Now, a new stream of EPR is being introduced for non-ferrous metals. Non-ferrous metals are metals that do not contain iron and are therefore non-magnetic. This makes them harder to sort in the recycling process.

EPR for non-ferrous metals has been introduced through the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025. This new requirement will take effect from 1 April 2026, giving producers time to prepare.

Who is obligated

These rules will apply to any business, regardless of how it sells products, if it: manufactures and sells goods under its own brand; sells goods made by others but rebranded, or imports goods under either its own or the original brand.

To fall within scope, the product must contain non-ferrous metals such as aluminium, copper, or zinc, either as the main material or within components, consumables, or spare parts.

What is in scope

The regulations set out 18 categories of products containing non-ferrous metals. Examples include:

• Beverage cans, aerosol cans, and similar containers

• Packaging foils for food, pharmaceuticals, and other goods

• Conductor cables, wires, and strips (excluding automobile-grade)

• Electric generator sets

• Apparel items such as belt buckles, zips, and shoe components

• Toys with non-ferrous metal parts

How to comply

In-scope producers must meet annual recycling targets set in the legislation. This will require registration with the Central Pollution Control Board (CPCB), submission of half-yearly and annual reports, and the purchase of recycling certificates from CPCB-registered recyclers. Producers may also work with a Producer Responsibility Organisation (PRO) to manage these activities on their behalf.

Recycled content

Beginning in 2028, all covered products containing non-ferrous metals will be required to include a minimum of 5% recycled content. This baseline requirement marks the first step in a phased approach to increasing the use of recycled materials.

The thresholds will rise over the following years. By the 2031–2032 compliance period:

• Aluminium content must contain at least 10% recycled material.

• Copper content must contain at least 20% recycled material.

• Zinc content must contain at least 25% recycled material.

Next steps

The CPCB will now develop the online portal where producers can register. In the meantime, businesses should assess which of their products fall within scope, review supply chains, and put systems in place to meet future targets.

For further guidance on this EPR stream, or on meeting EPR requirements worldwide, please get in touch with our team.

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