Frequently Asked Questions
Find clear answers to common questions about our compliance services, registration processes, and corporate advisory.
Plastic as a material is not an issue, the issue is how to manage the waste of plastic. As per various surveys conducted, India generates 26000 tonnes of plastic waste every day from urban areas. Plastic waste has negative impact on the environment, especially on marine life, which comes from land based activities. Plastic is a unique material and its application ranges widely, from packaging of food items to medical and engineering equipment. The Plastic Waste Management (PWM) Rules, 2016 clearly state that Urban Local Bodies (ULBs) should monitor that nobody can use less than 50 microns thick plastic bags and not allow usage of recycled plastics for packing of food items including beverages. The Rules also require that local bodies should provide separate collection, storage, and processing of plastic waste in their areas.
The Plastic Waste Management (PWM) Rules, 2016 make an arrangement to reduce the negative impact on the environment-related to plastic waste, in today’s era plastic is a wonder material and its use is almost impossible to ban. Under the PWM rules, authorities like Urban Local Bodies and Panchayats should provide separate collection, storage, and processing of plastic waste in their areas.
- Monitor and facilitate to use of more than 50 micron plastic carry bag
- Plastic has reached in rural area and therefore it expands jurisdiction of applicability from the municipal area to rural areas
- To set responsibilities to producer and generator of plastic waste to take back waste from the market in respect of their target as Extended producer responsibility (EPR)
- To create awareness in the civil societies to minimize the use of plastic
- To promote use of plastic waste for road construction as per Indian Road Congress guidelines or energy recovery, or waste to oil etc.
- Polyethylene Terephthalate (PETE)
- High-Density Polyethylene (HDPE)
- Polyvinyl Chloride (PVC - U)
- Polypropylene (PP)
- Polystyrene or Styrofoam (PS)
- Low-Density Polyethylene (LDPE)
- Others
- Producers or Brand Owners of plastic products
- Units Engaged in Processing or Recycling of Plastic Waste
- Manufacturers of Plastic Raw Materials
- Pan card and Aadhar Card of Authorized person
- Authorization Letter (except Proprietorship)
- Layout Plan/ Naksha
- Consent to Operate (CTO) from State Pollution Control Authority
- Agreement with Authorized Recycler
- Rent Agreement/Proof of Location
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 plastic materials are being used and may issue some clarifications. Once the clarifications issued by the Inspecting Authority are suitably submitted, the Plastic waste Management Authorization certificate is issued.
The Government fee for Plastic Waste Management (PWM) 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 Plastic Waste Management (PWM) Authorization certificate.
- 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, collection centre, importer, reconditioner, refurbisher, dismantler, assembler, dealer, recycler, auctioneer, vehicle service centre, consumer, 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.20,000 as consulting fee for end to end delivery of Battery Waste Management (BWM) Authorization certificate.
- Pan Card and UID of Authorized of Unit
- Pan card of unit
- Authorization letter
- Rent Agreement/Property paper
- GST
- IEC
- COI
- MOA and AOA/Partnership deed
- Valid CTO
- Valid Authorization
- Capacity certificate
- Any producer of battery/battery-containing equipment must apply for EPR Authorisation in Form 3 to State Pollution Control Board Pollution Control Committees in the case of selling their product in one state or to the Central Pollution Control Board in the case of selling their product in more than one state within three months of the date of commencement of these rules.
- In the case of a pan-India authorization, upon receipt of a complete application in all respects, a committee constituted by Central Pollution Control Board (CPCB) with representatives from State Pollution Control Board (SPCB) or Pollution Control Committees(PCC), after evaluating the State-specific EPR Plan, after such an inquiry as it deems appropriate, and on being satisfied that the producer has detailed out an effective system to manage Extended Producer Responsibility, The EPR-Authorization would be valid for a maximum of five years at first.
- ‘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.
Permission from the Ministry of Environment, Forest and Climate Change (MoEFCC) is a mandatory requirement for the import and export of specific categories of goods, particularly hazardous and other wastes. This regulation is governed by the Hazardous and Other Wastes (Management and Tran’s boundary Movement) Rules, 2016, and is a critical part of India's commitment to international environmental agreements like the Basel Convention.
Purpose of the MoEFCC Permission
The core purpose of this permission is to ensure that the Trans boundary movement of waste is conducted in an environmentally sound and responsible manner. Key objectives include:
• Preventing Illegal Dumping: The rules strictly prohibit the import of hazardous waste for the purpose of disposal in India.
• Facilitating Resource Recovery: The import of waste is permitted only for legitimate purposes such as recycling, recovery, reuse, and co-processing, which are essential for a circular economy.
• Environmental Safeguards: The permission process requires importers and exporters to demonstrate that they have the necessary infrastructure, technology, and processes to handle the waste safely and prevent environmental harm.
• International Compliance: It ensures that India fulfills its obligations under the Basel Convention, which regulates the movement of hazardous waste between countries.
The MoEFCC permit is required for a wide range of materials listed in the Schedules of the Hazardous and Other Wastes Rules, 2016. These generally include:
• Hazardous Wastes: This covers a broad spectrum of industrial, chemical, and metal-bearing wastes that are toxic, flammable, or otherwise harmful.
• E-Waste: Electronic and electrical assemblies, components, and scrap that are often imported for refurbishment, recycling, or as spare parts.
• Waste Tires and Rubber Scrap: Used tires and rubber scrap that are imported for recycling into crumb rubber or other products.
• Used Oil and Lead Scrap: These are commonly imported for reprocessing and reuse.
The import of hazardous and other wastes into India is a highly regulated process governed by the Hazardous and Other Wastes (Management and Trans boundary Movement) Rules, 2016. The procedure is designed to ensure that waste is not imported for illegal dumping and that it is only used by authorized entities for environmentally sound recycling, recovery, or reuse.
Eligibility and Authorization
• Actual User Status: Only an "actual user" is permitted to import hazardous and other wastes. An actual user is an industry that utilizes the waste as a raw material in its production process. A trader may also import on behalf of an actual user, but they must have a one-time authorization for this purpose.
• Valid Authorizations: The importer must possess valid authorizations and consents from the State Pollution Control Board (SPCB) for the handling and management of hazardous waste and a valid "Consent to Operate" under the Air and Water Acts.
Application for Permission (NOC)
• Application to MoEFCC: The importer must submit an online application in Form 5 to the Ministry of Environment, Forest and Climate Change (MoEFCC) through the designated portal (e.g., the National Single Window System).
• Simultaneous Submission to SPCB: A copy of the application must be simultaneously submitted to the concerned State Pollution Control Board (SPCB) for their review and comments. The acknowledgment of this submission from the SPCB must be included in the application to the MoEFCC.
• Justification and Technical Details: The application must include a detailed justification for the import, including a process flow chart showing how the waste will be handled, processed, and utilized.
The export of hazardous and other wastes from India is a highly regulated process governed by the Hazardous and Other Wastes (Management and Trans boundary Movement) Rules, 2016. The procedure is designed to ensure compliance with the Basel Convention, a global treaty that prevents the dumping of hazardous waste in countries that lack the capacity to manage it.
The overall principle is that waste can only be exported to an "actual user" or a facility with the capacity for environmentally sound management, and only with the explicit consent of the importing country.
1. Determine Eligibility and Type of Waste
• Permitted Wastes: Export is generally allowed for wastes that are listed in the schedules of the 2016 Rules, such as certain types of e-waste, metallic scrap, or waste oils, but only for recycling, recovery, or reuse.
• Exporter Status: The exporter must be the actual generator or a party authorized to handle the waste.
2. Obtain Prior Informed Consent (PIC)
• Mandatory for Certain Wastes: For highly restricted hazardous wastes listed in Part A of Schedule III and Schedule VI of the Rules, the exporter must obtain a Prior Informed Consent (PIC) in writing from the competent authority of the importing country. This is a crucial step and without it, the export cannot proceed.
• Documentation: This consent is a formal letter acknowledging that the importing country is aware of the waste's nature and has agreed to receive it.
3. Application for Permission (NOC)
• Application to MoEFCC: The exporter must submit an online application in Form 5 to the Ministry of Environment, Forest and Climate Change (MoEFCC). This is the central permission-granting authority.
• Supporting Documents: The application must be accompanied by a comprehensive set of documents, which include:
-- The Prior Informed Consent (PIC) from the importing country.
-- A valid Consent to Operate from the State Pollution Control Board (SPCB) and a valid authorization for hazardous waste management.
-- A copy of the agreement or contract with the buyer/importer.
-- Proof of adequate insurance coverage for the Trans boundary movement, which must cover both transit and any potential clean-up operations in case of an accident.
-- A notarized undertaking from the exporter, including a commitment to take back the waste if it is rejected by the importer.
-- A detailed chemical analysis report of the waste from an accredited lab.
The import and export of a wide range of materials require prior permission from the Ministry of Environment, Forest and Climate Change (MoEFCC). This is primarily to regulate the Trans boundary movement of hazardous and other wastes, as stipulated under the Hazardous and Other Wastes (Management and Tran’s boundary Movement) Rules, 2016.
The specific items that require prior permission are detailed in the various schedules of these rules. The level of restriction and the documents required vary depending on the type of waste
Hazardous Wastes
This is the most significant category, covering materials that are toxic, corrosive, flammable, or otherwise harmful. Permission is required for both import and export of these materials, which are categorized in the following schedules:
• Schedule III (Part A): This lists hazardous wastes that require Prior Informed Consent (PIC) from the importing or exporting country. These are typically highly restricted wastes, such as those containing toxic metals (e.g., lead, cadmium), waste mineral oils, and certain chemical residues.
• Schedule VI: This list includes specific hazardous wastes that are banned for import and export.
Other Wastes (for recycling and reuse)
The MoEFCC rules also regulate the import of certain non-hazardous wastes that are considered valuable resources for recycling. These wastes are listed in:
• Schedule III (Part B): This includes "other wastes" that can be imported for recycling, recovery, or reuse without prior permission from the MoEFCC, provided they meet certain conditions and are not mixed with hazardous wastes. Examples include certain types of plastic scrap, paper waste, and glass cullets. However, if these wastes are mixed with any hazardous material, they fall under the strict permission requirements.
• Used Tires and Rubber Scrap: Import of used tires is regulated and requires a permit.
E-Waste (Electronic Waste)
The import and export of used electrical and electronic assemblies, equipment, and their components are strictly controlled. This is to prevent India from becoming a dumping ground for e-waste from developed nations. Prior permission is required for the import of items like:
• Used Electrical and Electronic Assemblies (EEAs): This includes items like used computers, printers, and medical equipment. Permission is often granted with the condition that the items are for a specific purpose (e.g., refurbishment, repair) and must be re-exported after use.
• Used Electrical and Electronic Equipment (EEEs): The import of certain used, high-value medical equipment also requires a permit from the MoEFCC.
The documents required for Import/Export Permission from MoEF&CC depend on the type of material (Hazardous Waste, Ozone Depleting Substances, Wildlife, Plastic Waste, etc.).
But MoEF&CC has prescribed some common mandatory documents across categories, plus category-specific documents.
Common Documents required (for all applications)
1. Application Form – submitted through Parivesh Portal (https://parivesh.nic.in).
2. Company Documents
-- IEC (Import Export Code from DGFT)
-- PAN, GST, CIN / MSME certificate
-- Company incorporation/registration certificate
3. Authorization from SPCB/PCC (State Pollution Control Board or Pollution Control Committee) – e.g., Hazardous Waste Authorization.
4. Detailed Project/Activity Report with purpose of import/export.
5. Material Details
-- Type of material (waste, ODS, wildlife item, plastic, etc.)
-- Quantity, physical/chemical composition
-- HS Code / Customs Tariff Code
-- Country of origin / destination
6. Agreement/Contract between Importer & Exporter (if applicable).
7. Undertaking / Affidavit on compliance with MoEF&CC rules.
8. Digital Signature Certificate (DSC) of authorized signatory.
Category-Specific Documents
1. Documents required for import /export of hazardous waste
• Justification for import
• Valid State Pollution Board CTO / CCA & HW Authorization
• Copy of lead analysis report in soil, air, water, stack and blood of the workers.
• Process flow chart indicating adequate pollution control equipment including alkaline scrubber and battery breaking system for unit of more than 10,000 MTA of ISRI Code RAINS.
• Photographs & Video CD of running plant.
• Acknowledgement for receipt of copy of application from the Concerned State Pollution Control Board (SPCB) / Pollution Control Committee (PCC)
2. Documents required for Import of PET scrap/plastic scrap/Acrylic plastics etc
• Justification for import
• Valid Consent to Operate under Water Act, I9Z4 and Air Act, 1981.
• Process flow chart indicating adequate pollution control equipment.
• Exporter's certificate for virgin plastic from industries except for import of PET bottle scrap
• List of users
• Photographs & Video CD of running plant.
• Acknowledgement receipt of copy of application from concerned State Pollution Control Board (SPCB) / Pollution Control Committee (PCC)
3. Documents required for Import of waste tyres/rubber scrap
• Justification for import
• Valid Consent to Operate under Water Act, L9T4 and Air Act, 1981.
• Process flow chart indicating adequate pollution control equipment.
• List of users
• Photographs & Video CD of running plant.
• Acknowledgement for receipt of copy of application from concerned state Pollution control Board (SPCB)/ Pollution Control Committee (PCC)
Note: The application for, import of waste tyres for purpose of the manufacture of Tyre Pyrolysis Oil (TPO) through pyrolysis process is not being considered by the Expert Committee (EC) due to pending decision at DGFT
4. Documents required for import of EEAs for repair in India and re-export
• Justification for import
• Undertaking for re-export
• Details of previous import, if there has been any and confirmation regarding their re- export
• Acknowledgement for receipt of copy of application from concerned State Pollution Control Board (SPCB)/ Pollution Control Committee (PCC)
5. Documents required for Import of used EEAs on Loan / testing purpose/ projects/R&D
• Justification for import
• If being imported on returnable basis than undertaking for re-export
• Chartered Engineer Certificate indicating the manufacturing date, residual life and serial number.
• Details of previous import, if there has been any and confirmation regarding their re- export
• Acknowledgement for receipt of copy of application from concerned State Pollution Control Board
6. Documents required for Import of used EEAs for their re-use
• Justification for import
• If being imported on returnable re-export Rules,2OO8 basis then undertaking for re-export
• If refurbished components being imported as replacement to defective component then undertaking for export of equivalent numbers of defective components
• Chartered Engineer Certificate from exporting Country indicating the manufacturing date, residual life and serial number.
• Details of previous import, if there has been any and confirmation regarding their re- export.
• In case of capital items particularly medical equipment the fact that the machine has been refurbished at the OEM factory and after sales service is provided by the supplier/importer.
• Acknowledgement for receipt of copy of application from concerned state Pollution control Board (SPCB) / pollution Control Committee (PCC)
7. Documents required for Import of used MFDs
• Importers have valid Authorization as per the e-waste (Management and Handling) Rules, 2008.
• MFDs should only be for print size of A3 and above
• Undertaking that the MFDs will be fully functional with a residual life of minimum five years to be substantiated by
• Chartered Engineer Certificate (CEC) from the exporting country indicating the manufacturing date, residual life and serial number.
• The importer will furnish previous import details and the use to which the previously imported machines have been put to.
• Proposed use / utilization details of MFDs to be imported.
• Proof of annual returns filed by the importers to their concerned SPCBs / PCCs for all previous import, if applicable.
Further, in addition to all the above the custom Authority will also verify the following prior to giving clearance to such import:
• MFDs shall be free of any transit damage and shall be functional and in usable condition
• The importer shall have valid authorization from DGFT for such import
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