India’s new extended producer responsibility (EPR) regime for scrap of non-ferrous metals is facing implementation concerns ahead of the October deadlines, with industry pointing to the pending operationalisation of the Central Pollution Control Board’s (CPCB’s) compliance portal and the absence of a key parameter needed to calculate recycling obligations.
The rules covering aluminium, copper, zinc and their alloys came into force on April 1, 2026. Under Rule 50(3) of the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025, the CPCB is required to make the online portal functional within six months of commencement, making October 1 the deadline.
The portal is meant to handle registration of manufacturers, producers, collection agents, refurbishers and recyclers, filing of returns, and generation and transaction of EPR certificates.
However, industry sources said the CPCB’s Common EPR Portal for non-ferrous metals is still not operational. The portal is otherwise meant to be used to generate EPR certificates.
“EPR obligations have been accruing since April with no lawful route to register or discharge them,” an industry source said, referring to the provisions requiring covered entities to register and producers to meet their EPR targets.
The rules require producers and other covered entities to register online and prohibit entities covered under the registration provisions from carrying out business without registration.
Another concern relates to the calculation of the EPR target. Schedule XI sets the target for 2026-27 at 10 per cent of the quantity of products made of non-ferrous metals in the relevant earlier year, with the applicable year determined using the average life of the product.
The rules state that the average life of products made of aluminium, copper, zinc and their alloys “shall be specified by CPCB”.
Sources said this parameter was yet to be published, raising concerns over how obligated companies can determine their exact liability.
The first half-yearly returns under the rules are due by October 31, shortly after the October 1 deadline for the portal to become functional.
The rules, however, provide a potential mechanism for addressing implementation issues. Under Rule 50(4), the central government can, through an order, relax the filing period for returns by up to nine months if it considers this necessary in the public interest or for effective implementation.
The CPCB is also responsible for issuing guidelines and standard operating procedures covering registration, EPR certificate generation and fulfilment, return filing and other aspects of the regime.
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