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India’s non-ferrous metals recycling industry entered a new regulatory phase on April 1 with the rollout of the Extended Producer Responsibility (EPR) framework for aluminium, copper, and zinc. The move brings these materials into a structured circularity framework for the first time—focusing less on creating recycling systems and more on formalizing and tracking an already active but fragmented ecosystem. 

Unlike plastics and e-waste—where Extended Producer Responsibility (EPR), introduced in 2016 and 2011 respectively, led to the creation of new recovery systems—the non-ferrous sector has long operated through a mix of formal recyclers, informal collection networks, and global scrap flows. What changes now is the shift from a market-led system to one increasingly defined by compliance, registrations, traceability mechanisms, and evolving reporting structures. 

Formalising an existing ecosystem 

At the centre of this transition is a phased target system. Recycling obligations begin at relatively low levels before scaling up sharply over the coming years, reflecting a calibrated regulatory approach. But for the industry, a lower starting point does not necessarily mean lower pressure. 

Dhawal Shah, Managing Partner, Metco Ventures, says the phased approach is a practical way to introduce a new framework like this.

“It recognises that both industry and regulators need time to build systems, align realities and understand material flows more clearly,” he says. At the same time, he cautions that it should not be seen as a period of relaxed compliance.  

In his view, the initial phase is critical, as definitions, scope, and methodologies are tested in real conditions. He notes that recent stakeholder discussions have already shown that aspects such as product lifespan, conversion factors, and compositions under Schedule X are still evolving. While the intent of a gradual ramp-up is sound, early clarity, he believes, will be key to ensuring that compliance remains meaningful and does not become misaligned as targets increase. 

"The industry is actively engaging and preparing for implementation, but readiness remains uneven because certain aspects of the framework are still unclear," states Shah. He raises concerns over the applicability of EPR obligations on imported scrap, the treatment of attachments in imported scrap streams, and the possibility of double obligations being assigned to the same material. There is also limited clarity, he adds, on portal mechanisms, registration processes, conversion factors, and average end-of-life assumptions. "The industry believes implementation and operationalization of the proposed EPR portal should be deferred until key issues and stakeholder concerns are addressed," he informs. 

These concerns are not new, reflecting patterns seen across earlier EPR rollouts. What ultimately shapes outcomes, however, is the speed and effectiveness with which the system moves from policy to practice. 

Offering a ground-level view of how this transition typically unfolds,  

Saurabh Shah, Managing Director,Landbell GreenForest Solutions, which offers EPR and waste management services, points out that while India already has significant recycling capacity for non-ferrous metals, much of which has operated outside a formal EPR structure. Real visibility, he explains, begins only once the CPCB portal becomes operational, as recyclers and producers start registering and reporting within a unified system. Based on past experience, this process can take a few months to over a year, although he expects the non-ferrous framework to move faster given its alignment with existing EPR models. 

Investment signals—and policy friction 

Gaps in clarity extend beyond compliance—they also shape how the market interprets EPR as an investment signal. 

One of the key expectations from the framework is that it will unlock investments in formal recycling infrastructure, collection systems, and technology upgrades. Dhawal Shah believes that investmentpotential exists, but remains closely tied to policy clarity. EPR can drive investment, particularly in formal recycling and processing capacity, he says, but investors typically look for clearly identifiedobligated entities and predictable compliance costs. Concerns such as dual obligations on the same material stream and ambiguity around imported scrap may create near-term uncertainty. If these are addressed, the framework could become a strong driver for scaling up India’s recycling infrastructure. 

Saurabh Shah echoes the sentiment, noting that EPR frameworks in other waste streams have consistently led to an increase in recycling capacity once compliance systems become operational. As businesses begin to see economic value in formal participation, investments tend to follow. In the case of non-ferrous metals—where intrinsic material value is already high—he expects this transition to become visible on the ground, even though the sector is already relatively efficient in recovering material. 

Balancing imports and domestic recovery 

The question of imported scrap remains central to how the framework will evolve. India continues to rely significantly on overseas material as a secondary raw material input, complicating the push towards domestic circularity. 

Dhawal Shah says EPR can play a role in improving domestic scrap collection and recovery over time, but notes that current consumption patterns and historical material use mean domestic scrap availability will remain limited in the near to medium term. Imported non-ferrous scrap, therefore, continues to play a critical role in supporting manufacturing and conserving energy. He also argues that EPR should not disincentivize these flows by imposing obligations on scrap inputs, pointing out that globally, EPR regimes are typically applied to finished goods placed in the market. 

Adding to this, Saurabh Shah suggests that a more organized domestic recycling ecosystem could gradually reduce dependence on imports. By strengthening linkages between producers and recyclers, EPR can help create a more stable and predictable supply base—an advantage in a market increasingly exposed to geopolitical and price volatility. 

Traceability, formalization, and structural limits 

At a structural level, the framework attempts to address long-standing inefficiencies in the non-ferrous recycling ecosystem—particularly fragmentation, informality, and lack of traceability. 

"EPR is a step in the right direction, and the recycling industry fully supports it, as it can bring greater accountability, improve traceability, and gradually move the ecosystem towards more formal and organized operations," says Dhawal Shah. At the same time, he underlines that the sector remains complex, involving a large informal segment, highly fragmented scrap flows, and materials that are often mixed and non-uniform in nature. Any framework, he says, needs to remain flexible enough to reflect these realities. One of the key concerns being discussed is how obligations are assigned across the value chain, as getting this right will determine whether the framework drives outcomes without creating avoidable compliance complexity. He also emphasizes the need to keep the system practical and implementable, particularly for smaller players who form an integral part of the ecosystem. 

For Saurabh Shah, traceability sits at the heart of the transition. Even bringing recyclers and producers onto a formal registry, he notes, marks a significant shift for a sector that has long operatedinformally. While concerns around paper trading and weak auditing—seen in other EPR regimes—are valid, he expects systems to mature over time, improving compliance integrity. 

He also highlights an often-overlooked element of the framework: refurbishment. By enabling repair and reuse across a defined list of products, EPR allows producers to extend compliance timelines in line with product lifecycles—broadening the focus from recycling alone to overall resource efficiency. 

Execution will define outcome 

The phased targets under the new EPR framework, notes Sandeep Jain, immediate past president of BME, vice chairman of the Indian Copper Development Centre, and Managing Director of Laurel Wires, reflect policy realism rather than diluted intent. “Industry is not reading this as a low-pressure phase,” he suggests, but as a transition window to build systems ahead of significantly steeper obligations. 

Like others in the industry, he also states that while preparedness for the April rollout remains uneven—large producers and organized recyclers are largely ready, aggregators and MSMEs are still evolving—clear gaps persist around registration and onboarding, traceability systems, and last-mile awareness. At the same time, Jain sees EPR emerging as a strong demand driver for formal recycling, likely to catalyze organized collection networks, spur investments in technology and processing capacity, and improve the overall bankability of recycling businesses.  

However, he cautions that while EPR will strengthen traceability, accountability, and partial formalization of the informal sector, it will not fully address global price volatility, deep-rooted fragmentation, or rising compliance costs—particularly for MSMEs. 

Beyond intent: the cracks in the system 

Dr Sandeep Vakharia, Honorary Secretary of the Bombay Non-Ferrous Metals Association (BNMA) and Managing Director of Aashumi Chemicals, takes a more cautionary view, flagging fundamental gaps in the evolving framework. He points to widespread ambiguity across producers, recyclers, and collection networks, with stakeholders often unclear on liabilities, incentives, and compliance pathways. Aggregators, despite their central role, are not consistently integrated into the incentive structure, while mismatches between GST compliance and EPR credit systems continue to complicate traceability.