From Scrap to Global Trade — How Indian Recyclers Are Tapping New Markets
When Rajesh, a Pune-based recycler, received his first international inquiry from a European buyer for refurbished laptops, he thought the hardest part — recycling — was done.
But a week later, his shipment got stuck at the port. Why? Because he didn’t have a DGFT export authorization and hadn’t linked his CPCB and EPR registrations.
This story isn’t rare. As India becomes a hub for refurbished electronics and metal recovery, hundreds of recyclers and refurbishers are exploring exports — yet many struggle with compliance.
Let’s break down how you can obtain a DGFT license to export recycled e-waste, refurbished electronics, or recovered metals — without losing time, money, or shipments.
Understanding DGFT’s Role in E-Waste and Refurbished Exports
The Directorate General of Foreign Trade (DGFT) regulates India’s exports and imports — especially for restricted environmental goods such as used electronics, e-waste, batteries, or recovered metals.
Under the E-Waste (Management) Rules, 2022, Battery Waste Management Rules, 2022, and Plastic Waste (Amendment) Rules, 2025, exporters must prove that materials are recycled in a legally compliant facility before being shipped abroad.
DGFT Works Alongside:
| Authority | Role |
|---|---|
| CPCB (Central Pollution Control Board) | Grants registration to recyclers/refurbishers, verifies EPR compliance |
| MoEFCC (Ministry of Environment, Forest & Climate Change) | Issues NOCs for restricted or hazardous materials |
| SPCB/PCC | Issues Consent to Operate (CTO) and monitors local environmental norms |
| DGFT | Issues export license or authorization for restricted environmental goods |
Prerequisites Before Applying for DGFT Export License
Before you even open the DGFT portal, ensure these documents and registrations are ready. Each one connects environmental compliance with trade authorization.
Mandatory Registrations for Exporters
| Requirement | Issued By | Validity | Typical Time |
|---|---|---|---|
| CPCB Registration (Recycler/Refurbisher) | CPCB | 5 years | 30 working days |
| EPR Registration / Certificate | CPCB | Annual | Linked to recycling target |
| Consent to Establish & Operate (CTE/CTO) | State PCB | 5 years | 30–45 days |
| Importer–Exporter Code (IEC) | DGFT | Lifetime | Instant (Online) |
| GST & PAN Registration | Govt. of India | Permanent | — |
| MoEFCC NOC (if applicable) | MoEFCC | Case-specific | 30–90 days |
Note: CPCB registration is the foundation. Without it, DGFT cannot issue an export license.
Step-by-Step DGFT Export Authorization Process
Exporting recycled e-waste or refurbished electronics follows a digital approval path through https://dgft.gov.in.
Here’s what every recycler or exporter must do:
Step 1 — Identify Export Category
Check if your product is listed as restricted, free, or prohibited in the DGFT’s ITC-HS classification.
- Refurbished or used laptops, desktops, or phones → Restricted
- Recovered metals (copper, aluminium, iron, gold) → Free, if traceable through CPCB EPR certificate
Step 2 — Prepare Documentation
Keep the following ready:
- CPCB Registration Certificate
- EPR Certificate or performance report
- SPCB Consent to Operate (CTO)
- IEC, GST, PAN
- MoEFCC NOC (if waste is restricted)
- Commercial Invoice, Bill of Lading, Buyer’s Agreement
Step 3 — File Application on DGFT Portal
Login with your IEC number, go to Restricted Item Export, and fill Form ANF-2N.
Attach all supporting documents and select E-Waste / Refurbished Electronics in the product dropdown.
Step 4 — DGFT & CPCB Cross-Verification
DGFT automatically verifies your CPCB registration and EPR status.
If everything matches, DGFT forwards it for clearance. Any mismatch in address or company name can delay the process by 15–20 working days.
Step 5 — Export Authorization Grant
Once cleared, DGFT issues a Digital Export Authorization Letter (valid up to one year or shipment-based).
This letter must be uploaded to the customs ICEGATE system for export clearance.
Fees and Validity Overview
| License Type | Fee (₹) | Validity Period | Renewal Frequency |
|---|---|---|---|
| CPCB Recycler / Refurbisher Registration | 15,000 | 5 years | Renewable every 5 years |
| CPCB Renewal Fee | 7,500 + ₹0.625/MT (EPR transactions) | 5 years | — |
| Annual Maintenance (EPR Portal) | 5,000 | Annual | Yearly renewal |
| DGFT Export Authorization | ~1,000–2,500 | 1 year / consignment-based | Per export |
| MoEFCC NOC | ₹2,000–10,000 (based on volume) | Case-specific | Per shipment |
Tip: Always renew CPCB registration at least 120 days before expiry to keep DGFT licensing active.
How EPR Compliance Influences DGFT Export Licensing
EPR (Extended Producer Responsibility) isn’t just a recycling target — it’s your eligibility passport for export.
Every exporter must show that the material being exported (recycled copper, plastic granules, refurbished electronics) originated from CPCB-verified recycling.
If you’ve generated EPR certificates from registered recyclers, DGFT will accept them as proof that your export is legally recycled and not sourced from informal waste.
Example:
| Export Material | Proof Required | EPR Value (Example) |
|---|---|---|
| Recycled Copper | EPR certificate issued by CPCB | 1 certificate = 1 MT |
| Refurbished Laptop | CPCB Refurbisher license + EPR target compliance | Proof of refurbishment (video/inspection) |
| Battery Scrap | Battery Waste EPR certificate | Recovery ratio > 90% metals |
| Plastic Pellets | Plastic Waste Processor EPR report | 25% annual recycling compliance |
Realistic Timelines
| Process | Average Time (Days) | Authority |
|---|---|---|
| CPCB Registration | 30 | CPCB |
| SPCB Consent (CTE + CTO) | 45 | State PCB |
| MoEFCC NOC (if applicable) | 60–90 | MoEFCC |
| DGFT Application Review | 15 | DGFT HQ |
| Export Authorization Letter | 5–10 | DGFT |
Total Time (ideal scenario): 60–90 days
For exporters with prior CPCB registration, DGFT licensing can be completed within 20 working days.
Common Mistakes That Delay or Block Exports
- Submitting expired or suspended CPCB registration.
- Using incorrect HS Code or product description in DGFT portal.
- Mismatch between GST and DGFT address (automatic rejection).
- Missing geo-tagged videos or photos for recycling facility verification.
- Exporting restricted waste without MoEFCC clearance.
- Not filing quarterly and annual returns on the CPCB portal (mandatory for recyclers and refurbishers).
Pro tip: Always upload geotagged facility videos and update quarterly EPR filings before applying for export.
Business Advantages of Full Compliance
When recyclers maintain end-to-end compliance, they don’t just meet the law — they build export credibility.
Tangible Benefits:
- Faster Customs Clearance: Integrated DGFT–ICEGATE system recognizes registered CPCB exporters.
- Higher Buyer Confidence: EU, UAE, and Singapore buyers prefer certified recyclers.
- Government Incentives: Easier access to EPCG and sustainability-linked schemes.
- Financial Trust: Banks and export houses favor compliant exporters for trade credit.
What Happens if You Export Without Proper License
| Non-Compliance | Possible Consequence |
|---|---|
| Exporting without DGFT Authorization | Shipment seizure and customs penalty |
| Missing CPCB Registration | EPR deactivation and export suspension |
| False data submission | Blacklisting for 3 years under DGFT Act |
| Failure to file annual returns | ₹10,000 per day fine + license freeze |
| Mismatch in CPCB–DGFT records | License rejection or legal notice |
Did you know? Nearly 28% of rejected export licenses in 2024 were due to incomplete CPCB or SPCB documentation.
How Green Permits Simplifies Your Export Compliance
At Green Permits Consulting, we specialize in bridging environmental compliance with export readiness.
Our experts handle everything — from CPCB registration and EPR management to DGFT authorization filing.
We help you with:
- E-Waste, Plastic, and Battery Recycler Registration
- EPR Certificate generation and transfer management
- DGFT Restricted Item Export license filing
- MoEFCC NOC coordination and documentation
- Annual Return filing and quarterly EPR reporting
Conclusion: Turning Compliance into Competitive Edge
India is on track to become Asia’s largest recycling and refurbishment hub by 2030.
DGFT, CPCB, and MoEFCC have created a unified ecosystem where export growth and environmental responsibility go hand in hand.
By aligning early — registering under CPCB, maintaining EPR obligations, and securing DGFT authorization — exporters save time, build global trust, and open new markets.
With Green Permits, compliance isn’t a hurdle — it’s your passport to global sustainability trade.
📞 +91-78350 06182 | 📧 wecare@greenpermits.in
Book a Consultation today to make your export journey seamless and compliant.
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Add Your Heading Text Here
Yes, only CPCB-registered recyclers and refurbishers can legally export under DGFT authorization.
Usually 15–20 working days after CPCB and EPR verification.
Typically valid for 12 months or per consignment, whichever is earlier.
Only if your product is not classified as hazardous waste; otherwise, MoEFCC approval is mandatory.
Fines, shipment seizure, and possible blacklisting from DGFT and CPCB portals.
