Embracing Circularity — Waste Generated + Recycled Intensity — BRSR Core Attribute

What this attribute is

Embracing Circularity is one of the nine BRSR Core attributes that SEBI requires every Top-1,000 listed entity to subject to independent reasonable assurance under SAE 3000 (Revised). It sits within NGRBC Principle 6 — Environment and is the only BRSR Core attribute whose primary metric is a ratio of material flows (recycled + reused vs disposed) rather than an intensity per rupee.

The attribute captures three numbers:

1. Total waste generated in metric tonnes, split by category (plastic, e-waste, biomedical, hazardous, etc.)
2. Waste recycled + reused vs disposed split (% of total)
3. Recycled input % — share of input materials sourced from recycled / reclaimed sources

ESG-rating screens + circular-economy benchmarks both anchor on the recycled / reused % — a higher number signals more closed-loop material flow and lower landfill / incineration dependence.

What’s in scope — the waste categories

Per the BRSR format Principle 6 Essential Indicator 6, waste is reported separately for each of the following categories:

Category	Governing Indian rules	Typical sources
Plastic waste	Plastic Waste Management Rules 2016 (amended through 2024)	Packaging, process-waste plastic, MLP, flexible plastic
E-waste	E-Waste Management Rules 2022	End-of-life computers, monitors, servers, mobile phones, lab instruments
Bio-medical waste	Bio-Medical Waste Management Rules 2016	Hospital / clinic / lab waste; relevant for pharma + healthcare entities
Construction + demolition (C&D) waste	C&D Waste Management Rules 2016	Site demolition + new-build excavation; large quantities for real estate + infrastructure
Battery waste	Battery Waste Management Rules 2022	Lead-acid, Li-ion, Ni-Cd; UPS batteries, vehicle batteries, EV batteries
Radioactive waste	Atomic Energy (Safe Disposal of Radioactive Wastes) Rules 1987	Nuclear / atomic-energy entities only
Other hazardous waste	Hazardous + Other Wastes Rules 2016 — Schedule I categories	Spent oil, acid + alkali solutions, paint sludge, incinerator ash, contaminated containers
Other non-hazardous waste	(no specific rule; municipal solid waste rules apply)	Canteen waste, office paper, general scrap

Each category is reported separately in metric tonnes (tonnes; some entities use kg for very small quantities), then aggregated.

The recycled / reused / disposed split

For each waste category, three flows are reported:

• Recycled — waste sent to an authorised recycler for material recovery. The recycler must be CPCB / SPCB authorised for that waste category. Evidence: recycler authorisation certificate + weighbridge slips + EPR credit certificates (for plastic / e-waste / battery).
• Reused — waste returned to the production process or to a different downstream use without material conversion. E.g., process water reused after treatment, packaging returned to vendor, scrap metal returned to the casting furnace.
• Disposed — waste sent to landfill, incineration without energy recovery, deep-well injection, or other terminal disposal. For hazardous waste, disposal must be at a CPCB / SPCB authorised TSDF (Treatment, Storage + Disposal Facility).

The headline circularity metric is:

Recycled + Reused %  =  (Recycled tonnes + Reused tonnes)
                      ÷ Total waste generated tonnes

A higher % signals stronger circularity. Year-on-year movement is the key ESG-rating signal.

Recycled input percentage

The companion upstream metric:

Recycled Input %  =  Mass of input materials from recycled / reclaimed sources
                   ÷ Total mass of input materials

For a downstream manufacturer using recycled aluminium scrap as feedstock, recycled plastic flake for packaging, or reclaimed steel for structural components — the recycled-input % captures the upstream circular sourcing. The denominator is total mass of input materials (raw materials + process consumables) per the production records; the numerator is the recycled / reclaimed portion documented from supplier certifications.

This metric is disclosed under Principle 6 Essential Indicator 5 (alongside total input material details) and is part of the BRSR Core assurance scope.

Worked example

Mid-size FMCG entity for FY 2025-26.

Waste output

Category	Generated (t)	Recycled (t)	Reused (t)	Disposed (t)
Plastic waste	420	380	0	40
E-waste	8	8	0	0
Battery waste	2	2	0	0
Other hazardous waste	120	30	0	90
Other non-hazardous waste	350	60	220	70
Total	900	480	220	200

Recycled + reused % = (480 + 220) / 900 = 77.8%

Recycled input

Input material	Total mass (t)	Recycled portion (t)
Aluminium sheet	1,200	600 (recycled-content aluminium)
HDPE packaging	480	240 (recycled-content HDPE)
Paper packaging	150	90 (recycled-content kraft)
Steel components	350	0 (virgin only)
Total	2,180	930

Recycled input % = 930 / 2,180 = 42.7%

For year-on-year comparison: FY 2024-25 recycled+reused output % was 71.2% (up 6.6 pp YoY) and recycled input was 35.4% (up 7.3 pp YoY). Both improvements track the entity’s circularity commitments under the Plastic Waste EPR programme + the aluminium recycled-content procurement policy.

Evidence the assurance partner checks

Document	What it evidences	Issued by
Form 10 manifest	Hazardous waste transfer to recycler / TSDF	SPCB-issued; carried with each transport
Form 4 annual return	Aggregate hazardous waste generated + disposed for the FY	SPCB-issued; entity files annually
Plastic Waste EPR certificate trail	EPR credit retirement against plastic introduction quantity	CPCB EPR portal
E-Waste EPR certificate trail	EPR credit retirement against EEE introduction quantity	CPCB EPR portal
Battery EPR certificate trail	EPR credit retirement against battery introduction quantity	CPCB EPR portal
Recycler authorisation certificate	The recycler is authorised for the specific waste category	SPCB / CPCB (per category)
Weighbridge slips	Quantity-level evidence of each transfer	Entity’s weighbridge + recycler’s weighbridge
Supplier recycled-content declarations	Recycled input % numerator	Supplier-issued
Internal waste register / EHS database	Internal aggregation of all waste flows	Entity’s EHS system

Common audit findings

1. Unauthorised recycler chain. Plastic waste routed through an unregistered aggregator before reaching the authorised recycler — breaks the EPR credit chain + creates ESG-rating risk. The recipient at the first transfer point must be CPCB / SPCB-authorised for that category.
2. EPR credit double-counting. Same plastic waste tonnage counted as “recycled” by both the brand owner + the recycler; under EPR, the credit certificate is assigned to one party (typically the producer / brand owner) and that’s the only count valid for the BRSR recycled flow.
3. Hazardous waste — Form 10 manifest gaps. Transfer to authorised TSDF without Form 10, or with mismatched quantities between Form 10 + weighbridge slip. The variance must be reconciled + documented.
4. Recycled vs reused confusion. Process water reused after treatment is recorded as “recycled” instead of “reused” (or vice versa). The distinction matters because the recycled bucket implies material recovery (a downstream recycler converts the waste into a new product), while reused implies same-use without conversion.
5. Non-hazardous waste under-captured. Office paper + canteen waste + general scrap is often estimated rather than measured. Best practice: monthly weighbridge entries or contracted municipal pick-up records.
6. Battery waste not categorised. UPS batteries replaced under AMC, EV / forklift batteries replaced + handed to vendor under buy-back — these get missed from the battery-waste line. Battery waste has its own EPR framework under Battery Waste Management Rules 2022.
7. C&D waste under-recognised. New-plant construction or major shutdown demolition generates large quantities of C&D waste that the EHS team doesn’t always capture (the project team manages it). Need integration between project waste tracking + EHS database.
8. Recycled input — supplier declaration not retained. Recycled-content claim from supplier (e.g., “75% recycled HDPE”) needs a written supplier declaration retained as workpaper evidence. Verbal / email confirmation is insufficient for reasonable assurance.

EPR (Extended Producer Responsibility) intersection

For plastic packaging + e-waste + batteries, the EPR framework imposes a parallel obligation: the producer / importer / brand owner (PIBO) must collect + recycle / dispose of waste equivalent to its annual introduction quantity into the market. EPR fulfilment is tracked via the CPCB EPR portals (separate portals for plastic, e-waste, battery).

For BRSR purposes:

• The waste-output figure captures internal waste generated by the entity’s operations
• The EPR credit retirement captures end-of-life waste of products the entity introduced into the market

These are different denominators. An FMCG entity that introduced 1,000 tonnes of plastic packaging may have generated 50 tonnes of plastic waste internally (process scrap) and retired EPR credits equivalent to 1,000 tonnes (covering end-of-life packaging). Both flows are reported, but in different parts of BRSR — the 50 tonnes goes into the Principle 6 EI 6 waste table; the EPR credit retirement is part of the producer responsibility narrative under Principle 2 (Sustainable Products).

For the upstream Principle 2 framework, see NGRBC Principle 2 — Sustainable Products.

XBRL filing

This attribute is filed in the BRSR XBRL instance document under the Principle 6 Essential Indicator 5 (recycled input) + Essential Indicator 6 (waste output) elements from the MCA-published BRSR taxonomy module. Per-category waste quantities + recycled / reused / disposed breakdown + recycled input % are filed as separate elements. Verify element names + unit references against the current MCA taxonomy version before generating the instance document.

Both current-year and previous-year context references must be populated with matching boundary disclosure. See XBRL Taxonomy for BRSR for the structural overview.

How this attribute rolls up into the BRSR Core engagement

This attribute is one of the four Core attributes under Principle 6 (alongside GHG, water, and energy). The signed BRSR Core assurance report attests these numbers to reasonable assurance under SAE 3000 (Revised). Workpapers retained by the assurance partner cover the per-category waste reconciliation, Form 10 manifest sampling, EPR credit certificate trails, recycler authorisation verification, and boundary alignment with the parent entity scope.

For the engagement that produces the signed assurance opinion, see BRSR Core Assurance.

Related reading

• NGRBC Principle 6 — Environment — parent pillar
• NGRBC Principle 2 — Sustainable Products — EPR + product life-cycle linkage
• GHG Emission Intensity per Revenue — sibling Core attribute
• Water Withdrawal Intensity — sibling Core attribute
• Energy Footprint Disclosure — sibling Core attribute
• Document Evidence Requirements — full evidence checklist including waste documents
• XBRL Taxonomy for BRSR — XBRL filing structure
• BRSR Core Assurance — service