BRSR for Manufacturing — Material Disclosures, Process + Energy Emissions, and EPR Overlays for Auto + Electrical + Engineering

Why this guide exists

Indian listed manufacturing entities form the largest sectoral cohort within the Top 1,000 listed entities by market capitalisation — and the most heterogeneous. The “manufacturing” label spans automotive OEMs and component-makers, capital goods and machinery, electrical equipment, basic and fabricated metals, engineering, and light chemicals. Each sub-segment carries a distinctive Scope 1 + 2 profile, a distinctive set of EPR / extended-producer-responsibility overlays, and a distinctive Scope 3 dominant category.

This guide covers discrete + process manufacturing broadly, excluding three sub-sectors that have their own dedicated guides — Cement (calcination process emissions + EU CBAM are unique), Pharma (biomedical waste + CDSCO + USFDA overlay), and FMCG (plastic-packaging EPR + agricultural supply chains).

This guide walks through the BRSR-specific patterns observed for Indian listed manufacturers — the Core attributes that tend to be most material in practice, the process vs energy Scope 1 split for heavy manufacturing, the EPR overlays (E-Waste, Battery, ELV) that land for specific product categories, the EU CBAM exposure for iron-and-steel / aluminium / fertilizer exporters, the Factories Act + OSHWC Code intersection with Principle 3 disclosures, and the dominant Scope 3 categories that vary by sub-sector.

This guide describes common BRSR disclosure patterns for the manufacturing sector, but entity-level materiality, current SEBI phase-in applicability, the assurance standard applied, and CBAM / EPR exposure should always be confirmed for the specific listed entity and its product portfolio.

The manufacturing profile within the Top 1,000

Common sectoral features observed in Indian listed manufacturing BRSR disclosures (these shape the disclosure profile in practice but are not a SEBI-prescribed sector taxonomy):

• NIC classification spread — Indian manufacturing maps across NIC division 24 (Basic metals), 25 (Fabricated metal products), 26 (Computer, electronic, optical products), 27 (Electrical equipment), 28 (Machinery and equipment), 29 (Motor vehicles, trailers, semi-trailers), and 30 (Other transport equipment). Many listed entities span multiple NIC codes given multi-product portfolios.
• Multi-plant footprint — Listed manufacturers typically operate multiple plants across automotive clusters (Chennai-Hosur, Pune-Aurangabad, Manesar-Gurgaon, Pithampur, Sanand), industrial corridors (DMIC nodes), SEZs, and dedicated industrial estates. The Section A operations disclosure is often substantial.
• Heavy machinery + process operations — foundry / forging / casting / machining / paint-shop / assembly operations carry distinctive Scope 1 profiles (process heat, captive steam, fuel for thermal operations, fugitive VOC from paint shops, refrigerant leakage from process cooling).
• Captive power + utilities — many integrated plants operate CPPs (coal, gas, sometimes biomass) plus increasingly behind-the-meter rooftop solar; the Scope 1 vs Scope 2 boundary mechanics matter for intensity reporting.
• Substantial contract + outsourced workforce — manufacturing workforces are typically multi-tier (permanent operators + management + contract operators + apprentices + housekeeping + security + canteen). The Contract Labour (Regulation and Abolition) Act 1970 and OSHWC Code 2020 disclosure obligations are substantial.
• EPR exposure varies by product category — E-Waste EPR for electrical equipment manufacturers; Battery EPR for battery manufacturers + assemblers + importers; the proposed ELV framework for automotive OEMs; Hazardous and Other Wastes Rules for any entity generating hazardous waste streams.
• EU CBAM exposure for specific categories — iron and steel, aluminium, and fertilizer manufacturers exporting to the EU face the parallel CBAM regime.

Material BRSR Core attributes for manufacturing

The BRSR Core (per SEBI/HO/CFD/CFD-SEC-2/P/CIR/2023/122 dated 12 July 2023) is structured around 9 ESG attributes. The materiality of each attribute for a manufacturer is entity-specific, but the patterns commonly observed in published submissions are:

BRSR Core attribute	NGRBC Principle	Typical materiality for manufacturing	Sector notes
GHG emission intensity per revenue (Scope 1 + 2)	P6	Typically substantive to high; varies materially by sub-segment	Heavy metals + casting + forging carry high intensity; assembly-only carries lower. See GHG emission intensity per revenue.
Water withdrawal intensity	P6	Frequently material for entities with cooling-water demand	Foundries, paint shops, captive power cooling drive water demand. See Water withdrawal intensity.
Spend on wellbeing	P3	Typically substantive given workforce size + statutory Factories Act / OSHWC Code obligations	EPF / ESI / health insurance / canteen / transport / safety equipment all bucket here. See Spend on wellbeing.
Job creation in smaller towns	P8	Typically substantive for entities with industrial-estate / SEZ / non-metro plant locations	Most Indian manufacturing clusters are in Tier 2 / Tier 3 cities. See Job creation in smaller towns.
Complaints disclosure (POSH)	P5	Typically substantive given workforce size and gender-mix challenges	See POSH complaints disclosure.
Openness of business (related-party transactions)	P1	Typically moderate to material; high for groups with captive component / logistics / power subsidiaries	Inter-group component supply, captive logistics, captive power frequently feature. See Openness of business.
Gross wages paid to women	P5	Typically moderate disclosure; sector trajectory improving	Manufacturing workforces historically have low gender ratios; new automotive + electronics plants have substantially shifted this. See Female wages disclosure.

The materiality column reflects patterns observed in published Indian manufacturing BRSR submissions — entity-level materiality assessment is the framework that should drive actual reporting emphasis. See the Materiality Assessment Walkthrough.

Sector-specific patterns by area

Scope 1 process emissions in heavy manufacturing

For metals, casting, forging, and process-intensive manufacturers, Scope 1 has substantial complexity beyond fleet diesel and standby DG sets:

• Process heat — coke + natural gas + furnace oil + biomass for melting, heat-treatment, paint baking, drying, and thermal processing.
• Captive steam — boilers (natural gas / coal / biomass) for steam-driven process operations and CPP feed.
• Fugitive emissions — refrigerant leakage from process cooling, paint-shop solvent VOC, lubricant mist, fugitive methane from coke ovens (relevant for integrated-steel entities).
• Mobile combustion — internal-plant material handling fleets (forklifts, cranes, tow vehicles), often dual-fuel or increasingly battery-electric.

For integrated metals operations (iron and steel, primary aluminium), process emissions include reaction-chemistry CO₂ — direct CO₂ release from coke + ore reduction in blast furnaces, or from anode consumption in aluminium smelting. Methodology should follow GHG Protocol Corporate Standard with sector-specific guidance where applicable (e.g., the worldsteel CO₂ data-collection methodology for integrated-steel entities). Quantification methodology should be documented as part of the assurance preparation — see Document and Evidence Requirements.

Captive Power Plants + on-site renewable

Most large manufacturing plants operate some combination of:

• Captive Power Plant (CPP) — typically coal or gas-fired; emissions are Scope 1 (fuel) and on-site electricity is not re-counted as Scope 2.
• Group-subsidiary or third-party PPA power — emissions are Scope 2; market-based vs location-based reporting both common per the GHG Protocol Scope 2 Guidance.
• Behind-the-meter rooftop solar + on-site wind — net-meter or captive consumption; reduces Scope 2 grid demand.
• Renewable PPAs — increasingly common; reported via market-based Scope 2 where contractual instruments (RECs, I-RECs, bundled green tariffs) support the claim.

Boundary basis should be applied consistently per the SEBI December 2024 Industry Standards on BRSR Core.

EPR overlays — E-Waste, Battery, and ELV

Three EPR regimes are commonly relevant for Indian manufacturers depending on the product category:

E-Waste (Management) Rules 2022 — applies to producers, importers, and brand owners of electronic and electrical equipment listed in Schedule I + II. Producers must register on the CPCB EPR portal for E-Waste, file annual returns of EEE placed on the market by category, and procure EPR certificates against year-on-year increasing recycling targets. Manufacturers of consumer electronics, IT equipment, electrical appliances, medical devices, automotive electronics, and lighting fall in scope. EPR-portal-filed volumes and BRSR Principle 6 narrative on post-consumer e-waste should reconcile.

Battery Waste Management Rules 2022 — applies to producers, importers, recyclers, and refurbishers of all battery types — automotive lead-acid, portable consumer batteries, industrial batteries, and EV traction batteries. Producers register on the CPCB EPR portal for Batteries, file half-yearly returns of batteries placed on the market by chemistry + use category, and procure EPR certificates. Critical for automotive OEMs (lead-acid + Li-ion EV batteries), 2W / 3W manufacturers, and battery cell / pack assemblers.

End-of-Life Vehicles (ELV) framework — the Vehicle Scrappage Policy 2021 + Registered Vehicle Scrapping Facility (RVSF) Rules + Authorised Vehicle Scrapping Facility framework cover end-of-life vehicle processing. The formal ELV EPR regime for automotive OEMs is at advanced policy / draft stage; OEMs are commonly disclosing voluntary take-back and dealer-network return programmes under Principle 2 (Sustainable Products) narrative in anticipation.

Hazardous and Other Wastes Rules 2016 — applies to any manufacturer generating hazardous waste streams (spent solvents, used oil, ETP / WWTP sludges, contaminated containers, used batteries pending EPR routing, asbestos-containing material). Hazardous waste authorisations under Schedule I + II are facility-level; the manifest-based tracking system generates the underlying data for BRSR Principle 6 narrative on hazardous waste generation, treatment, and disposal.

EU CBAM exposure for specific product categories

Iron and steel, aluminium, and fertilizer manufacturers exporting to the EU face the parallel EU CBAM regime under Regulation (EU) 2023/956:

• Transitional period (1 October 2023 to 31 December 2025) — quarterly embedded-emissions data shared with EU importers under Implementing Regulation (EU) 2023/1773. No financial obligation.
• Definitive regime from 1 January 2026 — EU importers purchase CBAM certificates against embedded emissions, priced at the weekly EU ETS auction rate net of free allocation to EU domestic producers.

Indian iron-and-steel exporters (HSN 7201-7229 + specific downstream products), aluminium exporters (HSN 7601-7616 + specific downstream), and fertilizer exporters (specific HSN codes per the Regulation Annex I) are in scope. Manufacturers in other product categories (automotive, machinery, electrical equipment) are not in present-day CBAM scope but the EU has signalled scope expansion — keeping product-level embedded-emissions infrastructure ready is increasingly common. Batchwise coordinates EU CBAM Declaration preparation through partner CA firms.

Workforce, contract labour, and Factories Act intersection

Manufacturing workforce structure is typically multi-tier and substantially relies on contract labour for non-core operations:

• Permanent workforce — operators, supervisors, technical and engineering, plant management, R&D, sales and marketing, corporate functions.
• Contract workforce — material handling, packaging, housekeeping, security, canteen, and increasingly specific production support operations. Contract Labour (Regulation and Abolition) Act 1970 and OSHWC Code 2020 apply.
• Apprentices and trainees — Apprentices Act 1961 obligations + NATS / NAPS programme participation; relevant under Principle 8 (skills development).
• Migrant labour — substantial in some sectors and clusters; the Inter-State Migrant Workmen Act 1979 and OSHWC Code 2020 disclosure obligations apply.

The Factories Act 1948 and the OSHWC Code 2020 (when fully notified — currently rules notified, full enforcement state-by-state) prescribe statutory occupational health, safety, and welfare obligations. This generates the underlying data for BRSR Principle 3 (Wellbeing) narrative — fatalities, lost-time injuries (LTI), high-consequence work-related injuries, occupational disease cases, training hours, safety committee functioning. Lost-time injury frequency rate (LTIFR) per million person-hours is typically reported even though not a BRSR Core line item.

Common Scope 3 categories

The dominant Scope 3 category varies materially by manufacturing sub-segment. Across published submissions, the patterns commonly observed are:

Category 1 (Purchased goods and services) — frequently the largest Scope 3 source for assembled-product manufacturers (automotive, capital goods, electrical equipment) due to embedded carbon in steel, aluminium, copper, plastics, batteries, and electronic components. Methodology depth + supplier-specific data quality scoring is increasingly disclosed.

Category 4 (Upstream transportation and distribution) — inbound logistics of raw materials and components from suppliers to plants. Predominantly road-based in India; rail for bulk; sea for imports of critical materials.

Category 9 (Downstream transportation and distribution) — finished-product logistics from plants to dealer networks, distributors, or direct customers. Substantial for automotive + consumer durables given high-tonnage road logistics.

Category 11 (Use of sold products) — often the single largest Scope 3 source for products that consume energy during use. Automotive (lifetime fuel / electricity consumption × expected vehicle life), electrical equipment (lifetime electricity consumption), industrial machinery (lifetime energy consumption per assumed duty cycle). For an automotive OEM selling 1 million ICE vehicles per year with an assumed 15-year life × 15,000 km/year × ~150 g CO₂/km, lifetime use-phase Scope 3 Cat 11 can exceed direct Scope 1 + 2 by an order of magnitude. The methodology is sensitive to assumed product life and use-phase efficiency.

Category 12 (End-of-life treatment of sold products) — material for products under E-Waste, Battery, or ELV EPR; the methodology relies on India-specific end-of-life pathway emission factors.

For methodology depth on Scope 3 calculation conventions, see the Scope 3 for Service Companies guide — most conventions translate; manufacturing’s Cat 1 + Cat 11 specifics require sub-segment-specific emission factors.

Comprehensive Scope 3 disclosure historically sat in Principle 6 Leadership (voluntary), but per the SEBI BRSR Core circular dated 12 July 2023, Scope 3 GHG disclosure is required from the top 250 listed entities on a comply-or-explain basis from FY 2024–25, with assurance phased from FY 2025–26 on the same basis. See the Value Chain Disclosure glossary entry.

Section A patterns specific to manufacturing

Several distinctive patterns:

1. Products-and-services breakdown — typically segmented by product category (passenger vehicles vs commercial vehicles vs 2W; or LV switchgear vs MV switchgear vs distribution transformers; or capital goods sub-category). The principal-products-by-turnover schedule frequently lists multiple product categories given multi-product portfolios; concentration varies substantially.
2. Plant footprint — Section A operations disclosure typically lists multiple plants across automotive clusters, industrial estates, SEZs, and DMIC nodes. Many entities supply the full plant register as an annexure with state-wise + UT-wise plant counts.
3. Workforce structure — multi-tier as described above; the mapping into BRSR’s employee / worker categorisation typically requires a documented internal mapping table. The contract-labour share of total workforce is commonly disclosed for transparency given OSHWC Code obligations. See the BRSR Section A Pre-fill Workflow for the operational walkthrough.
4. Subsidiary / group structure — listed manufacturing groups frequently have component subsidiaries, captive logistics, captive power, R&D subsidiaries, international subsidiaries (overseas manufacturing or trading entities), and joint ventures with global technology partners. Boundary basis (operational vs financial vs equity-share control) should be applied consistently with Ind AS 110 consolidation and the SEBI December 2024 Industry Standards.
5. CSR spend — Section 135 of the Companies Act 2013 typically applies to large listed manufacturers; the Section A CSR block is usually substantive. Manufacturing CSR commonly anchors on skill development (often tied to apprenticeship and ITI partnerships in plant-proximate communities), education, healthcare, water + sanitation, and rural infrastructure.

How Batchwise fits

Batchwise coordinates BRSR Core Assurance for listed manufacturing entities through its partner CA firm network. The BRSR Core sign-off is delivered under partner CA firm letterhead and DSC; Batchwise handles the operational layer — buyer onboarding, evidence ingestion via the document portal, partner CA firm assignment, status tracking, and a 72-hour SLA on the coordinated end-to-end.

For manufacturing entities exporting iron and steel, aluminium, or fertilizers to the EU, Batchwise also coordinates EU CBAM Declaration preparation — the quarterly embedded-emissions report (transitional phase) and the definitive-period CBAM certificate workflow from 2026 onward — through the same partner-CA-firm model. For standalone Scope 1 + 2 GHG verification (often required by global parent reporting or by enterprise customers in automotive supply chains), ISAE 3410 is coordinated under the same model. For manufacturers in scope for value-chain ESG disclosures (top 250 listed entities, comply-or-explain from FY 2024–25), BRSR Value Chain Verification covers the upstream supplier cohort that crosses the 75% / 2% materiality thresholds.

See also: Document and Evidence Requirements for the artifacts the assurance provider expects, GHG Protocol glossary entry for the underlying accounting framework, and Materiality Assessment Walkthrough for the upstream scoping step that drives which Core attributes the engagement focuses on.