Question 1

EPR regulations only apply to the final consumer product as an integrated whole, like a laptop or a plastic bottle.

Accepted Answer

The new non-ferrous EPR rules require material-specific compliance. Companies already registered for E-waste EPR (covering the device) may now face separate obligations for the specific aluminium, copper, and zinc extracted during the dismantling process.

Question 2

Under EPR, producers are legally required to physically collect and recycle the metal scrap themselves.

Accepted Answer

Producers do not need to physically handle the scrap. They can simply participate in a market-based mechanism by purchasing 'EPR Certificates' from authorized, registered recyclers via the CPCB portal to offset their targets.

Question 3

Consider the following statements regarding the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2025:
1. The rules introduce Extended Producer Responsibility (EPR) obligations primarily for ferrous metals like iron and steel.
2. EPR Certificates generated by registered recyclers under this framework are valid for a maximum period of two years.
3. The framework mandates the use of domestically recycled non-ferrous metals in the manufacturing of new products starting from FY 2028-29.
How many of the above statements are correct?

Accepted Answer

(b) Only two — Statement 1 is incorrect: The rules apply specifically to 18 products of non-ferrous metals (aluminium, copper, zinc, and their alloys), not ferrous metals. Statement 2 is correct: EPR certificates traded on the CPCB portal are valid for exactly two years. Statement 3 is correct: Under Schedule XIII, minimum recycled content requirements (5% to 25%) begin in FY 2028-29. Therefore, exactly two statements are correct.

Question 4

Match List I (Stakeholder) with List II (Key Obligation/Role under the 2025 Non-Ferrous EPR Rules):
List I
A. Refurbisher
B. Central Pollution Control Board (CPCB)
C. Producer
D. Bulk Consumer
List II
1. Generates certificates that allow temporary deferment of EPR targets
2. Manages the centralized online portal and price band for certificate trading
3. Meets progressively increasing recycling targets starting at 10% in FY 2026-27
4. Required to set up collection points for scrap and hand it over to registered entities

Accepted Answer

(a) A-1, B-2, C-3, D-4 — Refurbishers (A) generate refurbishing certificates that defer a producer's EPR obligations (1). CPCB (B) is the nodal agency operating the digital registry and trading platform (2). Producers (C) carry the main EPR burden, starting at 10% in 2026-27 (3). Bulk Consumers (D) must set up collection points to channel scrap back into the formal system (4).

Question 5

Assertion (A): Electronics manufacturers and e-waste recyclers may face overlapping or dual Extended Producer Responsibility (EPR) registrations under the new 2025 rules.
Reason (R): E-Waste EPR covers the electronic product as an integrated unit, whereas the 2025 Hazardous Waste Amendment establishes a separate framework specifically covering the aluminium, copper, and zinc extracted during the recycling process.

Accepted Answer

(a) Both A and R are true and R is the correct explanation of A — Both statements are factually correct. The new EPR rules for non-ferrous metals (effective April 2026) regulate baseline commodities (Al, Cu, Zn). Because these metals are heavily present in electronics (wires, PCBs, heat sinks), an e-waste recycler extracting these metals must generate separate certificates for metal recovery on the CPCB portal, distinct from their e-waste device-level compliance. Hence, R correctly explains A.

EPR Rules Introduced for Non-Ferrous Metal Scrap

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