Any occupier who generates, stores, transports, uses or disposes of hazardous waste listed in the Hazardous and Other Wastes Rules needs an authorisation from the State Pollution Control Board in Form 2, valid for five years. We prepare the Form 1 application, set up your storage area, manifests and Form 3 register, and file the Form 4 annual return every 30 June.
Legal basis: Rule 6 of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 (as amended) under the Environment (Protection) Act, 1986; Schedules I, II and III
Who needs it
- Manufacturing units generating spent solvents, used oil, ETP sludge, paint sludge, spent catalysts, acid or alkali residues or contaminated containers
- Pharma, chemical, dye, textile processing, metal finishing, galvanising and electroplating units
- Automotive service centres, fleets and workshops generating used oil, oil filters and lead-acid batteries
- Recyclers and pre-processors of used oil, spent solvents, lead, zinc, copper, e-waste and spent catalysts (Schedule IV processes)
- Common and captive hazardous waste storage, treatment and disposal facilities
- Importers and actual users of 'other wastes' such as metal scrap and used electrical assemblies
Common in:Manufacturing & Industrial UnitsRecyclers & Waste ProcessorsPharma & ChemicalsHospitals & Healthcare
Documents required
- 1Application in Form 1 with details of each hazardous waste stream — Schedule I / II category, quantity per annum and mode of storage and disposal
- 2Copy of Consent to Establish and Consent to Operate
- 3Process flow diagram showing points of hazardous waste generation and mass balance
- 4Layout plan showing the hazardous waste storage area with impervious flooring, roofing, bunding, leachate collection and labelling
- 5Agreements or membership certificates with an authorised TSDF, recycler or co-processor for each waste stream
- 6Details of authorised transporters and sample Form 10 manifest
- 7Emergency response plan and worker safety and training arrangements
- 8Constitution documents, PAN, GST and authorised signatory letter
- 9For recyclers: details of recycling process, Schedule IV category, CPCB SOP compliance and installed capacity
- 10Previous authorisation, Form 3 register extracts and Form 4 returns, for renewal
Missing something? We help you obtain or regularise supporting documents before filing.
How we get it done
- 1
Waste inventory and classification
Day 1–5We walk your process to identify every hazardous waste stream, assign the correct Schedule I / II category and quantify annual generation.
- 2
Storage and disposal readiness
Day 6–15The storage area is reviewed against CPCB guidelines and TSDF / recycler tie-ups are put in place for each stream so the application is backed by a disposal route.
- 3
Form 1 filing
Day 16–18The application is filed on the state portal — combined with the CTO application where the state uses an integrated form — with the prescribed fee.
- 4
Inspection and queries
Day 19–90We support the SPCB verification visit and respond to observations; the Board is required to decide within 120 days of a complete application.
- 5
Grant and record system
Day 90–120On grant we set up your Form 3 register, Form 10 manifest workflow and labelling, and schedule the Form 4 annual return due 30 June.
If you don’t comply
Handling hazardous waste without authorisation is punishable under Section 15 of the Environment (Protection) Act, 1986 (now monetary penalties of ₹1 lakh up to ₹15 lakh with additional daily penalties, after the Jan Vishwas Act, 2023), and Rule 20 of the HOWM Rules makes the occupier liable to pay for damage caused to the environment. SPCBs routinely levy Environmental Compensation and issue closure directions for unauthorised storage or illegal disposal.
Why MYDA Group
Specialists, not generalists
Environmental compliance is our only practice, so your file is handled by people who do this every day.
Fixed fee, written scope
You know the professional fee and the statutory fees before we start. No surprise add-ons.
Inspection and audit-ready
We prepare your site and team for the board visit or certification audit and attend it with you.
Lifetime reminders
Every condition, return and renewal goes into your compliance calendar with alerts.
Frequently asked questions
How long can hazardous waste be stored on site?
Rule 8 allows storage of up to 90 days, extendable by the SPCB in specific cases such as small generators, seasonal disposal or where a TSDF is far away. The storage area must be impervious, covered, bunded and labelled in Form 8, and quantities must be logged in the Form 3 register.
What returns do we have to file?
An annual return in Form 4 is due to the SPCB by 30 June for the previous financial year, covering waste generated, stored, treated and disposed. Every consignment also travels with a Form 10 manifest, and your Form V Environmental Statement must reconcile with these figures.
Is the authorisation separate from our CTO?
Legally yes, but most SPCBs now accept a single integrated application and issue the authorisation alongside the CTO with matching validity. If your CTO was granted without a hazardous waste schedule, we file a stand-alone Form 1 application.
Can we send hazardous waste to any recycler?
Only to a recycler or co-processor that holds a valid SPCB authorisation for that specific waste category, or to an authorised TSDF. Sending waste to an unauthorised party makes you liable as the generator, so we verify the receiver's authorisation before every tie-up.
We generate very small quantities. Do we still need authorisation?
Yes — the Rules do not exempt small generators from authorisation, although SPCBs may grant simplified conditions and longer storage periods. Even a workshop producing a few hundred litres of used oil a year needs to be authorised and to route waste through registered channels.