How ESG Reporting Is Changing Corporate Scrap Disposal in India

Updated: June 07, 2026 · 15 min read

When SEBI issued its circular dated 12 July 2023 mandating BRSR Core disclosures, most sustainability teams scrambled to address carbon emissions and water intensity. Very few stopped to audit their scrap disposal chain. That gap is closing fast. With assurance requirements now live for the top 150 listed entities and the scope expanding to the top 1,000 companies from FY 2024-25, the question of ESG waste management in India has moved from a CSR footnote to a line item that external assurance providers will verify against source documents — including, critically, certificates of recycling and authorisation records from your disposal partners.

BRSR Core: What the 12 July 2023 SEBI Circular Actually Requires

SEBI’s circular dated 12 July 2023 (reference SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122) introduced BRSR Core as a subset of the existing Business Responsibility and Sustainability Report framework — but with one structural difference that changes everything: mandatory third-party assurance. Unlike the broader BRSR, where narrative disclosures carry limited verification burden, BRSR Core metrics must be attested by an independent assurance provider. Waste generation, waste intensity, and waste disposal methods are all within scope under Principle 2 (Products, Services, and Responsible Business Practices).

For the FY 2024-25 reporting cycle — annual reports being finalised right now — the top 1,000 listed entities by market capitalisation are required to submit BRSR Core disclosures. The assurance obligation applies to the top 150 from FY 2023-24 and cascades to the wider cohort in FY 2025-26. What this means operationally: your sustainability officer cannot simply declare “all scrap is recycled responsibly” and move on. The assurance team will ask for the paper trail. If that trail leads to an unlicensed kabadiwala or an unregistered trader, the disclosure fails verification.

What “Waste Disposal Method” Means Under BRSR Principle 2

The BRSR framework — aligned broadly with GRI Standards 306 — requires companies to categorise waste by type (hazardous versus non-hazardous), by disposal route (recycled, recovered, landfilled, incinerated, co-processed), and to report intensity relative to revenue or production output. For a mid-sized auto-component manufacturer in Pune generating 800–1,200 tonnes of mixed ferrous, aluminium, and copper scrap per year, this demands a documented chain of custody from the point of generation to the point of final processing. Verbal assurances from traders are insufficient; GSTIN-linked invoices, E-way bills, and certificates of recycling are the minimum expected documentation set.

The Three Regulations That Now Govern Every Corporate Scrap Transaction

ESG waste management in India does not exist in a single regulatory silo. Three distinct rule frameworks — each administered by a different authority — intersect at the point where a listed company hands over scrap to a disposal partner. Understanding how they interact is the starting point for any credible BRSR waste disclosure.

1. The Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016

Administered by the Central Pollution Control Board (CPCB) under the Ministry of Environment, Forest and Climate Change (MoEFCC), these rules govern the generation, storage, treatment, and disposal of hazardous waste including spent oils, batteries (covered separately post-2022), contaminated metal scrap, and process residues. Rule 5(1)(d) requires occupiers to maintain records of hazardous waste sent for disposal and to ensure the receiving facility is authorised by the relevant State Pollution Control Board (SPCB). Critically, records must be retained for a minimum of 3 years — an obligation that auditors now routinely cross-reference against BRSR waste disclosures.

2. The E-Waste (Management) Rules, 2022

For companies decommissioning IT assets, telecom equipment, or industrial electronics, the E-Waste (Management) Rules, 2022 (notified by MoEFCC on 2 November 2022, effective from 1 April 2023) are the controlling instrument. These rules shifted from a target-based EPR framework to a certificate-based system, where producers, consumers, and recyclers transact in E-Waste Exchange Credits. For a corporate bulk consumer — say, a bank retiring 5,000 laptops or a hospital decommissioning imaging equipment — the obligation is to deposit end-of-life equipment only with a CPCB-authorised dismantler or recycler and to obtain a certificate of disposal. That certificate, in turn, becomes the documentary evidence for the BRSR e-waste disclosure.

3. The Battery Waste Management Rules, 2022

Notified in August 2022, the Battery Waste Management Rules, 2022 replaced the earlier Batteries (Management and Handling) Rules, 2001 and introduced an EPR framework for all battery chemistries — lithium-ion, lead-acid, nickel-metal hydride, and others. Manufacturers and importers must meet annual collection targets (rising to 70% for lead-acid batteries by FY 2025-26) and purchase EPR certificates from registered recyclers. For companies with large forklift fleets, UPS banks, or EV charging infrastructure, spent battery disposal is now a compliance obligation with a paper trail requirement that feeds directly into BRSR reporting.

The Waste Metrics Listed Companies Must Now Quantify

The BRSR framework does not permit vague qualitative statements. The specific quantitative disclosures required under Principle 2, Essential Indicator 2 include: total waste generated (in metric tonnes, disaggregated by hazardous and non-hazardous), total waste disposed (by disposal method — recycled, recovered, landfilled), and waste intensity (waste generated per ₹ crore of revenue or per unit of production). For a company with ₹500 crore in revenue generating 2,000 tonnes of mixed industrial scrap annually, the waste intensity metric would be 4 tonnes per ₹ crore — a figure that must be reproduced exactly by the assurance provider and that will be benchmarked against prior years and sector peers.

The following table summarises the key BRSR waste disclosure fields and the supporting documents auditors typically request:

BRSR Disclosure Field	Unit	Supporting Document Required	Applicable Rule / Standard
Total waste generated (hazardous)	Metric tonnes / year	SPCB authorisation, Form 3 manifest, 3-year records	Hazardous Wastes Rules, 2016 — Rule 5(1)(d)
Total waste generated (non-hazardous)	Metric tonnes / year	Weigh-bridge slips, GST invoices, E-way bills	BRSR Core — SEBI Circular 12 July 2023
E-waste disposed	Metric tonnes / year	Certificate of recycling, CPCB-authorised recycler ID	E-Waste (Management) Rules, 2022
Battery waste disposed	Units / kg	EPR certificate, recycler registration proof	Battery Waste Management Rules, 2022
Waste recycled / recovered	% of total waste	Recycler’s processing certificate, material recovery statement	BRSR Principle 2 — Essential Indicator 2
Waste intensity (per ₹ crore revenue)	MT / ₹ crore	Audited financials cross-referenced with waste logs	BRSR Core — SEBI Circular 12 July 2023

Certificate of Recycling: From Nice-to-Have to Audit Evidence

Until three years ago, a certificate of recycling was something a responsible company might request from its scrap vendor as a goodwill gesture. Today, it is primary audit evidence. Under the BRSR assurance process, an external reviewer assessing a company’s “waste recycled” percentage will specifically seek certificates of recycling from the disposal partners named in the company’s records. A certificate that cannot be traced to a CPCB-authorised facility — or one issued by a trader who is merely aggregating scrap before passing it to an unregistered processor — will not survive scrutiny.

What a compliant certificate of recycling must contain: the name and CPCB/SPCB authorisation number of the processing facility, a description of the material received (with weight in metric tonnes verified by weigh-bridge), the date of receipt, the recycling process used (shredding and smelting for metals; dismantling and material recovery for e-waste), and the signature of an authorised signatory of the recycling facility. Some assurance providers in larger engagements — particularly for Big Four-led BRSR assurance for Nifty 100 companies — are now requesting GPS-tagged photographs of the received scrap as additional corroboration.

The GST Dimension

There is a parallel commercial reason why documentation matters beyond ESG. Under GST, scrap sales are taxable events (most metal scrap attracts 18% GST under HSN codes 72–76), and the buyer is liable to deduct tax at source under Section 51 of the CGST Act where applicable. A company that cannot produce a GSTIN-linked invoice from its scrap disposal partner has not only a BRSR problem but a potential GST compliance exposure. These two threads — sustainability reporting and tax compliance — converge in the same vendor onboarding process, which is why procurement and sustainability teams increasingly need to align on scrap vendor selection.

Why Using an Unregistered Scrap Dealer Is Now a Balance-Sheet Risk

India’s organised industrial scrap recycling sector handles an estimated 35–40 million tonnes of ferrous scrap annually, according to data cited by the Ministry of Steel in its National Steel Policy framework. Yet a substantial share — conservative industry estimates put this at 30–40% — still moves through informal channels: unlicensed aggregators, unregistered traders, and processors operating without SPCB authorisation. For a listed company disposing of scrap through such channels, the risk is no longer merely reputational.

Consider the mechanics. A sustainability officer signs off on a BRSR disclosure stating that 92% of the company’s non-hazardous industrial scrap was recycled in FY 2024-25. The assurance provider requests certificates of recycling for the 1,400 tonnes of MS and aluminium scrap sold to a trader in Bhiwandi. The trader provides a certificate on its own letterhead — with no CPCB authorisation number, no weigh-bridge record, and no indication of the downstream processor. The assurance provider issues a qualified opinion on the waste recycling metric. The qualified opinion is disclosed in the annual report. An activist institutional investor — and SEBI’s regulatory lens on ESG disclosures is getting sharper — raises a flag. The reputational and regulatory cascade from that single documentation gap can be traced back to a vendor selection decision that saved, at best, ₹2–3 per kg on scrap pricing.

Recent CPCB enforcement actions — particularly in industrial clusters in Maharashtra, Gujarat, and Tamil Nadu during FY 2024-25 — have focused on exactly this gap: companies generating hazardous or regulated waste without verifiable disposal documentation. The direction of regulatory travel is clear, and the NITI Aayog’s circular economy policy roadmap explicitly calls for formalising the scrap and recycling sector through mandatory registration and traceability systems.

The 7-Step BRSR Waste Compliance Checklist for This Quarter

For sustainability officers and BRSR teams finalising FY 2024-25 disclosures, or preparing FY 2025-26 waste management processes, the following actions are not aspirational — they are the minimum required to produce a defensible BRSR waste disclosure that will survive assurance.

1. Map every waste stream by regulatory category. Separate hazardous waste (governed by the Hazardous and Other Wastes Rules, 2016), e-waste (governed by the E-Waste Management Rules, 2022), battery waste (governed by the Battery Waste Management Rules, 2022), and general non-hazardous scrap. Each category has distinct documentation requirements and different BRSR disclosure fields.
2. Verify CPCB/SPCB authorisation of every disposal partner. Request a copy of the current authorisation certificate — not a self-declaration. Cross-check the authorisation number on the relevant SPCB’s public portal or the CPCB’s online registry. Authorisations are typically issued for 1–5 years and must be current at the time of disposal.
3. Collect weigh-bridge-certified weight records for every scrap movement. Weigh-bridge slips are the primary evidence for tonnage figures in BRSR waste disclosures. An invoice showing a negotiated price per kg is not sufficient on its own — the weight must be independently verified.
4. Obtain GST-compliant invoices with correct HSN codes. Metal scrap (HSN 72–76), e-waste components, and plastic scrap all carry specific HSN codes and GST rates. Invoices without correct HSN codes create both a GST compliance gap and a documentation gap for BRSR purposes.
5. Request a certificate of recycling for each disposal transaction, not just annually. Waiting until year-end to collect certificates creates gaps that cannot be retroactively filled. Build certificate collection into the accounts payable or vendor management workflow at the point each transaction is completed.
6. Retain all waste disposal records for a minimum of 3 years. This is the floor under Rule 5(1)(d) of the Hazardous Wastes Rules, 2016 for hazardous waste records. Best practice — and BRSR assurance expectation — is to apply the same retention standard to all waste categories, not just regulated waste.
7. Calculate and validate waste intensity before the assurance provider does. Compute waste intensity (total waste in MT ÷ revenue in ₹ crore) for the current year and the prior two years. Unexplained spikes will attract queries. If intensity rose due to a one-off plant decommissioning or a specific project, document the explanation now, not in response to an auditor’s query.

Related Articles

• Why Circular Economy Matters for Indian Manufacturers
• Electronics Recycling for IT Companies: Data Security Plus Compliance
• Bulk Waste Pickup Services: What to Expect and How to Prepare

Frequently Asked Questions

Which companies are required to make BRSR waste disclosures in FY 2024-25?

All top 1,000 listed entities by market capitalisation are required to submit BRSR disclosures (including waste metrics under Principle 2) for FY 2024-25, per SEBI’s circular dated 12 July 2023. Third-party assurance on BRSR Core indicators — which include waste intensity — is mandatory for the top 150 listed entities from FY 2023-24, expanding to the top 1,000 from FY 2025-26. Companies outside the top 1,000 are encouraged but not yet mandated to comply.

What documentation does a corporate need to prove its scrap was recycled responsibly?

At minimum: a GSTIN-linked invoice from the disposal partner, a weigh-bridge slip confirming tonnage, and a certificate of recycling issued by the processing facility — which must carry the CPCB or SPCB authorisation number of that facility. For hazardous waste, a Form 3 manifest under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 is also required. Assurance providers for BRSR Core will request all of these as primary evidence.

Does selling scrap to an unregistered dealer violate any Indian law?

For hazardous waste, yes — Rule 5(1)(d) of the Hazardous and Other Wastes Rules, 2016 explicitly requires occupiers to dispose of hazardous waste only through authorised facilities. For e-waste, the E-Waste (Management) Rules, 2022 require deposit with a CPCB-authorised dismantler or recycler. For non-hazardous general scrap, there is no direct statutory bar, but selling to an unregistered dealer creates a BRSR audit gap and a GST documentation risk that can have material consequences for listed companies.

What is an EPR certificate and does it count as a BRSR waste document?

An EPR (Extended Producer Responsibility) certificate is issued through the CPCB’s EPR portal and related platforms, confirming that a specified quantity of a regulated waste category (plastic, e-waste, battery, tyre) has been collected and processed. Under the Battery Waste Management Rules, 2022, producers must meet EPR targets — rising to 70% collection for lead-acid batteries by FY 2025-26. EPR certificates are valid BRSR supporting documents for the specific waste categories they cover, but do not substitute for certificates of recycling for general industrial scrap or metal waste streams.

How long must waste disposal records be kept for BRSR and regulatory purposes?

The Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 specify a minimum 3-year record retention requirement for hazardous waste disposal records. BRSR assurance providers, particularly for companies in the top 150 with mandatory BRSR Core assurance, typically request 2–3 years of comparative data. Best practice — and increasingly standard in Big Four BRSR assurance engagements — is to retain all waste disposal records for at least 5 years, aligned to the general accounting record retention standard.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered full-service industrial waste dealer with pan-India operations spanning Maharashtra, Gujarat, Delhi-NCR, Karnataka, Tamil Nadu, and Telangana. We work with listed companies, PSUs, manufacturing conglomerates, and large commercial establishments that need their scrap disposal to be not merely efficient, but audit-ready.

Our documentation standard is built around what BRSR assurance providers and CPCB inspectors actually ask for — not what looks good on a vendor brochure. Every transaction generates a GST-compliant invoice with the correct HSN code, a weigh-bridge-certified weight record, and a certificate of recycling traceable to an authorised processing facility. For regulated waste streams including e-waste and hazardous scrap, we work exclusively with CPCB and SPCB-authorised partners. Metal pricing is benchmarked against prevailing London Metal Exchange (LME) rates and Mumbai yard indices, so you receive fair-market value — not a distressed price in exchange for paperwork convenience.

Whether you are a sustainability officer closing out your FY 2024-25 BRSR waste disclosure, a procurement lead setting up a compliant scrap disposal programme, or a plant manager in Thane or Pune who needs a reliable, documented pickup service, we are structured to serve your requirement. Our specific capabilities include:

• Pan-India scrap pickup — ferrous, non-ferrous, mixed industrial, and CPCB-authorised e-waste recycling
• BRSR-grade certificates of recycling and destruction, with 3-year record retention
• GST-compliant invoicing with correct HSN codes across all scrap categories
• Compliance with the Hazardous and Other Wastes Rules, 2016, the E-Waste (Management) Rules, 2022, and the Battery Waste Management Rules, 2022
• Support for EPR compliance documentation across e-waste and battery waste streams
• Fair-market pricing for ferrous and non-ferrous metal scrap, indexed to prevailing LME and Mumbai yard rates
• Dedicated account management for listed-company clients with quarterly waste summary reports in BRSR-compatible format

Contact us to schedule a consultation or request a compliance quote. Our team responds within one business day.

Sources and References

• Central Pollution Control Board — Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016
• Central Pollution Control Board — E-Waste (Management) Rules, 2022: EPR Registration and Authorised Recyclers
• CPCB Extended Producer Responsibility Portal — EPR Certificates and Registration
• Ministry of Environment, Forest and Climate Change — Waste Management Rules Notifications
• SEBI — BRSR Core Circular dated 12 July 2023 (SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122)
• Ministry of Steel, Government of India — National Steel Policy and Scrap Recycling Framework
• NITI Aayog — Circular Economy and Resource Efficiency Policy Roadmap
• London Metal Exchange — Base Metal Spot Prices (Copper, Aluminium, Lead)