India has introduced Extended Producer Responsibility (EPR) for non-ferrous metals under the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025.
The framework covers aluminium, copper, zinc and their alloys and will come into effect from 1 April 2026.
The objective is to strengthen the collection and recycling of non-ferrous metal scrap, increase the use of recycled materials and support India’s transition towards a circular economy.
What Are Non-Ferrous Metals?
Under the Rules, non-ferrous metals include:
- Aluminium
- Copper
- Zinc
- Their alloys
These metals are widely used in packaging, electrical equipment, furniture, construction materials, appliances and other products.
Who Is Covered Under Non-Ferrous Metals EPR?
The Rules apply to key entities involved in the non-ferrous metal value chain:
Manufacturer: Manufactures specified products, components or spare parts made from non-ferrous metals.
Producer: Any person or entity, irrespective of the selling technique used such as dealer, retailer, e-retailer, who:
i. manufactures and offers to sell products made up of non-ferrous metals and their components or consumables or parts or spares under its own brand, using non-ferrous metals; or
ii. offers to sell under its brand products made up of non-ferrous metals and their components or consumables or parts or spares produced by other manufacturers or suppliers, using nonferrous metals; or
iii. offers to sell imported products made up of non-ferrous metals and their components or consumables or parts or spares under their own brand or original brand, using non-ferrous metals; or
iv. imports used devices or products or scrap of non-ferrous metals.
Collection Agent: Collects scrap of non-ferrous metals.
Refurbisher: Repairs or refurbishes specified products to extend their useful life.
Recycler: Recycles non-ferrous metal scrap and generates eligible EPR Registration certificates.
Bulk Consumer: An entity using at least 1,000 tonnes of specified non-ferrous metal products at any point during a financial year, including e-retailers.
Which Products Are Covered?
The Rules cover 18 categories of specified products:
| S. No. | Product Category |
| 1 | Cans for beverages, aerosols and similar products |
| 2 | Packaging foils for food, pharmaceuticals and similar products |
| 3 | Doors, windows and shutters |
| 4 | Aluminium Composite Panels |
| 5 | Aluminium partitioning, grills and similar products |
| 6 | Utensils, cookware and storage products |
| 7 | Furniture, ladders, handles, doorknobs and hardware |
| 8 | Roofing and ceiling sheets |
| 9 | Motors, pumps and alternators* |
| 10 | Conductor cables, wires and strips* |
| 11 | Sanitary ware and fittings |
| 12 | Electrical fittings* |
| 13 | Aluminium alloy bicycles |
| 14 | Transformers* |
| 15 | Electric generator sets |
| 16 | Centralised air-conditioning plants |
| 17 | Apparel products such as belt buckles, zips and shoes |
| 18 | Toys |
*Certain automobile-grade applications are excluded as specified under the Rules.
Key EPR Obligations
1. Registration
Producers, manufacturers, recyclers, refurbishers and collection agents are required to obtain registration through the CPCB online portal, as applicable.
An entity falling under more than one category may need to register separately for each applicable role.
2. Recycling Targets for Producers
Producers will have to fulfil annual recycling targets.
| 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 target is linked to the quantity of specified products and their prescribed average life.
3. EPR Certificates
Producers can fulfil their recycling obligations through EPR certificates generated by registered recyclers.
The framework also provides for refurbishment certificates for eligible refurbishment activities.
4. Mandatory Use of Recycled Materials
From FY 2028–29, manufacturers must use a minimum percentage of recycled non-ferrous metals in specified products.
| Metal | 2028–29 | 2029–30 | 2030–31 | 2031–32 |
| Aluminium | 5% | 10% | 10% | 10% |
| Copper | 5% | 10% | 15% | 20% |
| Zinc | 5% | 10% | 15% | 25% |
This requirement will help increase the use of secondary raw materials and reduce dependence on virgin resources.
Responsibilities of Bulk Consumers
Bulk consumers must:
- Facilitate collection of non-ferrous metal scrap from their premises.
- Establish collection points, as applicable.
- Hand over scrap only to registered recyclers, refurbishers, producers or collection agents.
Return Filing
Producers and manufacturers are required to submit periodic returns:
31 October: Return/information for April–September.
30 June: Annual information for the previous financial year.
Maintaining accurate production, sales, import, recycling and EPR certificate records will therefore be important for compliance.
Role of CPCB
The Central Pollution Control Board (CPCB) will play a central role in implementing the EPR framework, including:
- Online portal management
- Registration
- EPR certificate mechanism
- Compliance monitoring
- Guidelines and procedures
- Coordination with SPCBs/PCCs
Environmental Compensation
Non-compliance with EPR obligations may attract Environmental Compensation (EC) as prescribed by CPCB.
Payment of environmental compensation does not remove the underlying EPR obligation. Businesses will still be required to fulfil their applicable compliance requirements.
What Should Businesses Do Now?
With the Rules becoming effective from 1 April 2026, affected businesses should start preparing by:
- Checking EPR applicability
- Identifying covered products
- Determining their role as producer/manufacturer/other entity
- Compiling historical production, sales and import data
- Planning CPCB registration
- Identifying registered recycling channels
- Preparing for EPR certificate requirements
- Developing systems for record keeping and return filing
Early preparation can help businesses avoid compliance gaps once the framework becomes operational.
How Can Kar Parivartan Help?
Kar Parivartan provides end-to-end support for Non-Ferrous Metals EPR compliance, including:
- EPR applicability assessment
- CPCB registration support
- Product and entity categorisation
- EPR target assessment
- Documentation support
- EPR certificate management
- Recycler and collection-channel support
- Return filing
- Recycled-content compliance advisory
- Regulatory updates and ongoing compliance management
Get Ready for Non-Ferrous Metals EPR
The introduction of EPR for aluminium, copper and zinc is an important step towards strengthening resource efficiency and circularity in India.
With compliance beginning from 1 April 2026, producers, manufacturers and other covered entities should start assessing their obligations and preparing their compliance systems.
Need support with Non-Ferrous Metals EPR Registration & Compliance?
Connect with Kar Parivartan for end-to-end EPR advisory, registration, documentation, certificate management and compliance support.
FAQs
- When will Non-Ferrous Metals EPR come into effect?
The framework will come into effect from 1 April 2026. - Which metals are covered?
Aluminium, copper, zinc and their alloys. - What is the recycling target?
It starts at 10% in FY 2026–27 and increases to 75% from FY 2032–33 onwards. - Who is a bulk consumer?
An entity using at least 1,000 tonnes of specified non-ferrous metal products at any point during a financial year, including e-retailers. - Is recycled material mandatory?
Yes. Manufacturers will have minimum recycled-material requirements starting from FY 2028–29. - Who regulates Non-Ferrous Metals EPR?
The Central Pollution Control Board (CPCB) is the key implementing authority under the framework.
