India Notifies EPR Rules on 18 Products Containing Non-Ferrous Metals 
On July 2, 2025, the Ministry of Environment, Forest and Climate Change (MoEFCC) of India promulgated the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025 (hereinafter “the Rules”). The Rules establish an Extended Producer Responsibility (EPR) framework for 18 products containing non-ferrous metals—aluminium, copper, and zinc. Under this framework, producers and manufacturers are obligated to register, meet recycling targets, use recycled materials, and submit reports. The Rules will come into effect on April 1, 2026.
The following sections outline key definitions and summarize the responsibilities imposed on producers and manufacturers.
Definitions of Terms
| Term | Definition |
|---|---|
| Non-ferrous metals | Aluminium or copper or zinc or their alloys |
| 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. |
| Manufacturer | A person or an entity or a company which is manufacturing any specified product or component or spare part of non-ferrous metals. |
| Bulk consumer | Any entity using at least one thousand tons of non-ferrous metal specified products, at any point of time in the particular financial year, and includes e-retailer. |
| (Specified) Products | Any product made of non-ferrous metals as listed in Schedule-X:
*Definition and scope of each product remains unknown. |
Responsibility 1: Registration (Producer & Manufacturer)
Producers and manufacturers are required to register with the Central Pollution Control Board (CPCB). Registration must be completed through a dedicated online portal, which the CPCB plans to establish within six months. Entities that fall under both definitions of “producer” and “manufacturer” must register as both capacities.
Responsibility 2: Fulfilling Recycling Target (Producer)
Producers are required to meet annual recycling targets based on the quantity of specified products put on the market in previous years. These targets must be achieved each year. CPCB will also determine the average life (X) of each specified product
| Financial Year (Y) | Recycling Target |
|---|---|
| 2026-27
2027-28 |
10% of the quantity of products made of non-ferrous metals in year Y-X, where (X) is the average life of the product |
| 2028-29
2029-30 |
30% of the quantity of products made of non-ferrous metals in year Y-X |
| 2030-31
2031-32 |
50% of the quantity of products made of non-ferrous metals in year Y-X |
| 2032-33 onwards | 75% of the quantity of products made of non-ferrous metals in year Y-X |
The Rules do not explicitly state that recycling targets are to be calculated based on the “quantity placed on the market.” Instead, they refer more generally to “X% of the quantity of designated products,” leaving the basis for calculation currently unclear. However, similar EPR regulations in the past—such as plastic packaging, e-waste and batteries—have used the quantity of products placed on the market as the standard. Therefore, it is presumed that the same approach may apply under these Rules.
To meet recycling targets, producers are not required to conduct recycling themselves — instead, they may purchase “EPR certificates” from authorized recyclers of non-ferrous metals. These certificates are issued in proportion to the amount of non-ferrous metals recycled by the recycler, and are used by producers to offset their own recycling targets.
Alternatively, producers may purchase “refurbish certificates” issued when specified products are refurbished by authorized refurbishers. The purchase of refurbish certificates exempts the corresponding amount from the current year’s recycling target. However, 75% of the exempted amount is added to the recycling target for the year following the extended lifespan (Z) resulting from the refurbishment.
Example:
Specified Product: Motor
Average Life of Motor (X) = 10 years
Extended Life through Repair (Z) = 5 years
Under the Rules, the recycling target for financial year 2025–26 (Y) is calculated as 10% quantity of products made of non-ferrous metals in year Y-X. Thus, 2025-26 (Y) – 10 years (X) = financial year of 2015–16.
The recycling target for 2025-26 is therefore 10% of the quantity of motors placed on the market in 2015-16.
Assuming that 800 metric tons of motors were placed on the market in 2015-16, the recycling target for 2025-26 would be 10% of that amount, which is 80 metric tons. Accordingly, the producer would be required to purchase EPR certificates covering 80 metric tons for the financial year of 2025-26.
If the producer instead purchases 80 metric tons’ worth of refurbish certificates, the 2025-26 recycling target would be waived by that amount. However, 75% of the waived amount — i.e., 60 metric tons — would be added to the recycling target for the year following the extended lifespan of five years (Z), which is financial year 2030-31.
Responsibility 3: Use of Recycled Materials (Manufacturer)
Beginning in financial year 2028-29, manufacturers will be required to incorporate a certain proportion of recycled non-ferrous metal materials (hereinafter “recycled materials”) into the specified products they manufacture. The recycled materials must also be sourced from materials recycled within India.
The minimum use of recycled materials during each financial year are shown in the table below. These percentages represent the proportion of recycled materials relative to the total amount of each non-ferrous metal contained in the product.
| Type of Metal | Minimum use of recycled materials | |||
|---|---|---|---|---|
| 2028-29 | 2029-30 | 2030-31 | 2031-32 | |
| Aluminium | 5% | 10% | 10% | 10% |
| Copper | 5% | 10% | 15% | 20% |
| Zinc | 5% | 10% | 15% | 25% |
Responsibility 4: Filing Returns (Producer & Manufacturer)
Producers and manufacturers are required to submit returns according to the following schedule. The specific reporting contents have not yet been defined.
- By October 31 of each financial year: Submit information covering the first half of the current financial year (April–September).
- By June 30 of each financial year: Submit information covering the previous financial year (April of the previous year to March of the current year).
Other Provisions (Obligations of Bulk Consumers)
In addition to producers and manufacturers, the Rules impose the following responsibilities on bulk consumers:
- Set up collection points to facilitate collection agents in the collection and transportation of scrap of non-ferrous metals from their premises
- Ensure that scrap of non-ferrous metals generated by them shall be handed over only to registered recyclers or refurbishers or producers or collection agents
Download the Rules from link below:
https://egazette.gov.in/writeReadData/2025/264308.pdf
EnviX Comment
The draft version of the Rules was released in August 2024. In the finalized Rules, definitions of terms have been clarified, certain products used in automobiles have been exempted, and the enforcement date has been postponed from April 2025 to April 2026. However, several issues and uncertainties remain under the current provisions:
- Scope of Regulated Entities: In past EPR rules — such as those for plastic packaging, e-waste and batteries — regulated entities were limited to those located within India, while foreign companies are excluded. This point was not explicitly stated in previous rules, it is presumed that the same exclusion of foreign entities also applies under the latest Rules.
- Recycling Target Calculation Method (1): The basis for calculating recycling targets is not clearly defined. This article is taking the position which assumes that “quantity placed on the market” is most likely, but other possibilities such as “quantity procured” could also be possible, which will significantly affect the final number of recycling targets.
- Recycling Target Calculation Method (2): It remains unclear whether recycling targets will be calculated by each producer based on the actual content of aluminium, copper, and zinc in each product, or whether the CPCB will establish a uniform estimate for each product which applies to all companies and all products. For reference, under the E-Waste (Management) Rules, 2022, standard content values for gold, aluminium, copper, and iron are pre-defined for each product category, which applies to all products from all companies regardless of their actual content. As a result, even when a product’s actual usage is lower than the standard, the company will be required to meet higher recycling targets than it actually should.
- Use of Recycled Materials: Manufacturers are required to incorporate a certain percentage of recycled materials into products. However, if the scope of regulated entities is limited to domestic manufacturers—as with other provisions—then imported products may be exempt from this obligation. (Ultimately, this will depend on the authorities’ interpretation.) Moreover, there are currently no provisions requiring importers to purchase “recycled materials certificates” in lieu of direct usage. As a result, imported products may end up being subject to fewer legal obligations than products manufactured domestically.
