EPR for Scrap of Non-Ferrous Metals in India
Ministry of Environment, Forest and Climate Change (MoEFCC) has notified the Hazardous and Other Waste (Management and Transboundary Movement) Amendment Rules, 2025. Through these rules, the Government has introduced Extended Producer Responsibility (EPR) for scrap of non-ferrous metals. Here, non-ferrous metals refer to Aluminium, Copper, Zinc and their alloys.
The objective behind the introduction of this rule is to reduce environmental pollution and conserve natural resources by promoting the proper collection, recycling and environmentally sound management of non-ferrous metal scraps. The extraction, processing and improper disposal of non-ferrous metals may have adverse impacts on the environment.
Since these materials are valuable and recyclable, improper extraction, processing and disposal can result in resource depletion, waste generation, air pollution, water pollution and soil pollution. Therefore, the EPR system has been introduced to create an obligation for systematic collection, recycling and environmentally sound management of non-ferrous metal scrap.
1. What is EPR for Scrap of Non-ferrous metals?
EPR for Scrap of non –ferrous metals defines the responsibility of producer for recycling of scrap of Non-ferrous metals and producer shall meet the EPR target specified in the Schedule-XI in respect of the products listed in Schedule-X. For full filing its obligation the producer may also take the help of third party such as collection agent or dealer. A producer may fulfil its EPR target by purchasing EPR certificates through the online portal form registered recyclers.
2. Which non-ferrous metals are covered under the EPR Rules?
Here Non –ferrous metals means Aluminium or Copper or Zinc or their alloys for the purpose of these Rules
3. Which entities are required to register on the EPR Portal for Scrap of Non-Ferrous Metals?
The following entities are required to register on the EPR Portal for Scrap of Non-ferrous Metals
a) Manufacturer
b) Producer
c) Collection agent
d) Refurbisher
e) Recycler
What are the registration fees applicable to manufacturers, producers, recyclers, refurbishers, and collection agents under the EPR framework for Non-Ferrous Metals?
Flowing registration fee has been prescribed for different person.
| Capacity of Scrap of Non-ferrous metal per Annum (TPA) | Manufacturer (Registration fee) | Recycler (Registration fee) | Refurbished (Registration fee) | Collection agent (Registration fee) |
|---|---|---|---|---|
| <500 | Rs.2500 | Rs.1500 | Rs.1000 | RS.500 |
| 500-1000 | Rs.5000 | Rs.3000 | Rs.2000 | Rs.1000 |
| 1001-5000 | Rs.25000 | Rs.15000 | Rs.10000 | Rs.5000 |
| 5001-10000 | Rs.50000 | Rs.30000 | Rs.20000 | Rs.10000 |
| 10001-20000 | Rs.100000 | Rs.60000 | Rs.40000 | Rs.20000 |
| 20001-50000 | Rs.375000 | Rs.250000 | Rs.150000 | Rs.100000 |
| 50001-100000 | Rs.750000 | Rs.500000 | Rs.300000 | Rs.200000 |
| >100000 | Rs.1000000 | Rs.750000 | Rs.500000 | Rs.300000 |
Who is considered a “Manufacturer” for the purpose of EPR for Scrap of Non-Ferrous Metals?
Manufacturer means a person or an entity or a company which is manufacturing any product or component or spare part of non-ferrous as specified in Schedule-X of the HOWM Amended Rules 2025
Who is considered a producer for the purpose of EPR for Scrap of Non-ferrous Metals?
As per HOWM Amendment Rules 2025, a producer means any person or entity, irrespective of the selling technique used such as, retailer, e-retailer who –
1 Manufacturers 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
2 Offers to sell under its brand products made up of non-ferrous metals and their components or consumables or parts spares produced by other manufacturers or suppliers, using Non-ferrous metals or,
3 Offers to sell imported products made up of non-ferrous metals and their components or consumables or parts or spared under their own brand or original brand, using non-ferrous metals or
4 Who imports used devices or products or scrap of nonferrous metals
What non-ferrous metal products are covered under the HOWM Amendment Rules, 2025?
Following Non-ferrous metal products are listed in Schedule-X of the HOWM amended Rules
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 Products
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
What are the responsibility of a Manufacturer and Producer?
Responsibility of a manufacturer and producer are as follows
| Manufacturer | Producer |
|---|---|
| a. Manufacturer will register itself on portal | I. Every producer will register itself on portal |
| b. It will ensure proper collection of Scrap of Non-ferrous metals and waste generated during the manufacturing process and ensure its recycling or disposal | ii. Producer will file the half yearly return on or before of 31st October of every year and annual return on or before 30th June of following the Financial year to which returns relates |
| c. Manufacturer shall use the domestically recycled materials for the manufacturing of new product as per the Schedule-XIII | III. Producer will create awareness through Media, Publications, advertisement, Posters, or any other means of communication |
| d. Manufacturer shall file half yearly return on or before 31st October of every year and shall also file annual return on or before 30th June following the financial year to which that return relates | iv. Every producer shall have responsibility of recycling of the Scrap of Non-ferrous metals and shall meet the EPR target specified in Schedule-XI |
| e. If Manufacturer having multiple offices, it may file a single annual return Combining information from all the offices | v. Producer will fulfil its EPR target by purchasing EPR certificate through the online portal from registered recyclers. |
What will be the EPR obligation of a producer?
Following recycling obligation has been assigned to producer for Non-ferrous metals as per Schedule-XI of the HOWM Amendment Rules, 2025.
| Year | 2026-27 | 2027-28 | 2028-29 | 2029-30 | 2030-31 | 2031-32 | 2032-33 onwards |
|---|---|---|---|---|---|---|---|
| Recycling obligating in weight | 10% | 10% | 30% | 50% | 50% | 50% | 75% |
Note:-
a. Unit establish after 1st April 2026, EPR obligation will start after two years
b. EPR obligation for importers of used devices or products or scrap shall be 100%of NMF imported
c. Recycling target may be reviewed and increase after the end of Year 2033-2034 and
d. Avg. life of products made of AI or Cu or Z n or their alloys shall be specified by CPCB
Our Approach to EPR Registration?
1
How can BR & Associates assist with EPR registration for Non-Ferrous Metals?
BR & Associates provides end-to-end assistance for EPR registration, including applicability assessment, documentation, application preparation, portal filing, and coordination with the concerned authority.
2
Does BR & Associates assist with documentation and regulatory queries?
Yes. We assist in preparing and reviewing the required documents and information and provide support in responding to observations, deficiencies, and clarification requests raised by the concerned authority.
3
Can BR & Associates support manufacturers, producers, recyclers, refurbishers, and collection agents?
We provide regulatory assistance based on the specific obligations applicable to each category, including registration and ongoing EPR compliance requirements.
Our Experience
BR & Associates has 5+ years of experience in regulatory compliance and has served 1000+ clients across India. Our experience includes assignments for reputed organizations such as Afcons Infrastructure, Electrosteel Castings Ltd., Mitsubishi Heavy Industries Group Companies, ArcelorMittal, and Yatri. We provide end-to-end support in EPR, BIS, Legal Metrology, CDSCO, Ministry NOCs and other regulatory compliances.
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