Aluminium, copper, zinc and their alloys · Chapter VIII, Hazardous and Other Wastes
(Management and Transboundary Movement) Rules, 2016, as inserted by G.S.R. 438(E)
dated 1 July 2025 · in force from 1 April 2026.
Update: the Rule 50(3) portal deadline has passed, unmet.
Rule 50(3) required CPCB's non-ferrous EPR portal to be functional within six months of
commencement — by 1 October 2026. That date has now passed. The non-ferrous module remains
non-operational, independently confirmed in
Business Standard, 20 September 2026.
Rule 45(2) requires registration to be made online on that portal; Rule 45(5) bars carrying on
business without registration; Rule 46(3) permits fulfilment only by purchasing certificates
through it. None of this is currently possible.
The first half-yearly return falls due 31 October 2026
under rules 51(4), 52(2), 53(2), 54(2) and 55(5) — a statutory filing deadline now
approaching against a portal that still does not exist.
Rule 50(4) allows the Central Government to relax filing periods by up to nine months, but that
requires an order; none has been observed.
Read this before you use the number.
Schedule XI sets your target as a percentage of what you placed on the market in year
Y − X, where X is the average life of the product. Note 2 to Schedule XI
says average life “shall be specified by the Central Pollution Control Board.”
CPCB has not published those values. Nobody in India can compute an exact
non-ferrous EPR obligation today. This tool gives you a defensible range and names
what you are blocked on. Treat any vendor quoting you a single precise tonnage with suspicion.
1. Who you are
Rule 44(o). If you do both, you run both calculations — see the note below the result.
The year whose obligation you are computing.
2. Product and average life
You are supplying X because CPCB has not. Use your own warranty data, replacement-cycle
data or industry convention, and keep the two numbers honestly far apart. The width of the
output range is the point — it is your evidence of what the regulator still owes the market.
3. Quantity placed on market
Weight of non-ferrous metal in Schedule X products you placed on the Indian market,
in tonnes, for each candidate base year. Only the years your X range actually touches are shown.
Base financial year
Implied by X =
Tonnes placed on market
Your obligation
Recycling target for , by weight
Item
Low
High
Certificates come in fixed lump sizes.
Rule 47(3) issues EPR certificates only in denominations of 100, 200, 500, 1,000 and 10,000 kg.
You cannot buy an exact tonnage — you round up. The rounded figures are in the table above.
Purchase cadence is contested.
Rule 49(2) in English says purchase proportionately half-yearly. The Hindi text of the
same rule says तिमाही — quarterly — while the same notification uses
अर्धवार्षिक (half-yearly) correctly elsewhere for return deadlines. Until CPCB clarifies,
the conservative position is to plan quarterly proportionate purchases.
What you are blocked on
Seven parameters in Chapter VIII are delegated to CPCB. Three of them block computation outright.
Parameter
Source
What it blocks
Average life (X)
Sch. XI Note 2
The base year. Without it there is no calculation, only a range.
Conversion factor (Cf)
Rule 47(1)
How much certificate a recycler can issue per tonne of output.
Environmental compensation rate
Rule 60(1)
Cost of shortfall — and the certificate price band, fixed at 30–100% of it.
Operational loss factor
Rule 46(2)
Reduction applied to your gross target.
Refurbishing deferral duration
Rules 48(2), 49(4)
When the deferred 75% lands back on you.
Registration & maintenance fees
Rule 45(8)
Cost of compliance.
Return forms and SOPs
Rule 57(1)(c)–(d)
Which data you must be capturing all year.
Other things that bite
The target triples in FY 2028-29. 10% → 10% → 30% → 30% → 50% → 50% → 75%. It is not a gradual ramp.
Shortfall does not go away. Rule 60(4): paying environmental compensation does not discharge the target. It carries forward up to three years, stacking on top of each new year's obligation.
Register once per role. Rule 45(4): producer and recycler are separate registrations. Rule 45(6): a registered entity may not transact with an unregistered one.
The lower figure wins. Rule 46(4): where your numbers and your recycler's differ on the portal, CPCB counts the smaller one toward your fulfilment.
Refurbishing defers, it does not erase. Rules 48(2)–(3): deferred quantity returns at 75% when the extended life ends. That is a dated multi-year ledger, not an annual number.
Purchase is capped. Rule 49(1): current-year liability + prior-year backlog + 10% headroom. You cannot stockpile cheap certificates.
Certificates expire. Rule 47(2): two years from the end of the FY in which generated.