Law Updates

Subject

Summary: A mobile CNG or CBG unit cannot simply be taken to an industrial site and used as a portable fuel station. That is one of the clearest practical points emerging from the Gas Cylinder (Third Amendment) Rules, 2026. The Central Government has amended the Gas Cylinder Rules, 2016 to create detailed conditions for CNG and CBG Mobile Refueling Units, commonly called MRUs. The amendment changes Rule 6(4) and inserts a new Condition 22 in Form G covering ownership, approvals, filling, dispensing, equipment safety, operating locations, emergency arrangements and record-keeping.  The notification is dated 21 September 2026. The Gazette was published on 23 September 2026, and the rules state that they take effect from the date of final publication in the Official Gazette.  For CGD companies, CBG operators, mines, ports, railway operations, waterway operators, and businesses using large equipment that cannot easily reach a conventional fuel station, the amendment deserves a close reading. Gas Cylinder Third Amendment Rules 2026 at a Glance Particular Details Name of Rules Gas Cylinder (Third Amendment) Rules, 2026 Notification Number G.S.R. 831(E) Issuing Ministry Ministry of Commerce and Industry Department Department for Promotion of Industry and Internal Trade Notification Date 21 September 2026 Gazette Publication Date 23 September 2026 Commencement Date of final publication in Official Gazette Governing Act Explosives Act, 1884 Rules Amended Gas Cylinder Rules, 2016 Rule Changed Rule 6(4) Form Changed Form G New Provision Condition 22 Main Subject CNG/CBG Mobile Refueling Units Earlier Draft G.S.R. 461(E), dated 10 June 2026 Main Business Areas Affected CGD, CBG, mines, ports, railways, waterways, heavy equipment and industrial operations Before finalising the amendment, the Government had published draft rules on 10 June 2026. Objections and suggestions were invited for 30 days, and the final Gazette records that the representations received were considered.  What Exactly Has Changed? The amendment has two main parts. Rule 6(4) Has Been Amended A proviso has been inserted in Rule 6(4) permitting CNG/CBG to be dispensed into motor vehicles or equipment covered by the new Condition 22 of Form G.  This provision needs to be read together with Condition 22. It should not be interpreted as general permission for unrestricted mobile fuel dispensing. Condition 22 Has Been Added to Form G A new Condition 22 titled “Additional conditions for CNG/CBG Mobile Refueling Units (MRUs)” has been inserted after Condition 21.  This new condition deals with almost the entire operating cycle of an MRU: who can own it,  what equipment it must contain,  where it can be filled,  where it can dispense,  which vehicles can receive fuel,  safe distances,  shutdown systems in emergencies,  cylinder requirements,  hoses and couplings,  supervision,  vehicle approvals,  planning for emergencies,  record keeping, and  limitations on public retail uses.  Condition 22 is thus much more than just a permit to do mobile refueling. What Is a CNG/CBG Mobile Refueling Unit? In simple terms, an MRU is a mobile gas storage and dispensing arrangement. The amendment describes it as a mobile assembly containing equipment such as: CNG/CBG Storage Cascade,  Fuel Dispensing Unit, Pipes, Hoses, Fittings, Valves, Pressure Regulators, Safety Devices, Emergency Shut-off System,  and Related Equipment.  The system can be installed on: a vehicle,  trailer,  skid, or  another mobile platform.  Its purpose is to dispense CNG or CBG into approved onboard fuel cylinders or fuel systems at a site specifically approved for such use.  That last condition matters. The word “mobile” describes the unit. It does not mean the dispensing location is unrestricted. Who Can Own a CNG Mobile Refueling Unit? The rules do not permit any company with a suitable vehicle to own and operate a CNG MRU. A City Gas Distribution company must own a CNG MRU authorised for the geographical area concerned.  The MRU must also comprise an assembly approved by the Chief Controller. That assembly includes more than the cylinders. The approval covers components and arrangements such as: storage cascade,  dispensing system,  piping,  hose,  pressure regulation equipment,  safety equipment,  ESD system,  design,  operation process, and  response plan.  To a CGD operator, the compliance issue is not just about whether it has adequate storage cylinders for refueling operations. The entire design of the refueling setup must meet the required framework. Who Can Own a CBG Mobile Refueling Unit? CBG follows a different ownership route. A licensee must own a CBG MRU under Forms E & F.  The CBG MRU must also have an approved assembly containing the prescribed storage, dispensing, pressure-control, and safety components. This difference between CNG and CBG ownership should be checked at the beginning of a project. A business should not first purchase or fabricate an MRU and only later determine whether its existing authorisation actually permits it to own and operate the unit. CNG MRU vs CBG MRU Compliance Point CNG MRU CBG MRU Who can own it? CGD company Form E & F licensee Geographical area condition CGD company must be authorised for concerned geographical area Not stated in the same manner for CBG ownership Assembly approval Required Required ESD requirements Applicable Applicable Cylinder standards Applicable Applicable Site safety conditions Applicable Applicable Records Applicable Applicable Emergency planning Applicable Applicable The biggest distinction lies in ownership. Most of the operational and safety requirements under Condition 22 apply to both. Which Vehicles and Equipment Can Be Refueled Through an MRU? This is where businesses need to be careful. The amendment does not say that any commercial vehicle, truck, machine or fleet vehicle can automatically be served through an MRU. CNG/CBG may be dispensed only into approved onboard cylinders fitted as fuel tanks to the vehicles or equipment covered by the provision. Valid filling permission and other applicable statutory approvals must also be available.  The main categories are set out below. Vehicle or Equipment Position Under the Amendment Non-transport vehicles operating in specified mines Covered Non-transport vehicles operating in notified ports Covered Indian Railways locomotives Covered Ships or boats operating on approved waterways Covered subject to relevant approvals Engines under test at authorised testing laboratories Covered Heavy machinery/equipment unable to reach a fuel station Can be considered in exceptional circumstances Non-Transport Vehicles Used in Mines The rule covers non-transport vehicles operating within areas of mines falling under the law referred to in the notification.  This may be particularly relevant for mining machinery that operates continuously within a mining site and is difficult to move outside the premises solely for refueling. The vehicle list is still subject to the required vetting process. The mine-related provision should therefore not be treated as an automatic blanket permission for every machine on a mining site. Non-Transport Vehicles Inside Notified Ports Non-transport vehicles working within ports notified by the Ministry of Ports, Shipping and Waterways are also covered by the new condition.  Businesses operating port equipment should separately verify: the vehicle category,  operating location,  applicable approval,  vehicle list, and  MRU site.  Indian Railways Locomotives Locomotives of Indian Railways are expressly included within the permitted categories.  The concerned railway administration also appears in the vehicle-vetting provision, which means railway-linked projects need coordination with the relevant railway authority. Ships and Boats on Inland or Seaborne Waterways The amendment also covers ships and boats operating on approved inland or seaborne waterways. Depending on the activity, approval may involve: Maritime Board,  Inland Waterways Authority of India,  concerned port authority, or  another competent maritime or inland-waterway authority.  The relevant authority will depend on where the vessel operates and which authority has jurisdiction. Engines Under Test Engines under test at laboratories authorised by the Central Government are also addressed under Condition 22.  This provision should not be stretched to include any private workshop or testing facility. The exact status of the laboratory needs to be checked. Can Heavy Machinery Be Refueled at Its Operating Site? Possibly, but not automatically. The Chief Controller may allow refueling of onboard CNG/CBG cylinders fitted to: heavy equipment,  machinery, or  other heavy vehicles  that cannot be brought to a fuel dispensing station.  The significance of the wording is that the consent is based on special circumstances. The authority may ask for: reasons for consent in written form, additional protection, inspection of the site,  risk assessment, and  other conditions considered necessary.  For a large construction, mining, or industrial project, this provision can be useful. Still, the correct approach is to seek and obtain the required permission rather than treating physical difficulty in moving the equipment as sufficient approval. Where Can a CNG/CBG MRU Be Filled? The place where the MRU itself is filled is controlled. An MRU can be filled or charged only within the designated area of: a CNG mother station, or  CNG/CBG filling premises licensed under Form E & F.  The MRU must be shown in the approved layout. It must also be linked with the relevant mother station or licensed premises, and the necessary amendment to the premises licence must be obtained.  This creates a direct regulatory link between the mobile unit and the licensed facility from which it is charged. Where Can the MRU Actually Dispense CNG or CBG? Filling the MRU and dispensing from the MRU are not the same regulatory activity. The amendment states that CNG/CBG MRUs are to dispense into approved onboard fuel cylinders at premises licensed in Form G, subject to the conditions in the rule.  For businesses, this means the compliance chain should be reviewed in three parts: where the MRU is filled,  how it is transported, and  where and to what equipment it dispenses.  Looking at only one stage can leave a major gap in the project. Filling an MRU vs Dispensing From an MRU Point Filling/Charging the MRU Dispensing From the MRU Main location CNG mother station or applicable Form E & F licensed filling premises Applicable Form G licensed premises Approved layout Relevant Relevant to licensed premises/site arrangement Licence connection MRU attached to applicable licensed premises Dispensing subject to Form G conditions Main purpose Charge the MRU storage cascade Deliver CNG/CBG into approved onboard cylinders Main risk Filling/storage and pressure management Site, public access, vehicle and dispensing safety Treating these two operations separately during compliance planning will make licence and site review much easier. What Approvals Should Businesses Check? Condition 22 refers to more than one approval or permission. The exact combination will depend on the proposed activity. MRU Assembly Approval The complete MRU assembly needs the approval referred to in the Rules. Businesses should make sure that the actual installed system matches the approved configuration. Changes in components, layout, or operating arrangement should not be assumed to remain covered without checking. Valid Filling Permission The amendment states that filling of applicable onboard cylinders must be carried out under valid filling permission.  Form E & F Position Form E & F is particularly relevant to: CBG MRU ownership, and  filling/charging premises referred to under the MRU provisions.  Form G Position Condition 22 itself has been inserted into Form G. Dispensing activity therefore needs to be examined against the applicable Form G licence conditions. Approved Layout The MRU arrangement must be properly reflected in the approved layout where required. Licence Amendment The Gazette specifically refers to the necessary amendment in the licence of the premises to which the MRU is attached.  This is an area where PESO compliance services or Gas Cylinder Rules compliance support can be useful, particularly when an existing licensed facility is adding an MRU rather than developing a completely new site. Safety Distance Requirements for CNG/CBG MRUs Site selection is one of the most practical compliance issues in the amendment. During dispensing, the minimum prescribed distance around the MRU must be maintained. Total Water Capacity of Gas Storage Cascade Minimum Distance From Buildings and Boundaries Up to 4,500 litres 4.0 metres More than 4,500 litres 5.0 metres These distances are expressly stated in the Gazette.  However, operators should not treat 4 metres or 5 metres as an automatic clearance for every site. The Chief Controller may specify greater distances from: public roads,  ignition sources,  overhead electrical lines,  drains,  basements,  hazardous storage, or  other vulnerable locations.  A site that appears suitable on a basic drawing may therefore still require changes after a proper safety assessment. What If the MRU Capacity Is Above 10,000 Litres? The rules create another important threshold. A CNG/CBG MRU with total water capacity above 10,000 litres cannot be used unless the Chief Controller specifically permits it with additional safeguards.  For project planning, capacity should therefore be checked at the design stage rather than after the MRU has been procured. A higher-capacity unit may need a different regulatory approach from a smaller MRU. Emergency Shutdown System: What Does the Rule Require? Every MRU must have a fail-safe Emergency Shutdown system, usually referred to as ESD. The system needs to be capable of shutting down the operation quickly if something goes wrong. Under the amendment, it must: be manually operable,  be accessible from at least two locations,  isolate the storage cascade,  isolate the dispensing lines,  stop the CNG/CBG supply source,  stop dispensing immediately when activated, and  be tested periodically according to the manufacturer's procedure.  The rule therefore deals with both installation and continued functionality. Having an ESD switch on the equipment is not enough if it is inaccessible, untested, or not connected to the correct parts of the system. Technical Standards for MRU Cascade Cylinders The amendment also specifies technical requirements for cylinders used in the storage cascade. Technical Area Requirement Design IS 7285, ISO 9809, ISO 11119 or another code acceptable to Chief Controller Maximum allowable working pressure Not above 250 bar gauge unless specifically approved otherwise Periodic testing Required Inspection Required Certification Required Valves Approved type Pressure Relief Devices Approved type Fittings Approved type These conditions are expressly set out in the amendment.  The wording allows different recognised cylinder design codes. Businesses should therefore check which standard applies to the actual cylinders being used instead of assuming all listed standards need to apply at the same time. Hose and Coupling Requirements Hoses and couplings receive separate attention because these are the parts through which gas is actually transferred from the MRU. The rules require them to be suitable for CNG/CBG service. They must also have: mechanical continuity,  electrical continuity,  minimum burst pressure of not less than four times maximum operating pressure,  periodic pressure or leak testing,  breakaway coupling,  excess-flow or quick shut-off arrangement, and  suitable bonding or earthing.  For maintenance teams, these are not one-time installation checks. Testing history, condition of hoses and replacement or repair records can form part of the site's broader compliance trail. How Should the Dispensing Area Be Controlled? The area around an operating MRU cannot remain open to unrestricted movement. Physical measures must be used to prevent unauthorised people from entering the dispensing area. The amendment gives examples such as: barricading,  chain-link fencing,  cones, or  other physical barriers.  Warning signs must also be clearly displayed in: English,  Hindi, and  the local language.  Activities unrelated to MRU operations are not allowed inside the dispensing area. For a busy mine, port or industrial location, this may require changes to vehicle movement and pedestrian access around the refueling point. What Is Prohibited Inside the Dispensing Area? The amendment specifically prohibits: smoking,  open flames,  mobile phone use,  hot work,  unauthorised electrical equipment, and  public access.  These restrictions should be reflected in: site signage,  operating instructions,  operator training,  contractor controls, and  day-to-day supervision.  Who Must Supervise CNG/CBG Refueling? Refueling cannot be left to an untrained operator. At least one authorised and trained responsible person from the CGD entity or the Form E & F licensee, as applicable, must be present and directly supervise the operation.  The responsible person should understand: CNG/CBG hazards,  relevant provisions of the Gas Cylinder Rules, and  the applicable Form G licence conditions.  Training records must also be maintained and produced when demanded. This distinction is useful: the rule is not satisfied merely because someone experienced happens to be present. The person's authorisation, training and records also matter. Who Supervises Filling of the MRU? The filling operation of the MRU itself must be carried out under the direct supervision of a responsible person of the CGD company or Form E & F licensee who has been properly trained in the safe handling and dispensing of CNG/CBG.  Operators should therefore maintain clear responsibility for both stages: Stage 1: Filling the MRU Responsible, trained supervision is required while the MRU is being charged. Stage 2: Refueling Vehicles or Equipment Responsible, trained supervision is also required during dispensing at the operating site. Vehicle and Equipment Approval Before Refueling A proposed vehicle cannot simply be added to the MRU operation because it has a compatible CNG or CBG cylinder. The vehicle list must be vetted by the competent authority. Depending on the activity, this may include: Directorate General of Mines Safety,  Conservator of Ports,  concerned railway administration,  Inland Waterways Authority of India, or  another competent authority having jurisdiction.  The approved list must be maintained at the site. More importantly, it has to be updated before a new vehicle or equipment unit is refueled. That makes vehicle-list control a live operational requirement, not a one-time approval exercise. Authority-Wise Compliance Responsibility Authority/Entity Main Role Under the Amendment Central Government Issued final amendment Chief Controller MRU assembly approval, special permissions and additional safeguards CGD company CNG MRU ownership and operational responsibility Form E & F licensee CBG MRU ownership and relevant operations DGMS Applicable vehicle vetting in mine-related cases Conservator of Ports Applicable port-related vetting Railway Administration Relevant railway vehicle/equipment vetting Inland Waterways Authority of India Relevant inland-waterway approval/vetting Maritime/Port Authority Applicable vessel or port oversight District Magistrate Receives emergency plan where specified Local Fire Service Emergency-plan coordination Police Authority Emergency-plan coordination Not every authority in this table will apply to every MRU project. The operating sector and location will determine which authorities are relevant. What Happens When One MRU Is Replaced With Another? Fueling must stop during an MRU exchange. The rules require: complete suspension of fueling,  closure of all valves,  depressurisation of the dispensing system where required,  activation of the ESD, and  removal of unauthorised persons from the safety zone.  This should be treated as a separate operating procedure rather than handled informally by the site team. Leak Checks Before Dispensing Before fuel starts flowing, the equipment must first be checked. The amendment requires visual checking of: hoses,  couplings,  valves,  dispenser, and  receiving fuel system.  Dispensing must not start unless these are found to be leak-free.  A simple operational checklist can help ensure that this inspection is not skipped during busy shifts. Emergency Access Must Remain Open The MRU dispensing area should be located and maintained in a manner that allows emergency vehicles to enter and operate without obstruction. The amendment specifically refers to: fire tenders,  ambulances, and  emergency-response vehicles.  This means site drawings should consider emergency movement, not only MRU parking space and dispensing clearance. Every MRU Site Needs Its Own Emergency Plan The amendment calls for a site-specific emergency plan for each site. That plan has to be: prepared for emergency implementation,  submitted to the specified authorities,  displayed at the operating site,  communicated to operators, and  tested through periodic mock drills.  Copies may have to be submitted, as specified, to: District Magistrate,  local fire service,  police authority, and  jurisdictional Controller or Chief Controller.  A generic corporate emergency manual may therefore not be enough by itself. The plan needs to reflect the actual MRU site. Where Can a CNG/CBG MRU Not Be Used? This is one of the most important restrictions in the amendment. An MRU cannot be used for public retail dispensing on: public roads,  residential areas,  commercial parking areas,  basements,  enclosed premises, or  any place that has not been specifically approved.  Does This Mean a Mobile CNG Pump Can Operate Anywhere? No. The amendment does not create an unrestricted “fuel anywhere” model. The MRU is mobile, but its use remains tied to: approved sites,  approved vehicles or equipment,  the relevant licensed premises,  specified safety distances,  competent-authority approvals, and  operating restrictions.  For businesses studying mobile CNG or CBG delivery as a new model, this distinction should be checked before any commercial commitment is made. What Records Must an MRU Operator Keep? The amendment contains a fairly detailed record-keeping requirement. The CGD entity or Form E & F licensee must maintain records relating to: Record Category What Should Be Captured MRU filling Filling activity Dispensing Fuel-dispensing activity Pressure Pressure readings Vehicles/equipment Details of units refueled Operators Details of operating personnel Leakage Leak checks ESD ESD checks Hoses Hose testing Maintenance Maintenance activity Defects Identified defects Repairs Repairs undertaken Incidents Operational incidents These records must be produced before the inspecting authority when demanded.  For an operator, this means compliance is not limited to obtaining the initial approval. Records need to show what happened after the MRU became operational. What Rules Apply While the MRU Is Being Transported? The MRU remains regulated while it is moving from one location to another. During movement, the unit has to comply with: applicable transport provisions for cylinders under the Gas Cylinder Rules, and  other applicable law in force.  Transport compliance should therefore be checked separately from site dispensing requirements. Complete CNG/CBG MRU Compliance Checklist Before starting operations, a business can use the following as an internal review list. Compliance Check What Needs to Be Verified MRU type CNG or CBG Ownership eligibility Correct CGD/Form E & F route Geographical authorisation Verified for applicable CNG MRU Assembly approval Matches actual MRU configuration Filling permission Valid Approved layout MRU properly reflected Licence amendment Obtained where required Filling location Correct licensed premises Dispensing location Approved Form G premises/site Vehicle category Covered under Condition 22 Vehicle vetting Completed by relevant authority Safety distance 4 m/5 m or higher where specified Capacity 10,000-litre threshold checked Cylinder standard Verified Working pressure Verified ESD Installed and tested Hoses/couplings Correct specification and testing Earthing/bonding Available Trained supervisor Appointed Training records Maintained Warning signs English, Hindi and local language Access restriction Physical barriers installed Leak check Completed before dispensing Emergency access Maintained Emergency plan Site-specific plan prepared Mock drill Conducted periodically Operational records Maintained Transport compliance Checked before movement This table should be used as an internal review tool, not as a substitute for the applicable licence conditions or approval issued for a particular site. What Does This Amendment Mean for CGD Companies? CGD companies are directly relevant because the rules connect CNG MRU ownership with a CGD company authorised for the geographical area concerned. A CGD company considering an MRU should review: whether the proposed MRU falls within its authorised area,  whether the assembly approval covers the proposed configuration,  where the MRU will be filled,  where dispensing will occur,  whether the vehicle category is permitted,  whether competent-authority vetting has been completed,  and whether operating records and emergency controls are in place.  The amendment makes MRU operation a structured compliance activity rather than simply an extension of normal CNG distribution. What Does It Mean for CBG Operators? CBG businesses should first look at the ownership condition. A Form E & F licensee must own the MRU under the framework set out in Condition 22.  From there, the operator needs to review: assembly approval,  filling premises,  dispensing site,  technical controls,  operator training,  vehicle eligibility,  emergency planning, and  record keeping.  This becomes particularly important where CBG is proposed for industrial or heavy-equipment use outside a conventional retail-fueling setting. What Does It Mean for Mining and Heavy-Equipment Businesses? For mines and other businesses using heavy equipment, the amendment may make MRU-based refueling more practical in situations where large machinery is difficult to move. But the new route is controlled. A mining company should not begin by asking only, “Can an MRU reach the machine?” The more useful questions are: Is the vehicle/equipment covered?  Who owns the MRU?  Is the operating site approved?  Has the vehicle list been vetted?  Are required distances available?  Has the emergency plan been prepared?  Is special permission required for the particular equipment?  For heavy equipment outside the specifically listed categories, the exceptional-permission route may become important. Business Benefits of the New MRU Rules The biggest value of the amendment is regulatory clarity. Businesses now have a more specific framework for deciding when and how mobile CNG/CBG dispensing may take place. Potential tangible advantages are as follows: a standardized way to provide refueling on mobile bases, more clarity in operations at mines and harbors,  the special regulations on rail transport and waterways transport,  a way for large machines that can't get to a regular station,  the safety distance regulation,  technological specifications, emergency plans, and  better accounting by documentation. Such advantages should not be taken as guaranteed money savings. The very amendment doesn't guarantee any money savings, any cheaper fuel price, or any faster approval process. Practical Challenges Businesses May Face The rules also add work at the planning and operating stages. Site Availability A proposed location may not have enough room to maintain the required safety distance and emergency access. Licence Changes Existing licensed premises may need amendment before the MRU can be properly linked to the site. Vehicle Vetting Adding a new machine or vehicle may require the approved list to be updated before it can be refueled. Technical Documentation Specifications for equipment, pressure limits, ESD systems, hose requirements, and cylinder requirements have to coincide with the actual installation. Training Persons responsible should be adequately trained, and records should be kept. Emergency Planning Each site requires its own emergency arrangement rather than relying only on a general corporate plan. Daily Records The operating team has to maintain enough information to demonstrate checks, testing, repairs, and incidents when inspected. Compliance Risks Businesses Should Avoid Some issues deserve attention before an MRU starts operating. Treating the MRU as an Unrestricted Mobile Fuel Station The Gazette does not support that interpretation. Starting at an Unapproved Site A mobile unit still requires an approved operating location. Refueling a Vehicle Not on the Approved List The vehicle list should be updated before the new vehicle or equipment is refueled. Mixing Up Filling and Dispensing Permissions The location used to fill the MRU and the location where it dispenses are governed differently. Ignoring the 10,000-Litre Threshold A higher-capacity MRU requires the specific permission referred to in the rules. Keeping Incomplete Training Records The competence of the responsible person needs to be backed by records. Skipping Pre-Dispensing Leak Checks The rule requires the relevant equipment to be checked and found leak-free before dispensing starts. Weak Emergency Planning An emergency plan should match the actual site and be communicated to operators. What Should Businesses Do Before Starting an MRU Project? A practical project review can follow this sequence. Step 1: Define the Activity Clearly Record: whether the gas is CNG or CBG,  where the MRU will be filled,  where it will operate,  what it will refuel,  and who will own it.  Without these basics, it is difficult to identify the correct regulatory route. Step 2: Check Ownership Eligibility For CNG, review CGD authorisation for the geographical area. For CBG, review the Form E & F licence position. Step 3: Review Existing Licences Check: relevant filling permission,  Form E & F position,  Form G licence,  approved layout,  and amendments required for attaching the MRU.  Step 4: Review MRU Technical Details Verify: storage cascade,  cylinder standard,  working pressure,  ESD,  valves,  PRDs,  hoses,  couplings,  breakaway arrangements,  bonding, and  earthing.  Step 5: Review the Operating Site Check: safety distances,  boundary conditions,  access controls,  warning signs,  emergency access,  surrounding hazards.  Step 6: Check Vehicle Eligibility Determine the type of equipment/vehicle and the body that is going to review it. Step 7: Develop the Operation’s Procedure This includes procedure for: filling, dispensing,  leak test, MRU changeover,  access control,  emergency stop,  and incident response.  Step 8: Develop the Emergency Plan Develop a site-specific emergency plan and not use a generic one. Step 9: Set Up Records Before Operations Begin Develop data fields for: filling, dispensing, pressure, vehicle, operator, ESD, leak, hose, maintenance, repair,  and incident reporting.  This order constitutes a sensible method of compliance rather than an ordered prescription by the government. How Corpseed Can Help With CNG/CBG MRU Compliance An MRU project can involve several linked compliance questions. The business may already have a gas-related licence but still need to determine whether the proposed mobile unit, site, equipment and operating model fit within the amended Gas Cylinder Rules. Corpseed can support businesses looking for PESO compliance services and Gas Cylinder Rules compliance assistance in areas such as: 1. Applicability Review Corpseed can review the proposed activity to understand: whether the project falls within Condition 22,  whether CNG or CBG provisions apply,  and which stakeholder category is relevant.  2. Existing Licence Review Existing licences and permissions can be checked against the proposed MRU arrangement to identify possible gaps before operations begin. 3. MRU Compliance Gap Assessment The proposed setup can be reviewed against areas such as: ownership,  approved layout,  site conditions,  MRU capacity,  technical specifications,  emergency controls,  records, and  vehicle eligibility.  4. Regulatory Documentation Support Corpseed can assist in organising the information and supporting documents needed for applicable regulatory submissions or licence amendments. 5. Technical Compliance Coordination Where the project requires technical drawings, equipment details, safety documentation or supporting records, Corpseed can help coordinate the compliance documentation required for the relevant approval process. 6. Site Compliance Review A proposed operating site can be reviewed for regulatory points including: safety distance,  access control,  emergency access,  signage,  and operational restrictions.  7. Compliance Record Framework Operators can be supported in setting up practical formats for: filling records,  vehicle records,  leak checks,  ESD checks,  maintenance,  testing,  and incident documentation.  8. Inspection Readiness Before inspection or operational commencement, the business can review whether licence documents, technical approvals and operating records are properly organised. Businesses planning an MRU for a mine, port, railway operation, waterway application or heavy-equipment site should avoid using a generic licensing checklist. The regulatory path should be mapped against the actual gas, owner, site and equipment involved. For businesses seeking PESO compliance services, Corpseed can assist with regulatory assessment, licence and approval review, documentation support and ongoing Gas Cylinder Rules compliance based on the actual MRU project. Key Takeaways The Rules on CNG CBG Mobile Refueling Units 2026 provide a cleaner working environment for mobile refueling activities, but they do not facilitate unfettered mobile fuel retailing. A few points deserve particular attention: The amendment changes Rule 6(4) and adds Condition 22 to Form G.  A CNG MRU must be owned by an authorised CGD company for the concerned geographical area.  A Form E & F licensee must own a CBG MRU.  The rules identify specific vehicles and equipment that may be refueled through MRUs.  Heavy machinery may be considered in exceptional circumstances, subject to additional safeguards and approval.  Minimum safety distance is 4 metres up to 4,500 litres and 5 metres above 4,500 litres, subject to higher distances where specified.  MRUs exceeding 10,000 litres need specific permission with additional safeguards.  ESD, cylinder standards, hose controls, training and vehicle vetting are part of the operating framework.  Every site needs proper emergency planning and operating records.  Public retail dispensing from an MRU is prohibited on public roads, in residential areas, in commercial parking areas, in basements, in enclosed premises, and in other unapproved locations.