Authorisation for Export of Hazardous Waste
Exporting hazardous waste from India requires prior authorisation to ensure environmental safety, compliance with international conventions (including the Basel Convention), and lawful transboundary movement. Exporters must obtain permissions from the Ministry of Environment, Forest & Climate Change (MoEFCC) or the relevant State Pollution Control Board (SPCB) and follow statutory procedures including Prior Informed Consent (PIC) where applicable.
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What is Hazardous Waste and Why Export Controls Matter?
Hazardous waste may be found in solid, liquid or contained-gas forms and typically arises from chemical production, manufacturing activities and other industrial processes. Such wastes may possess hazardous properties including toxicity, corrosiveness, ignitability, infectiousness, reactivity or radioactivity. Because of their persistent and harmful nature, the international movement of hazardous wastes is tightly regulated to avoid environmental harm, illegal dumping and to ensure that the importing state is able and willing to manage the material in an environmentally sound manner.
Who is an Exporter?
An exporter is any individual, company or occupier within Indian jurisdiction that intends to export hazardous or other listed wastes. Exporters can include recyclers or actual users who will process the waste abroad as well as traders who arrange exports on behalf of clients. Both recyclers and traders are eligible to apply for authorisation, but they carry full responsibility for compliance during movement and final disposal or recovery abroad.
Why Obtain Export Authorisation?
A valid export authorisation provides legal clarity, enables lawful cross-border trade in recyclable/metal scrap and other listed wastes, ensures that the export complies with the Basel Convention and national rules, and protects exporters from action for illicit shipment. Authorisation also requires transparency—movement documents, records and PIC/NOC correspondence are maintained—helping demonstrate environmental responsibility and strengthening business credibility in global supply chains.
1. Typical Documents Required for Export Authorisation
• Covering application to MoEFCC/SPCB with export details and applicant identification.
• Company incorporation certificate / proof of legal entity and PAN.
• GST registration (if applicable) and relevant trade licences.
• Detailed description of waste consignment (type, quantity, composition), sample analysis reports where applicable.
• Shipping & movement documentation (Form 6 – movement document) prepared as required by the Rules.
• Records for Form 3 (export register) and commitment to maintain movement records.
• Details of the foreign recipient including address, facilities and evidence of capability to handle the waste in an environmentally sound manner.
• Prior Informed Consent (PIC) correspondence/authenticated PIC letter from the importing country (where Schedule III/PIC conditions apply).
• Any 'consent to establish' / 'consent to operate' or other environmental consents if applicable to the consignor's operations.
• Packaging, labelling and manifest details; proposed shipping route and port of exit; insurance and carrier details.
• Any additional information requested by MoEFCC/SPCB for risk assessment and due diligence.
Procedure for Obtaining Export Authorisation
Application Submission: The exporter must apply to the MoEFCC or the concerned SPCB with full consignment details, recipient details, waste description, and supporting documents per the Rules. The application should be complete and accurate to facilitate timely assessment.
Prior Informed Consent (PIC): For wastes listed under Schedule III or Schedule VI where PIC obligations apply, the exporter must obtain Prior Informed Consent from the importing country before shipment. PIC involves formal communication and acceptance by the importing authority that it consents to receive the specified waste under stated conditions.
No Objection Certificate (NOC) / Authorisation: On receipt of an authenticated PIC letter (if PIC applies) and after satisfying due diligence, MoEFCC may issue a No Objection Certificate (NOC) or export authorisation. The NOC typically references the authenticated PIC and sets conditions for shipment, handling and recovery.
Movement Documents & Records: Each movement must be accompanied by the prescribed movement document (Form 6). Exporters must maintain export records using Form 3 or other registers as required and must produce these records for inspection when called upon by authorities.
Compliance & Reporting: Exporters must ensure that shipments strictly follow the conditions set out in the authorisation and PIC. Annual returns, movement records and other reporting obligations must be filed with the relevant authority. Authorities may inspect facilities, shipment packaging and documentation to verify compliance.
Grant & Validity: If satisfied, the Ministry/Board grants authorisation; the export authorisation is typically valid for 5 years from the date of issue, subject to any conditions specified in the authorisation.
Penalties & Illegal Export Consequences
Description: Illegal export of hazardous waste attracts strict legal consequences including seizure of consignments, prosecution, cancellation of licences/authorisations, monetary penalties and civil or criminal liability under Indian environmental laws and international obligations.
Typical Timeline & Validity for Export Authorisation
Processing times depend on application completeness, PIC procedures with the importing country and inter-agency clearances. Exporters should plan well ahead to allow for international PIC timelines and domestic scrutiny.
Application preparation and submission
Variable (days to weeks depending on document readiness)
Compile consignment specifications, recipient details, test reports and regulatory consents; submit application to MoEFCC/SPCB.
Prior Informed Consent (PIC) process (if applicable)
Weeks to months depending on importing country procedures
MoEFCC/SPCB transmits request and obtains authenticated PIC from the importing country; timeline varies with foreign authority response times.
Grant of NOC / Authorisation
Variable (weeks) after PIC and due diligence
On receipt of PIC and completion of domestic due diligence, MoEFCC may issue authorisation with conditions and validity.
Validity period
5 years
Export authorisation is typically valid for five years from date of issue unless shorter validity is specified in the authorisation.
Total Estimated Time
Highly variable — from a few weeks (if PIC not required and application is complete) to several months where PIC and international clearances are involved.
Listicles
Export-Eligible Hazardous Wastes (Representative Examples)
- Metal-bearing wastes: antimony, lead, cadmium, tellurium residues and similar metal-bearing scraps intended for recycling or recovery.
- Used lead-acid batteries (whole or processed) destined for authorised recyclers with capacity to treat battery waste.
- Electronic assemblies and components for recycling or recovery (selected e-waste assemblies).
- Clean metal scrap: iron, steel, aluminium, copper, nickel, zinc — where non-dispersible and prepared for recycling.
- Mixed non-ferrous scrap and galvanic sludge, zinc processing residues, calcium fluoride sludge and precious-metal residues.
- Glass waste in non-dispersible form and certain paper & paper-product wastes specified under the Rules.
Key International & National Controls
- Basel Convention obligations — Prior Informed Consent (PIC) for transboundary movements where required.
- Hazardous and Other Wastes (Management & Transboundary Movement) Rules — Indian legal framework for hazardous waste exports and imports.
- Customs and port/authorities oversight — verification of shipment documents and compliance at ports of exit.
What Makes an Export Illegal?
- Export without proper authorisation from MoEFCC or without SPCB concurrence where required.
- Authorisation obtained through misrepresentation or fraud.
- Shipment details that do not match movement documents (Form 6) or Form 3 records.
- Intentional dumping or export in contravention of Basel Convention obligations or national environmental law.
Need Help Securing Export Authorisation?
DoStartUp provides end-to-end support to exporters seeking authorisation for hazardous waste exports. Our services include application preparation, PIC coordination, documentation of recipient due-diligence, liaison with MoEFCC/SPCB, preparation of movement documents (Form 6) and assistance with customs and port formalities.
We help structure robust technical dossiers and present evidence that the recipient facility can manage the waste in an environmentally sound manner so your application is assessed efficiently.
Expert preparation of application dossiers and Form 6 movement documents
Assistance obtaining and authenticating PIC where required
Regulatory liaison with MoEFCC, SPCBs and customs authorities
Post-authorisation compliance support, recordkeeping systems and annual returns assistance
Book a free consultation with DoStartUp to plan your export, manage PIC timelines and ensure full regulatory compliance — response within 1 hour.
Who Must Comply and Who Can Apply?
Exporters of hazardous or other listed wastes (both actual users/recyclers and traders) must comply with the export authorisation regime and obtain permissions before shipment.
Exporters should ensure the foreign recipient has the technical capacity and authorisations to manage, recover or recycle the waste in an environmentally sound manner.
Actual users/recyclers exporting for legitimate recycling or recovery abroad.
Traders arranging exports on behalf of generators or clients.
Occupiers who generate waste and arrange export under contractual arrangements.
Exporters share responsibility for due diligence, safe packaging, accurate documentation and verification that importing states consent to the movement under PIC where applicable.