India Rolls Out EPR Rules for Non-Ferrous Metals: Aluminium, Copper & Zinc Under Regulation

India EPR Push for Scrap Management of Non-Ferrous Metals such as Aluminium, Copper & Zinc

The Union Ministry of Environment, Forest, and Climate Change has recently issued a notification related to the Hazardous and Other Waste (Management and Transboundary Movement). The Ministry introduced a new Extended Producer Responsibility (EPR) regime. It is due to come into force on 1 April 2026 and is specifically aimed at scrap generated from Non-Ferrous Metals like aluminum, copper, zinc, and their alloys.

This step can make producers responsible for recycling their products and managing them at the end of their life. As mentioned in the notification, the central government thoroughly entertained all kinds of comments for 60 days. The consultation power is provided under the Environment (Protection) Act, 1986, and has finalised these rules as an amendment to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.

Publish Date of Final Notification

The draft notification published on August 14, 2024, contained contextual information that is notably absent from the final notification. A defining element of this regulatory regime is the establishment of an online portal by the Central Pollution Control Board (CPCB). The portal will serve as a one-stop shop for data collection and will administer registration for all of the non-ferrous metal waste ecosystem, including manufacturers, producers, collection agents, refurbishers, and recyclers.

It is positive that the government aims for circularity with so much in mind, but it was clear that there is a huge leap between very high-level environmental analysis and the targets imposed for practical implementation. The minimum recycled material usage targets are surprisingly low: starting at merely 5% in 2028-29, and increasing to 10% for aluminium, 20% for copper, and 25% for zinc by 2031-32.

Schedule-XIII of the Rules provides the minimum recycled material usage targets for new non-ferrous metal products.

Extended Producer Responsibility

EPR is a policy tool that establishes producers' responsibility for the collection, recycling, and disposal of products that enter the market. India introduced the EPR concept when it implemented the E-Waste (Management and Handling) Rules, 2011. The EPR policy has been implemented for plastic waste management and, more recently, metal scrap recycling. A key concern is to provide for the integration of informal recyclers, who have a significant role in India's waste ecosystem but will likely be excluded from it without formal recognition of their role (further, without conscious schemas and/or formalisation initiatives). The government must establish purposeful processes, be it formalization incentives or cooperative arrangements, ensuring their participation over replacement.

Future Considerations

Non-ferrous metals, like aluminium and copper, are vital for societies because they can be recycled without loss of quality. Recycling non-ferrous metals provides the benefits of energy savings, delaying dependence on mining, and embracing circular economy principles.

The new framework recognizes that the industry faces challenges while transitioning from the old regulations related to recycling and recovering metals. However, a foundational road map to permit the sustainable use of metals has been established. The regulations allow a wide range of products, from electrical wire to building materials, to be used and have a robust impact in the marketplace.