India's new extended producer responsibility (EPR) regime for non-ferrous metals is encountering significant implementation challenges ahead of critical deadlines. According to reports from Business Standard, the Central Pollution Control Board's (CPCB) Common EPR Portal for non-ferrous metals remains non-operational despite the April 1, 2026 commencement date. Under Rule 50(3) of the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025, the CPCB was required to make the online portal functional within six months of commencement, making October 1 the mandatory deadline. The portal is designed to handle registration of manufacturers, producers, collection agents, refurbishers and recyclers, filing of returns, and generation and transaction of EPR certificates.
The operational delays are creating practical challenges for industry compliance. As reported by Business Standard, EPR obligations have been accruing since April with no lawful route to register or discharge them. 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. This creates a situation where companies face obligations under the new regime but lack the necessary infrastructure to fulfill them legally.
A critical implementation concern involves the calculation methodology for EPR targets. According to Business Standard reports, 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. However, the rules state that the average life of products made of aluminium, copper, zinc and their alloys 'shall be specified by CPCB', which has not been published. This parameter absence raises concerns over how obligated companies can determine their exact liability for recycling obligations.
The timing of these implementation challenges is particularly challenging given upcoming compliance requirements. As reported by Business Standard, 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 provide a potential mechanism for addressing implementation issues through Rule 50(4), which allows the central government to relax filing periods by up to nine months if necessary in the public interest or for effective implementation. The CPCB is also responsible for issuing comprehensive guidelines covering registration, EPR certificate generation and fulfillment, return filing and other aspects of the regime.
