrap collection, recycling and management. Producers responsible for the above-mentioned regulations should reach the specified recycling rates under the EPR scheme.
Who Needs Non-Ferrous Metal EPR Registration?
The following businesses need to register on the CPCB EPR Portal:
1. Manufacturers
Manufacturers of products/ components/ parts covered under the respective schedule shall be required to register themselves and fulfill their EPR responsibilities.
2. Producers
Producers are those who produce products covered under the respective schedule for sale in the Indian market under their own brand name. The producers could also be those who import such products under their own brand or original brand name.
Those companies which import used products, devices and/or non-ferrous metal scrap will also be considered as producers.
3. Collection Agents
Collection agents who collect non-ferrous metal scrap and deliver them to the registered recyclers shall be required to register under the EPR scheme.
4. Recyclers
Recyclers of non-ferrous metal scrap shall be required to register themselves and maintain records of the scrap which is collected, recycled and disposed of by them.
5. Refurbishers
Refurbishers working on products covered under the respective schedule shall be required to register.
Who Is Not Required to Register?
Not all metal businesses are automatically required to register.
If the product or activity does not come within the purview of the relevant schedules, the company cannot assume that Non-Ferrous Metal EPR registration is mandatory.
Bulk consumers do not also fall within the category of registrants mandated by Rule 45. But this does not mean that they do not have obligations relating to collecting and handing over non-ferrous metal scrap properly.
Thus, before making an application for registration, businesses must verify whether they belong to any of the product categories or play a particular role.
Which Products Are Covered?
Schedule X consists of the list of covered products of non-ferrous metal products. Some of these products include:
- Beverage and aerosol cans
- Packaging foils
- Doors, windows and shutters
- Aluminium composite panels
- Utensils and storage products
- Furniture
- Roofing and ceiling sheets
- Certain motors, pumps and alternators
- Wires, cables and strips
- Sanitary ware and fittings
- Electrical fittings
- Aluminium alloy bicycles
- Transformers
- Generator sets
- Certain air conditioning units
- Toys and other specified products
Documents Required for Non-Ferrous Metal EPR Registration
The application is made online in the prescribed format. The business needs to have the basic information of the business and activities ready.
- Depending on the category, the information may include:
- Business/company Information
- Information regarding the authorised person
- Registered and operating address
- Information about the products which are covered
- Information regarding manufacturing or recycling facility, if any
- Information about production/recycling/handling capacity
- Any other supporting information/documents regarding the business
- The requirements for documentation need to be verified from the latest CPCB application form and instructions.
Steps for applying for EPR Registration for Non-Ferrous Metals?
The application for EPR registration will be made online.
Step 1: Check applicability
Check what kind of material, product and business activity it is and whether it is covered by the applicable schedule.
Step 2: Find out the category
Check if the entity is a manufacturer, producer, collection agent, recycler or refurbisher.
Step 3: Information readiness
Be ready with the information regarding business, authorised person, products and supporting documents.
Step 4: Make the application
Fill the prescribed online registration application form on the CPCB EPR website and submit the information.
Step 5: Verification & Registration
CPCB verifies the information submitted in the application. After the application is approved, the business gets its registration.
Step 6: Follow the EPR Rules
The entity has to maintain compliance after registration. Businesses can also take professional support for EPR registration, return filing and ongoing compliance.
Non-Ferrous Metal EPR Compliance Timeline
The rules provide for half-yearly and annual returns.
For manufacturers, producers, collection agents, refurbishers and recyclers:
- Half-yearly return: On or before 31 October
- Annual return: On or before 30 June following the relevant financial year
Producers also have to meet their applicable recycling targets.
For example:
| 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% |
For importers of used devices, products or non-ferrous metal scrap, the EPR obligation is 100% of the non-ferrous metals imported in the previous year, as provided under the rules.
What Is the Role of CPCB?
EPR framework implementation and monitoring have been assigned to CPCB. It will involve managing the EPR portal, monitoring registrations and compliance, formulating the procedure for issuance of EPR certificates and coordination with the SPCBs and PPCs.
What if you fail to comply?
The entity subjected to the obligation to register must register prior to conducting the relevant activity.
If a business does not follow the rules, it may have to pay environmental compensation. Its registration may also be cancelled if it provide invalid information.
Conclusion
Non-Ferrous Metal EPR applies to specified aluminium, copper, zinc and alloy products covered under the applicable rules. Businesses should first check whether their product and business activity fall under the EPR requirements and then complete the required registration and compliance.
If you need help with non-ferrous metal recycling, EPR compliance or related regulatory requirements, Certilize can assist you with the process and ongoing compliance support.
Frequently asked questions
Who Requires Non-Ferrous Metal EPR Registration in India?
Those businesses falling under the applicable rules and schedules must register with CPCB.
Do I Need EPR Registration for All Metals Businesses?
No. It depends upon the products being dealt in and their material and nature. You may wish to review the applicability based on your products from the applicable schedule.
Which Metals are Covered Under Non-Ferrous Metal EPR?
The applicable framework includes aluminium, copper, zinc and their alloys as well as the products mentioned in the applicable schedule.
When do I have to file my EPR returns?
The returns for half-year and annual are filed generally by 31 October and 30 June respectively.
Am I free to start my EPR without knowing my EPR Category?
It is recommended to first identify your category and review the applicability of products from the applicable schedule.
