Authorisation for Import of Hazardous Waste

Importing hazardous waste into India is one of the most heavily regulated cross-border activities you can undertake. Used oil for re-refining, lead-acid battery scrap, certain non-ferrous metal residues, used catalysts, and specific e-waste streams can be brought in — but only if you are a registered recycler with the right authorisation. The gatekeepers are MoEF&CC, CPCB, your State Pollution Control Board, and Customs. The route runs through the PARIVESH 2.0 portal, Form 6 of the Hazardous & Other Wastes Rules, and where the Basel Convention applies, prior informed consent from the country of export.

Skip the authorisation and your consignment sits at the port. The shipping line bills you demurrage, Customs issues a hold notice, and the only realistic outcome is re-export at your cost. This page walks you through the FY 2026-27 process — what is eligible, what has changed, and how to get the file approved first time.

At a Glance

• Who needs it: Indian importers of hazardous waste falling under Schedule III, IV, or V of the Hazardous & Other Wastes Rules 2016 (as amended).
• Governing law: Hazardous & Other Wastes (Management & Transboundary Movement) Rules 2016, amended through 2022 and 2024; Customs Act 1962 for port-side enforcement.
• Regulators: MoEF&CC issues the final authorisation; CPCB gives the technical recommendation; SPCB recycler authorisation is a pre-condition.
• Portal: PARIVESH 2.0 single-window — Form 6 application, Form 7 approval, query management, and renewal all flow through it.
• International law: Basel Convention on Transboundary Movements applies to Annex VIII categories — Prior Informed Consent procedure with the country of export.
• Authorisation validity: Typically 1 to 2 years; renewable subject to capacity utilisation, compliance discipline, and downstream channel adequacy.
• Turnaround: 4 to 8 months for fresh authorisation; first import in 2 to 4 weeks after Form 7 is issued.
• E-waste imports: Permitted only for fully segregated, traceable streams; mixed or unsorted e-waste is barred under the E-Waste Rules 2022.

What's New for FY 2026-27

The regulatory framework has tightened materially since 2023. Here is what shifts the goalposts for you this year.

• PARIVESH 2.0 end-to-end: All transboundary movement applications now run digitally on PARIVESH 2.0. Physical file movement between CPCB and MoEF has been retired; status is tracked through your dashboard.
• EPR portal cross-verification: Your CPCB EPR registration (for plastic, e-waste, battery, used oil categories) is now cross-checked against your Form 6. A mismatch on category or capacity triggers automatic rejection.
• Stricter capacity utilisation rule: Imports cannot exceed your authorised recycling capacity minus your domestic feedstock intake. CPCB demands a quarterly mass balance reconciliation under the revised compliance protocol.
• Basel PIC digitised: For Annex VIII categories, the competent authority of the exporting country must e-file consent through the Basel Online Reporting System. Paper consents from non-Basel parties are no longer accepted.
• E-waste regime tightening: After the E-Waste Rules 2022 came into force, imports of mixed or unsorted e-waste are barred. Only fully segregated streams with downstream channel proof get approved.
• TSDF tie-up upfront: You must produce a signed agreement with an authorised Treatment, Storage & Disposal Facility for residue management — before, not after, you file Form 6.

Why Pre-Authorisation Discipline Matters

Many importers underestimate how unforgiving this regime becomes once goods are afloat.

• Customs will not release without it: ICEGATE flags Schedule III, IV, V HSN codes against the CPCB-MoEF approval database. No approval, no clearance — and no exceptions for first-time importers.
• Re-export is the only Plan B: Once the consignment lands without authorisation, you cannot domestically dispose or sell it. The Customs Act mandates re-export at the importer's cost, including return ocean freight.
• Demurrage adds up fast: Port demurrage runs ₹15,000-₹30,000 per container per day after the free period. A 30-day delay on a 5-container shipment routinely costs ₹25-45 lakh.
• NGT and SPCB action follows: Unauthorised import is a standalone violation under the HW Rules. NGT applications, SPCB show-cause notices, and possible cancellation of your existing recycler authorisation are all on the table.
• Trade finance fallout: Marine insurance claims, supplier letters of credit, and bank trade lines all get triggered by a stuck consignment. Your banking relationship gets flagged.
• Reputational damage with the SPCB: A single unauthorised import event will surface at every future renewal and inspection. The State Board's institutional memory is long.

How It Actually Works

The end-to-end sequence runs through seven defined stages, each with its own dependencies.

Step 1: Eligibility and Category Mapping

You must already be a CPCB or SPCB-authorised recycler for the specific waste category. Your existing authorisation defines what you can import. The waste must fall under Schedule III (recyclable), Schedule IV (utilisation-permitted), or specific Schedule V categories. We map your intended import to the right Schedule, confirm HSN classification, and flag any category mismatch before any further work is done.

Step 2: Capacity, Mass Balance and Downstream Channel Lock-In

We document your installed recycling capacity in tonnes per year, current utilisation from domestic feedstock, and the headroom available for imported volumes. The TSDF agreement for residue disposal must be signed and dated before filing. Without these three pieces in place, CPCB will not issue a recommendation.

Step 3: Country of Export and Basel PIC

For categories listed under Annex VIII of the Basel Convention, the competent authority of the exporting country must file Prior Informed Consent. We coordinate with your foreign supplier's regulatory consultant so both ends of the PIC procedure run in parallel rather than in sequence.

Step 4: Form 6 Filing on PARIVESH 2.0

The Form 6 application captures importer details, supplier details, waste category, quantity, transport route, port of entry, downstream channel, and residue management plan. We file digitally with all annexures including the TSDF agreement, CPCB EPR certificate, capacity proof, and marine insurance details.

Step 5: CPCB Technical Review (60-120 days)

CPCB raises queries through PARIVESH. Common queries cover capacity reconciliation, downstream channel adequacy, and supplier credentials. Each query has a 15-day response window. We track and respond inside that window — missing it sends the file to the back of the queue.

Step 6: MoEF&CC Final Approval (30-90 days)

After CPCB recommendation, MoEF&CC issues the formal Form 7 authorisation, typically with conditions on annual quantity, port of entry, and reporting frequency. Validity is generally 1 to 2 years and is tied to your existing recycler authorisation cycle.

Step 7: Customs Coordination and First Import

The approval is registered on ICEGATE against your IEC. Your customs broker files the Bill of Entry referencing the Form 7 authorisation number. We pre-brief the port-side CPCB officer on the first consignment so inspection delays are minimised.

A Real Example: Used Lead-Acid Battery Importer

Take a registered lead recycler in Tamil Nadu importing used lead-acid battery scrap from the United States.

• Installed capacity: 30,000 tonnes per year of lead recovery, verified by SPCB site inspection records.
• Domestic feedstock: 18,000 tonnes per year from local battery collection partners across South India.
• Available headroom: 12,000 tonnes per year capacity available for imported scrap before hitting the authorised ceiling.
• Intended import: 10,000 tonnes per year from a US-based exporter holding an EPA recycler authorisation.
• TSDF tie-up: Signed agreement with a Gujarat-based TSDF for slag and gypsum residue at ₹2,800 per tonne, with quarterly volume commitments.
• Basel PIC: US EPA filed export consent through the Basel Online Reporting System; MoEF&CC matched it against the Form 6 application within 21 days.
• Application timeline: Form 6 filed in May; CPCB queries returned in July; CPCB recommendation in October; MoEF approval in December.
• Total elapsed time: 7 months from filing to Form 7, with first container clearance 18 days post-approval at Chennai port.

The numbers stayed clean because every prerequisite — capacity, downstream channel, Basel consent, port readiness — was locked before Form 6 went in. Skipping any one of them adds 2 to 4 months to the cycle.

After Authorisation: Ongoing Compliance

Form 7 is the start of a continuing obligation, not the finish line.

• Quarterly returns to CPCB: Quantity imported, recycled, residue generated, and residue disposed — filed on PARIVESH 2.0 within 30 days of each quarter end.
• Annual return to SPCB: Form 4 of the HW Rules covering domestic and imported feedstock together with a complete mass balance statement.
• Manifest system: Each consignment from port to plant moves on a Form 10 manifest signed by the transporter, importer, and TSDF where residue routes through. Records preserved for 5 years.
• Capacity utilisation review: If actual utilisation falls below 60% of authorised import volume for two consecutive quarters, MoEF can revise the limit downward at renewal.
• Mass balance audit: CPCB runs a desk audit annually. Imported tonnage must reconcile to recycled output plus residue disposal plus inventory on hand, with tolerance under 3%.
• Downstream channel verification: TSDF receipts are uploaded monthly. Any mismatch between manifest and TSDF intake triggers a query within 15 days.
• Financial assurance: A bank guarantee or insurance cover equal to the cost of re-export of one full consignment is held on file and renewed annually.

Treat post-authorisation compliance as the second half of the project. Renewal hinges on the paper trail you build in the first 12 months.

Where It Goes Wrong

These are the issues we see derail importers most often.

• Over-claiming capacity: Importers cite nameplate capacity that includes lines under maintenance or commissioning. CPCB cross-checks against SPCB site inspection records.
• Missing TSDF agreement: An MoU or term sheet is rejected. CPCB requires a signed commercial agreement with quantities, tariffs, and a defined term.
• Generic supplier credentials: A trading company invoice without details of the original waste generator gets queried. CPCB wants the full chain of custody documented.
• Wrong port of entry: Form 6 specifies the port. Diverting a consignment to another port without amendment triggers an immediate Customs hold.
• Mixed-category shipments: Combining used oil with battery scrap in one Bill of Entry breaks the authorisation. Each category needs its own consignment and its own clearance.
• Quantity overshoot: A Bill of Entry value or quantity exceeding the Form 7 approval limit voids the clearance for that consignment, even if the annual aggregate is within bounds.
• Late renewal: Filing renewal in the last 30 days before expiry is high risk. A six-month lead time is the working norm and the CPCB expectation.
• Untracked EPR overlap: If you are a registered Producer under EPR, your imported feedstock counts toward your EPR compliance balance. Failing to reconcile this trips an annual return audit.

What You Receive at the End

• Form 7 import authorisation issued by MoEF&CC with conditions and validity period
• CPCB technical recommendation letter and query-response record
• PARIVESH 2.0 dashboard access with conditions tracker and expiry alerts
• Basel PIC consent record (where applicable) cross-linked with the export country authority
• ICEGATE registration of the approval against your IEC code
• Customs port-side briefing note for your Customs House Agent
• Quarterly compliance reporting template aligned with the CPCB format
• Renewal reminder schedule starting 6 months pre-expiry with a documentary checklist

How to Get Started

Send us your IEC, SPCB recycler authorisation, CPCB EPR registration, installed capacity proof, intended import quantity, foreign supplier details, and proposed downstream channel partner. Within 5 working days we issue an eligibility opinion that confirms whether the category is importable for your facility and what gaps exist on capacity, downstream channels, or Basel coverage.

Once eligibility is confirmed, we move to Form 6 drafting, TSDF tie-up support, Basel PIC coordination with the export country, PARIVESH 2.0 filing, and CPCB query management end-to-end. You hold one point of contact through the project, with a fortnightly status note covering query status, expected timelines, and any escalation we recommend.