AN Overview of EPR for Non-Ferrous Metals
The EPR for non-ferrous metals, under the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025, came into effect from April 1, 2026. Before its implementation, the introduction of the framework followed a phased regulatory process spanning nearly two years. MoEFCC proposed a draft amendment on August 14, 2024, inviting objections/suggestions within 60 days. The Central Government finalized the amendment on July 1, 2025, under the Environment (Protection) Act, 1986, adding Chapter VIII under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
The EPR framework for non-ferrous metals covers aluminium, copper, zinc, and their alloys. It has a total of 18 products listed under Schedule X, EPR recycling targets timeline under Schedule XI, products permitted for refurbishing under Schedule XII, and the minimum recycled content requirements under Schedule XIII. Registering on the CPCB portal helps to monitor EPR compliance to avoid penalties and environmental compensation. Plus, the recycling target is expected to increase from 10% in FY2026-27 to 75% by 2032-2033.
The Extended Producer Responsibility for Non-Ferrous Metals includes manufacturers, producers, recyclers, collection agents, and refurbishers. These stakeholders must register online on the CPCB portal to obtain an EPR certificate for non-ferrous metals. But what if you get stuck in between and fail to complete the registration on the CPCB portal? Consult with EPR experts from India's top expert consultancy, Enterclimate, for end-to-end assistance in EPR for non-ferrous metals.
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Secure Penalty ProtectionEPR for Non-Ferrous Metals: Understand Non-Ferrous Metals & Significance of EPR Rules
The EPR for non-ferrous metals regulations is defined under the Hazardous and Other Wastes (Management and Transboundary Movement) (Amendment), 2025. It came into effect on April 1, 2026.
Non-ferrous metals are aluminium, copper, zinc, and their alloys. They do not contain any iron compositions.
The EPR regulations are essential for several reasons:
- Sustainable management of products from production to end-of-life disposal.
- Promotes the recycling and reuse of non-ferrous metals to conserve resources.
- Stakeholders involved in producing, selling, importing, handling, or recycling non-ferrous metal-based products must manage the disposal of the waste generated at the end of life for the product.
What is the Applicability of EPR for Non-Ferrous Metals?
The eligible entities in EPR for non-ferrous metals are as follows:
- Producers
- Manufacturers
- Recyclers
- Refurbishers
- Collection Agents
What are the Documents Required for EPR Certificate for Non-Ferrous Metals?
Applicants registering on the CPCB portal to obtain an EPR certificate for non-ferrous metals must have a complete list of documents before proceeding with the application. Look below to know the documents required for registration of the EPR certificate for non-ferrous metals.
- Application Form 1 on CPCB Portal
- Certificate of Incorporation/ Business Registration proof
- PAN card of the applicant/company
- GST registration certificate
- Business Address proof
- Details of Products from Non-Ferrous Metals
- Collection and Recycling Plan
- Waste Management Plan
- Financial Statements
- Declaration of Compliance
- Agreement with Authorized Recyclers
- Authorization Letter (filed by consultant)
- Environmental Compliance documents (if applicable)
- Other relevant details requested by CPCB
- Digital Signature Certificate (DSC)
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Book a 1:1 Virtual MeetingWhat is the Procedure to Obtain EPR Certificate for Non-Ferrous Metals?
You must follow a step-by-step process to obtain the EPR certificate for non-ferrous metals. The eligible entities must comply with the guidelines of the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025.
Step 1: Determine Applicability
The initial step for the eligible entities is to identify whether they fall under the EPR framework for non-ferrous metals. It helps to assess their Extended Producer Responsibility for non-ferrous metals.
Step 2: Registration on CPCB Portal
The eligible entities must register on the CPCB portal to secure EPR certification for non-ferrous metals. It is required to register separately under each category.
Step 3: Submit Documents
Applicants must submit the mandatory documents to upload on the CPCB portal for registration and verification.
Step 4: Calculate EPR Targets
Upon submission of documents, producers must know EPR obligations and applicable recycling targets under Schedule XI of the EPR framework for non-ferrous metals.
Step 5: Collection and Channelization of Scrap
The end-of-life products and scrap from non-ferrous metals are collected through the authorized channels and transferred to the registered recyclers for compliant processing.
Step 6: Recycling through Registered Recyclers
Registered recyclers convert the collected scrap in accordance with prescribed standards. The recycling activity serves as a basis for EPR certificate generation and contributes to meeting the recycling targets.
Step 7: Procuring EPR Certificates
Registered recyclers generate an EPR certificate corresponding to the quantity of waste recycled. Producers procure the EPR certificates to meet the obligations under the compliance mechanism.
Step 8: Return Filing
Registered entities must submit half-yearly and quarterly returns through the CPCB portal. The return filing provides collection, recycling activities, certificate transactions, and compliance status details.
Step 9: Maintain Record and Compliance
The eligible entities must ensure record-keeping linked to recycling, certificate procurement, and return filing. Proper documentation helps in regulatory compliance to minimize environmental compensation and penalties.
EPR Certificate for Non-Ferrous Metals in India: How to Generate?
The CPCB issues an EPR certificate through the portal in favour of registered recyclers for the quantity of non-ferrous metal recovered after recycling. The CPCB is responsible for calculating the quantity to generate an EPR certificate for non-ferrous metals in India using a prescribed formula, which is,
QEPR = Qp X Cf
- QEPR refers to the quantity eligible to procure the EPR certificate
- Qp refers to the quantity of the end product obtained after recycling
- Cf is the conversion factor prescribed by CPCB
What are the ways to Identify the Original EPR Certificate?
To determine if the EPR certificate you've received is original, look for the following things:
- Year of certificate
- End product code
- Recycler code
- Unique identification code
- Certificate validity period
The unique identification code and validity must be in the denominations of 100 kg, 200 kg, 400 kg, 1000 kg, and 10,000 kg, or any number fixed by the CPCB upon the approval of the Steering Committee under Rule 63.
Transaction of EPR certificates under EPR for Non-Ferrous Metals
The extended producer responsibility for non-ferrous metals permits producers to achieve recycling obligations through the CPCB portal. The purchase limit for EPR certificates is up to-
- Current year liability
- Any unfulfilled liability carried forward from the previous year
- Additional 10% of the current year's liability
- The EPR targets must be fulfilled every half-year.
- EPR certificates automatically adjust and are extinguished after utilization.
- Refurbishing certificates allows the temporary deferral of EPR obligations.
- All transactions are digitally recorded on the CPCB portal.
- The government may establish dedicated trading platforms.
- CPCB prescribes the minimum and maximum price bands for certificate trading.
Central Pollution Control Board: CPCB Portal in EPR Framework for Non-Ferrous Metals
The Central Pollution Control Board (CPCB) is a central feature of the EPR framework for non-ferrous metals. It is an online portal, regulated by CPCB within 6 months with effect from the date of enforcing the Hazardous and Other Wastes (Management and Transboundary Movement) (Amendment) Rules, 2025.
It requires stakeholders (manufacturers, recyclers, producers, refurbishers, collection agents, and bulk consumers) to register non-ferrous metals (aluminium, zinc, copper or their alloys) to ensure EPR compliance.
The CPCB portal serves as a unified place for the stakeholders to manage registration of non-ferrous metals, help in filing half-yearly and annual returns, collect data, fulfil EPR obligations, and track every transaction linked to the EPR credits. It aligns with the SPCB to design framework guidelines, conduct inspections, and awareness programs.
India's EPR Framework for Non-Ferrous Metals
The regulations of EPR for non-ferrous metals are effective from April 1, 2026. The CPCB portal will be operational within six months, right after the EPR rules come into effect. The BIS Standards are revised within six months.
The EPR framework for non-ferrous metals includes key institutions and stakeholders, which are CPCB, SPCB, Bureau of Indian Standards, Bulk Consumers, and the Steering Committee.
Products under the Schedule X of EPR Framework for Non-Ferrous Metals
Here is a list of industrial and consumer products made from non-ferrous metals, such as aluminium, copper, and zinc under the Schedule X of the EPR framework for non-ferrous metals. See below:
- Cans
- Packaging Foils
- Doors, Windows, Shutters
- Aluminium Composite Panel
- Aluminium positioning, grills
- Utensils consist of Cookware, Canisters, and Storage
- Furniture tables, chairs, benches, ladders, doorknobs, handles, and hardware
- Roofing and Ceiling Sheets
- Motors, pumps, alternators (other than automobile grade)
- Conductor cables and Wires, Strips (other than automobile grade)
- Sanitary ware and fittings
- Electrical fittings (other than automobile grade)
- Aluminium Alloy Bicycle
- Transformer (other than automobile grade)
- Electric Generator Sets
- Centralized air conditioning plants
- Apparel products (Belt Buckles, Zip, Shoes)
- Toys
Extended Producer Responsibility Obligation of Producers Under Schedule XI
Under Schedule XI of the EPR framework for non-ferrous metals, the obligations of producers are assessed from FY2026 to FY2033 and onwards. For more clarity, look at the table given below:
| S. No | EPR Recycling Targets for Producers Under Schedule XI |
|---|---|
| FY2026-27 | 10% |
| FY2027-28 | 10% |
| FY2028-29 | 30% |
| FY2029-30 | 30% |
| FY2030-31 | 50% |
| FY2031-32 | 50% |
| FY2032-33 | 75% |
Units established after April 1, 2026, shall start complying with EPR obligations after two years, following the prescribed targets in the table.
The EPR obligation for importers of used devices or products or scrap of non-ferrous metals in the year (Y) must be 100% of the non-ferrous metals imported in the year (Y-1).
Note:
- The recycling targets from FY2026 to FY2033 and onwards are calculated as a percentage of the products' quantity made from non-ferrous metals introduced in the market in the year (Y-X), where "X" represents the average life of the product.
- Recycling targets might increase after the review, after FY2033-34 ends.
- The average number of products made of non-ferrous metals, such as aluminium, copper, zinc, or their alloys, shall be specified by the CPCB authority.
- Targets begin at 10% and rise to 75%, making early compliance planning essential.
Percentage for Minimum Use of Recycled Materials in New Products (Non-Ferrous Metals) Under Schedule XIII
See the table given below to know the percentage for the minimum quantity of recycled materials in making new products, based on non-ferrous metals.
| TYPE OF METAL | FY2028-FY2029 | FY2029-FY2030 | FY2030-FY2031 | FY2031-FY2032 |
|---|---|---|---|---|
| Aluminium | 5% | 10% | 10% | 10% |
| Copper | 5% | 10% | 15% | 20% |
| Zinc | 5% | 10% | 15% | 25% |
Extended Producer Responsibility for Non-ferrous Metals: Responsibility of Stakeholders
Under the Extended Producer Responsibility for non-ferrous metals in India, there are five stakeholders. Continue reading to understand the responsibility of each stakeholder separately.
PRODUCER:
- The producer must be CPCB-registered and file half-yearly and annual returns on time.
- The entity is responsible for raising awareness using media, training programs, and other sources.
- The entity must ensure environmentally compliant processing of non-ferrous metal scrap after its collection and recycling.
MANUFACTURER
- The entity must be legally registered on the CPCB portal.
- Collect the scrap and waste during the manufacturing of the product to ensure sustainable disposal.
- As per Schedule XIII in the framework of EPR for non-ferrous metals, the entity must utilize the recycled materials to convert into new products.
- The entity must file half-yearly and annual returns as prescribed on the portal for the current FY.
- In case of more than one branch for the office, the manufacturer must provide all details in a single annual return.
- Manufacturers must ensure to procure the recycled materials from CPCB-registered recyclers for fulfilment of EPR obligations.
REFURBISHER
- Each refurbisher must be CPCB-certified and ensure proper collection of scrap or used non-ferrous metals listed under Schedule XII.
- Ensure timely filing of the half-yearly and annual returns, along with ensuring the compliant refurbishing of the non-ferrous metals listed under the Schedule XII.
- The quantity of waste generated during refurbishment must be transferred to the disposal facility.
RECYCLER
- The entity must be CPCB-verified and ensure the facility and recycling process prescribed in the EPR framework for the non-ferrous metals.
- The entity must ensure eco-friendly transport, storage, and recycling of non-ferrous metal scrap.
- The entity is responsible for the proper disposal of the scrap from non-ferrous metal products.
- The entity must timely fill the half-yearly and annual returns on the CPCB portal.
- The entity must maintain records for the quantity of recycled, unrecycled, or undisposed scrap of non-ferrous metal on the CPCB portal.
COLLECTION AGENT
The agent must be CPCB-certified and collect the scrap of the end product made from non-ferrous metals from manufacturers, producers, and bulk consumers. The end product scrap must be sent to the registered recycler on the CPCB portal.
Extended Producer Responsibility of Producers for Scrap of Non-Ferrous Metals
Look for the key pointers below to understand the Extended Producer Responsibility of producers for scrap of non-ferrous metals.
- The entity is responsible for ensuring that scrap generated from products under Schedule X is recycled, and EPR targets for products under Schedule XI are achieved.
- If a producer coordinates with any third party in the collection and channelization of non-ferrous metal scrap, ensuring compliance is their responsibility.
- CPCB provides a reduction factor to account for operational loss in recycling.
- Producers meet the EPR recycling targets by purchasing the EPR certificates for non-ferrous metals, generated by CPCB-registered recyclers through the portal.
- The generated certificate of EPR for non-ferrous metals by producers must be audited by the CPCB authority.
Environmental Compensation in Non-Compliant EPR for Non-Ferrous Metals
There are several reasons for environmental compensation in non-compliant EPR for non-ferrous metals. Look at the key pointers given below:
- Any entity failing to fulfil the EPR recycling targets will incur environmental compensation.
- Any entity that fulfils the sufficient recycling targets within the stipulated duration will be refunded for the remaining environmental compensation.
- The collected environmental compensation funds will be utilized in restoring the landfill dumpsites.
- Repeated violations result in strict penalties.
- CPCB monitors all the payments of environmental compensation and ensures they are utilized to restore polluted sites.
What is the Validity of the EPR Certificate for Non-Ferrous Metals?
An EPR certificate for non-ferrous metals is valid for two years, from the end of the financial year in which it was generated. If the certificate is not in use for a long time, it will expire automatically.
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Free 30-min Strategy CallWhy Trust Enterclimate to Secure a Certificate of EPR for Non-Ferrous Metals?
Enterclimate has always been India's No.1 consultancy with top industry experts proficient in EPR compliance. With its PAN-India reach, until now, the consultancy has assisted 500+ businesses involved in non-ferrous metals that require an EPR certificate. But without any clear guidance or clarity, everything is clueless, which is why Enterclimate's in-house EPR experts are ready to assist you for EPR for non-ferrous metals. Now that you know about us, it's also essential to know what we've achieved.
From CPCB certification to environmental auditing, ESG reporting, EPR target fulfilment, environmental and social impact assessment, we handle everything. Given below are the reasons why we are the first choice for EPR for non-ferrous metals-
- 500+ EPR and environmental compliance clients served across India
- PAN India presence
- 300+ Verified recyclers
- 1,000+ EPR filings completed
- 99% document accuracy
- 97% first-time submission approvals
- Zero missed filing deadlines/ compliance notices
- 100% traceable EPR certificate
- 100% recycler verification support
- Single point compliance management
- Real-time target tracking support
FAQs on EPR for Non-Ferrous Metals
The EPR framework for non-ferrous metals came into effect on April 1, 2026.
The Central Pollution Control Board (CPCB) is a central point for EPR registration and compliance.
EPR for non-ferrous metals is required for environmental compliance, to meet recycling targets, ensure pollution control, facilitate import authorization, avoid penalties, enable sustainable reporting, promote the circular economy, and the growth of the businesses.
Producers, manufacturers, collection agents, recyclers, and refurbishers must fulfil the extended producer responsibility for non-ferrous metals in India.
The mandatory documents include Form 1, the Incorporation certificate, PAN, GST no., company address proof, details of recycle/non-recycled/non-refurbished status for non-ferrous products, waste management plan, collection and recycling plan, and more.
The extended producer responsibility for non-ferrous metal in India involves CPCB portal registration, target assessment, documentation, recycling, generating the EPR certificate and return filing.
The bulk consumers are responsible for setting up collection points for the collection agents to collect and transport scrap of non-ferrous metals from the facility. Also, they ensure the collected scrap materials are handed over only to the CPCB-certified recyclers.
EPR for non-ferrous metals is important for the following reasons:
- Energy and resource conservation
- Less reliance on importing non-ferrous metals
- Eliminates non-registered/third-party recyclers providing fake EPR certificates.
- Regulatory and environmental compliance is retained.
- Easy to fulfil obligations for the current FY and obtain the EPR certificate.
The benefits of the non-ferrous metals EPR framework include low pollution, less compliance burden, recycling scrap to conserve resources, and improving brand reputation.
