Frequently Asked Questions
Find clear answers to common questions about our compliance services, registration processes, and corporate advisory.
India's Green Credit Programme and carbon credit initiative focus on Sustainable Agriculture-based Green Credit, aiming to encourage natural and regenerative agricultural practices and land restoration. The goal is to enhance productivity, soil health, and the nutritional value of the food produced.
The types of green credits are as following:
- Forest & Ecosystem Credits.
- Air Quality Credits.
- Water Quality and Access Credits.
- Waste Management Credits.
- Energy Efficiency Credits.
- Renewable Energy Generation Credits, among others.
Any manufacturing activity being conducted by a business entity may or may not involve the generation of any kind of pollution, be it air, water or noise pollution. As per the Central & State Pollution Control Board guidelines, these manufacturing activities are considered white or green category business activities.
Then there are orange & red category of manufacturing activities, which involve generation of air pollution or water, noise pollution. For this, the installation of pollution control devices such as ETP, STPs, Dust collector, besides other pollution control measures are undertaken to mitigate the effect of manufacturing activity.
The Environmental Audit is performed at regular intervals to check whether the pollution control devices & other pollution control measures being undertaken are effective or not, whether more is required to be done to further tighten the grip around generation and control of pollution.
The process of Environmental auditing is an organized, scientific and time interval-based technique to ascertain a manufacturing entity ’s effectiveness & efficiency for:
How the business entity is performing on relevant statutory and internal requirements
Ensuring that top management is monitoring the environmental practices
Creating awareness & promoting good environmental management
Maintaining credibility with the public that our future generations will be free from pollution
Regular training & workshops for staff awareness and enforcing commitment to departmental environmental policy
Continuously exploring improvement opportunities for fighting pollution
Establishing the minimum standards for developing a credible Environmental Management System (EMS)
The process of Environmental Audit consists of following three phases.
Pre – Audit phase
Audit Phase
Post – Audit phase
Pre-Audit Phase
At the pre-audit stage, the business entity desirous of Environmental Audit is required to allot human & other resources for the whole audit process. The business entity is also needed to prepare an audit plan and the documents required for the environmental audit.
Audit Phase
After the pre-audit phase is complete, the business entity may proceed with the actual audit. The audit team is expected to follow the standards & procedures laid down during the pre-audit phase. The audit team in this phase is required to conduct site inspections and interviews, evaluate teams and perform document reviews, as per the guidelines of the Govt. Environment Body. After this is done, the audit lead team is required to prepare thorough Environmental Audit Reports.
Post - Audit Phase
In the Post-Audit phase, the Audit team should reflect on the data generated and reports of environmental audit thus prepared so that the areas of improvement could be found out and steps to mitigate the pollution are undertaken.
There are three main types of environmental audits that a company may conduct. These are as follows:
Environmental compliance
Environmental Management System (EMS) audits
Functional environmental audits
Environmental Compliance Audits
Environmental compliance audits, as the name suggests, determines whether the business entity is compliant regarding those particular pollution control devices and pollution control measures which were delineated during the issuance of the State/ Central Pollution Control Certificate.
Every manufacturing activity is required to get a certificate from State Pollution Control Board. When a Pollution Certificate is issued, the requirements of pollution control device & other pollution control measures are mentioned in the Pollution Board Certificate. The focus of the environmental compliance audit is to ascertain whether the business entity is following all or most of the parameters as mentioned in the Pollution Board Certificate. Other Pollution Board certificate such as Environment Impact Assessment – Environment Clearance (EIA-EC) also includes the conditions which are required to be fulfil during the operation of a particular manufacturing/infrastructure/mining activity.
Environmental Management System (EMS) audits
The Environmental Management System (EMS) Audits is an audit process in which the EMS of an organization, engaged in manufacturing, infrastructure development or mining, is evaluated to ascertain whether the system is effective enough to maintain the benchmark performance of the pollution control devices and other pollution control measures. The EMS Audit is conducted as per the guidelines of Clause 9 of the ISO 14001:2015. This performance is done to ensure:
That the Environmental Management System is proving effective in monitoring & controlling the air, water & noise pollution.
The EMS is properly inspected in terms of its expected performance standards.
The evaluation of objective of the EMS and its targets is undertaken.
To identify new targets or opportunities.
Ascertaining whether the EMS is fulfilling the organizational, stakeholder and legal requirements.
Periodic Review of the EMS for its perpetual suitability, adequacy and effectiveness.
To ensure continual improvement in a particular EMS.
Functional Environmental Audits
Functional Environmental Audit is a process under which specific compliance conditions are monitored and inspected for adherence to the Pollution Control Board Guidelines. For example, if an Effluent Treatment Plant (ETP) or a Sewage Treatment Plant (STP) is installed as a pollution control device to check water pollution, then the functional environmental audit would be focused on whether the treated water from the outlet of the ETP or STP satisfies the limits of concentration of hazardous materials in the treated water, if it is found to be wanting on these parameters, then the functional environmental audit would suggest the measures to be taken to mend this leakage of pollutants in the water body.
The first document required for an Environmental Audit is the site plan, layout plan or key plan. This is required to define the scope of the audit along with any changes done to the premises
The Consent to Establish (CTE), Consent to Operate (CTO), Environmental Clearance (EIA-EC) certificates, along with any EPR certificate, if the Business entity is engaged in plastic, electronics, battery or tyre manufacturing or import.
Previous environmental inspection reports and checklists to ascertain that inspections have been conducted and recorded at regular time intervals. The Hazardous waste manifests, sampling data, and other inspection reports are also required to establish a sound record keeping.
The raw purchase data, units manufactured & distribution, of all chemicals and other raw materials used, their locations, and quantities to find out the environmental regulations applicable to the facility.
The documents about Environmental Plans and procedures, best management practices and other applicable documents to show how the business entity is managing environmental issues and preventing problems. Also required are the EPA Risk Management Plan, Standard Operating Procedures (SOP’s) and written emergency response programs, if applicable.
The training records of technical persons, radiation safety official, chemical handing certificate etc to ensure that the employees are adequately trained to handle their daily tasks. The medical reports of some employees to ascertain whether the work of the employee is any anyway affecting his/her physical health.
- The Batteries Management and Handling Rules were adopted in 2001 with the primary goal of ensuring the safe disposal of discarded lead acid batteries with the participation of all stakeholders. To ensure environmentally sound recycling of used batteries, rules have been established to ensure proper monitoring and record keeping on the selling or import of lead acid batteries, as well as the storage of used batteries for recycling by registered recyclers.
- Improper lead handling and recycling could endanger workers' health and have a negative effect on the environment. As a result, it is critical to ensure that secondary lead processing takes place in facilities that are registered with the Central or State Pollution Control Boards in an environmentally sustainable manner. It is essential to ensure that all recyclables are directed to approved recycling facilities. It is also necessary to put an end to the widespread practice of smelting used lead acid batteries in backyards throughout the Country.
- Manufacturers, importers, reconditioners, and assemblers have responsibilities under the Batteries Rules to ensure that used batteries are collected and routed to Authorized recyclers. Other stakeholders, such as retailers, recyclers, customers, auctioneers, and regulators, including customs authorities, were also assigned responsibilities.
- Every manufacturer, producer, importer, recycler, and bulk consumer involved in the manufacture, processing, sale, purchase, collection, storage, reprocessing, and use of batteries or their components, including their components, consumables, and spare parts that make up the product operational
- All types of batteries, regardless of form, length, weight, material composition, or use, as specified in Schedule-I;
- All appliances into which a battery is or may be fixed to operate
- Person who is generating battery waste must obtain permission from the State Pollution Control Board or the Pollution Control Committee of the Union territories concerned, as the case may be;
- He must submit an application in Form 2(A) to the State Pollution Control Board or the Pollution Control Committee for authorization.
- Following receipt of a complete application for authorization in all respects, the State Pollution Control Board or the Pollution Control Committee of Union territories can, after making any inquiries it deems necessary and being satisfied that the applicant has appropriate facilities, technical capabilities, and equipment to safely handle battery waste, grant a permit within ninety days in form no 2(B) and it is valid for five years.
- Every person authorized under these rules must keep a record of the battery waste they handle in Form 6 and prepare and submit an annual return containing the information stated in Form 1 to the State Pollution Control Board or Pollution Control Committee on or before the 30th day of June following the financial year to which the return relates.
The applicant is required to submit the above stated documents, along with the application, in a prescribed format, to the State Pollution Control Board. The concerned officer may inspect the premises where the battery materials are being used and may issue some clarifications. Once the clarifications issued by the Inspecting Authority are suitably submitted, the Battery waste Management Authorization certificate is issued.
The Government fee for Battery Waste Management (BWM) Authorization certificate may range from NIL to up to Rs.10,000 depending on the State Pollution Control Board. If an agency is hired for the same, it may charge you some fee. Metacorp charges Rs.10,000 as consulting fee for end to end delivery of Battery Waste Management (BWM) Authorization certificate.
- GST Certficate
- Pan card of unit
- Authorization letter, in case of Private/Public Limited Company
- Rent Agreement/Ownership proof
- Valid CTO/CFO
- Battery Waste Recycer collection agreement
- ‘Battery’ or ‘’accumulator’’ means any source of electrical energy produced by direct conversion of chemical energy, including disposable primary (Alkaline/Mercury/Silver oxide/Zinc Carbon) batteries, rechargeable secondary (Lead Acid/Lithium Ion/Lithium Metal/Nickel Cadmium) batteries, and any other battery that contains (or may produce) potassium hydroxide at the end of its life.
- Extended Producer Responsibility (EPR) refers to any battery manufacturer's responsibility for their products beyond production before environmentally sound end-of-life management; and for the channelization of waste batteries to ensure environmentally sound waste management. Implementing a take-back scheme, setting up recycling centres, or both, and making agreed agreements with registered recyclers either individually or jointly through a Producer Responsibility Organization acknowledged by producer or producers in their Extended Producer Responsibility are examples of Extended Producer Responsibility. - Authorization;
- ‘Producer' refers to someone who: i. manufactures and offers to sell batteries and their components, consumables, parts, or spares under their own brand; or ii. manufactures or offers to sell equipment / products that use a battery or batteries as a component under their own brand; or iii. offers to sell assembled battery under their own brand.
The documents required for Plastic EPR Registration as a producer are as following:
- GST
- Pan card of Unit
- CIN
- Aadhar card and pan card of Authorized Person
- SPCB CTO
- Total Area (Sq ft.) -
- Picture with GEO tagging of -
- Raw Material Area
- Production Area
- Dispatch Area
- Video of Processing Area
- Name of Machinery & Details of Machinery-
- Production Hrs
- Picture of Machine
- Sales and purchase bill of last two years
The documents required for Plastic EPR as brand owner are as follows:
- CIN Registration(For Private limited company)
- GST Registration
- Aadhar card + PAN Card of Authorized Person
- Picture of Products
- SPCB CTO consent
- State wise sales data and procurement data for last two years
To submit annual compliances for the Battery EPR Registration, the following steps are to be followed:
Sale/purchase data upload
The Battery EPR Registration holder is required to login into the CPCB Battery EPR portal and upload the sale/purchase data/invoices on the CPCB portal
Recycling Credits / obligation Transfer
The applicant is required to transfer the recycler credits to his/her account, from the CPCB registered recycler. The recycler credits to be transffered can be known by logging into the CPCB Battery EPR Portal
Submission of Govt fee for annual compliances
The applicant is required to submit the Govt. fee for annual compliances for battery EPR. This may range between Rs.2500 to Rs.10,000
The following entities are required to get a Battery EPR Registration:
- Manufacturers of Lead-Acid & Lithium-ion Batteries
- Importers of lead-acid & Lithium-ion batteires
- Recyclers of lead-acid & lithium-ion batteries
Targets for Extended Producer Responsibility Authorization (EPRA)
Targets forLithium-ion Batteries
During the first two years-
30% of the quantity of waste generation as indicated in EPR Plan
During the third and fourth years-
40% of the amount of waste generation as indicated in EPR Plan
During the fifth and Sixth years-
50% of the amount of waste generation as indicated in EPR Plan
Seventh year onwards-
70% of the amount of waste generation as indicated in EPR Plan
Targets for Lead Acid Batteries
During the first two years - 90% of the quantity
During the third and fourth years- 100% of the quantity
The Government fee for filing Battery EPR Compliances is Rs.2,500, it may increase depending on the recycling target. Also the battery recycling credits are to be procured from a CPCB registered battery waste recycler, the cost of which may vary.
The Govt fee for Battery EPR annual compliances are as following:
| S.No | Annual Turnover Slab (Rs. crore) | Govt fee. (Rs.) |
| 1. | 5 | 2500 |
| 2. | 5>50 | 5000 |
| 3. | >50 | 10000 |
The documents required for EIA-EC certification are as following:
- CIN certificate
- PAN card of the company
- Aadhar card + PAN card of authorized person
- Email ID for registration
- Proposed capacity of hospital
- Plant Layout/site plan
- Permanent Employment during construction phase, if any
- Temporary Employment during construction phase
- Temporary employment during operation phase, if any
- Permanent Employment during operation phase
- Land ownership/lease documents
- Plot area bifurcation as Green area, Built-up area and Open & Paved area
- Water requirement and source
- Water usage breakup/ water balance
- Power requirement and source
- DG set capacity
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