Authorization for Import of Hazardous Waste

Hazardous waste poses serious risks to human health and the environment if not properly managed. These wastes are often non-biodegradable, toxic, persistent, and require stringent control during collection, treatment, recycling, transportation, and disposal. In India, the import of hazardous waste for purposes such as recycling, recovery, and reprocessing requires prior authorisation from the competent authorities.

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What is Hazardous Waste?

Hazardous waste can exist in solid, liquid, or gaseous form and is typically generated by manufacturing, chemical processing, and related activities. Such waste may exhibit properties like toxicity, reactivity, ignitability, corrosiveness, radioactivity or infectiousness. These properties make hazardous waste unsuitable for regular disposal and demand proper handling through authorised channels and specialised technologies for treatment, recovery and safe disposal.

Legal Framework — Hazardous Waste Management Rules

The Hazardous Waste Management Rules (originally notified in 1989 and amended in 2000, 2003, and comprehensively revamped in 2016 as the 'Hazardous and Other Wastes – Management & Transboundary Movement Rules') govern every aspect of hazardous waste management in India. The regulatory framework covers generation, collection, treatment, storage, transportation, packaging, disposal as well as import and export controls. The Ministry of Environment, Forest & Climate Change (MoEFCC) is the nodal agency, assisted by the Central Pollution Control Board (CPCB), State Pollution Control Boards / Pollution Control Committees (SPCBs/PCCs), the Directorate General of Foreign Trade (DGFT), Port Authorities and Customs for transboundary movement and enforcement.

Import Requirement & Prohibition

Individuals or companies intending to import hazardous waste for recovery, recycling or reprocessing must obtain prior authorisation from the MoEFCC (or the competent authority designated by MoEFCC) and follow the prescribed procedure. Import for direct disposal in India is strictly prohibited. Authorisation is conditional on prior informed consent (PIC) and compliance with applicable environmental, customs and transboundary movement rules.

Why Prior Authorisation Matters

Prior authorisation ensures that imports are scrutinised for environmental soundness, technical capability of the importing facility, and legal compliance. It prevents indiscriminate dumping, ensures hazardous fractions are handled by capable recyclers/re-processors, protects local ecosystems and public health, and aligns imports with circular economy goals by enabling responsible recovery of valuable materials under controlled conditions.

1. Typical Documents Required for Import Authorisation

Application form and cover letter specifying nature and quantity of wastes to be imported, end-use/recovery route and consignee details.

Details of the importer: Certificate of Incorporation, GST registration, PAN, address proof, contact details.

Site details: Plant/site layout, process flow chart, list and specifications of installed machinery/equipment, pollution control measures and capacity to handle the specified wastes safely.

Consent/clearances: Any required 'consent to establish' or 'consent to operate' where applicable, local SPCB permissions and prior clearances.

Prior Informed Consent (PIC) or equivalent export permission from the exporting country's competent authority (required for transboundary movement in many cases).

Safety & compliance documents: Emergency response plans, safety procedures, hazardous materials handling SOPs, worker training and PPE arrangements.

Customs/port-related documents as required and any other state-specific documents requested by SPCB/MoEFCC.

Import Authorisation Procedure — stepwise

1. Application to SPCB/State Authority: The applicant (recycler, processor or trader) prepares a detailed application with supporting documents, technical details of the recovery/recycling process, site capability and safety measures, and submits it to the concerned State Pollution Control Board (SPCB) or Pollution Control Committee (PCC) as directed by MoEFCC guidelines.

2. SPCB Review & Recommendation: The SPCB/PCC examines the application for technical adequacy, environmental safeguards and local acceptability. The SPCB/PCC processes the application and, where appropriate, forwards its recommendation to the MoEFCC within 30 days with any safety stipulations, conditions or observations.

3. Prior Informed Consent (PIC): For wastes governed by international transboundary movement rules, the importer must secure a Prior Informed Consent (PIC) or equivalent export permission from the exporting country's competent authority. The MoEFCC will generally require verification of PIC before granting import authorisation.

4. MoEFCC NOC / Authorisation: The MoEFCC considers the SPCB recommendation and the PIC (where applicable). If satisfied, MoEFCC issues the No Objection Certificate (NOC) or import authorisation specifying permitted waste categories, quantities, conditions (transport, storage, treatment, reporting), validity period and monitoring obligations.

5. Customs & Port Formalities: On grant of authorisation, the importer must comply with Customs import procedures, present the MoEFCC authorisation/NOC and PIC documents at port of entry, and ensure authorised routing to the nominated facility.

6. Ongoing Compliance: The authorised importer/operator must maintain records, submit periodic returns, permit inspections, comply with monitoring and reporting conditions, and ensure environmentally sound management until final recovery or dispatch (if re-export is required).

Validity, Timelines & Renewals

Timelines set by authorities aim to ensure due diligence while providing clarity to applicants. SPCBs normally forward recommendations within defined windows and MoEFCC decisions depend on PIC verification and internal processing.

  1. SPCB processing & recommendation

    Up to 30 days (from receipt of a complete application)

    SPCB reviews technical documents, conducts inspections if necessary, and forwards recommendations and safety stipulations to MoEFCC within the prescribed period.

  2. MoEFCC decision & NOC issuance

    Variable — depends on PIC verification and inter-agency checks

    MoEFCC issues import authorisation / NOC once satisfied that PIC is in place (where required) and that the applicant meets all technical and environmental safeguards.

  3. Import authorisation validity

    5 years

    Import authorisations are typically valid for five years unless otherwise specified in the authorisation conditions.

  4. Renewal

    Apply prior to expiry (timing per MoEFCC/SPCB guidance)

    Renewal requires submission of a fresh application and compliance records before expiry; authorities will assess past compliance and may inspect before renewal is granted.

Total Estimated Time

Processing times vary: SPCB recommendation within ~30 days where application is complete; MoEFCC decision timing is variable and contingent on PIC and other checks; overall end-to-end time depends on completeness, inspections and inter-agency coordination.

Listicles

Categories Permitted (examples, subject to PIC & conditions)

  • Metal and metal-bearing wastes (e.g., cadmium, lead, antimony, tellurium compounds) for recovery/recycling.
  • Galvanic sludge and leaching residues from metal processing where recovery of metals is intended.
  • Used lead-acid batteries (whole or crushed) specifically for authorised recycling processes.
  • E-waste for repair, refurbishment, research or component recovery — often permitted with re-export conditions where applicable.
  • Clean, uncontaminated metal scrap (iron, steel, aluminium, copper and similar) intended for recycling in compliant facilities.
  • Waste electrical and electronic assemblies imported for repair, testing or research subject to conditions.
  • Paper, paperboard and used multifunction printers/copiers and precious metal-bearing residues where recovery routes exist.

Prohibited Imports (selected examples)

  • Waste edible fats and oils — banned for import.
  • Household waste — prohibited from import.
  • Critical care medical equipment (for disposal) — prohibited.
  • Solid plastic waste — banned from import under specified notifications and policy changes.
  • Waste electrical and electronic assemblies intended for direct disposal rather than authorised recovery.
  • Certain chemical wastes explicitly listed as banned by MoEFCC/DGFT notifications.

Compliance Obligations & Recordkeeping

  • E-waste importers may need Extended Producer Responsibility (EPR) authorisation under E-waste Management Rules where applicable.
  • Maintain detailed records of all imports in Form 3 or equivalent formats as required by the SPCB and produce these records during inspections.
  • File annual returns (e.g., Form 4) with the State Pollution Control Board as prescribed and retain proof of safe handling and final disposition.
  • Adhere to customs, DGFT and port authority requirements for transboundary movement and demonstrate PIC where necessary.

How DoStartUp Supports Import Authorisation

Our compliance team helps prepare robust import authorisation applications with technically detailed process descriptions, site capability evidence and safety documentation.

We coordinate PIC verification with exporting-country authorities, compile SPCB submissions, follow up with MoEFCC and assist with customs/port documentation and post-import compliance reporting.

Application drafting and technical dossier preparation

Assistance securing and verifying PIC documentation

Regulatory liaison with SPCBs, MoEFCC, DGFT and Customs

Guidance on EPR, recordkeeping, Form 3/Form 4 filings and inspection preparedness

Book a consultation with DoStartUp to streamline your hazardous waste import authorisation and ensure full regulatory compliance.

Who Can Apply & Eligibility

Both actual users (recyclers, re-processors, authorised recovery facilities) and traders/importers can apply for import authorisation, provided they meet regulatory requirements, demonstrate technical capability and have the necessary consents and infrastructure for environmentally sound management of the imported wastes.

Eligibility is conditional on demonstrating appropriate processing/recovery capability, compliance history, safety and emergency response systems, and the ability to comply with monitoring and recordkeeping obligations specified by SPCB/MoEFCC.

Recyclers and authorised recovery facilities with technical capacity and compliant infrastructure.

Traders who can demonstrate authorised downstream recovery or re-export arrangements and who secure PIC where required.

Applicants must obtain or show 'consent to establish'/'consent to operate' and any local SPCB permissions where applicable.

Authorities will evaluate the applicant's technical and institutional capacity during application processing to ensure environmentally sound management of imported hazardous wastes.

Frequently Asked Questions