Law Updates

Subject

Summary: The Ministry of Environment, Forest and Climate Change has made a targeted change to the Coastal Regulation Zone framework. Through G.S.R. 832(E) dated 22 September 2026, the Central Government has amended Annexure-II of the Coastal Regulation Zone Notification, 2019. The amended entries now list Bitumen, Linear Alkyl Benzene, N-Paraffin, and Carbon Black Feedstock.  The real business relevance lies in the background to the amendment. The Government had received representations regarding permission for the receipt and storage of Linear Alkyl Benzene, N-Paraffin and Carbon Black Feedstock in CRZ areas, but not in CRZ-IA. The issue was examined by the concerned Expert Appraisal Committees and later by the National Coastal Zone Management Authority before the Annexure-II amendment was finalised.  For companies operating terminals, coastal storage facilities, port-linked infrastructure or chemical-handling projects, this change is useful, but it needs to be read carefully. The notification does not say that all petroleum activities are now freely allowed along the coast. It also does not turn Annexure-II inclusion into automatic project approval. The first question is therefore not simply, “Is the product in the list?” A business also needs to ask where the project is located, wHat activity is proposed, what the existing clearance permits and whether any other project-specific compliance remains applicable. Notification at a Glance Particular Verified Details Issuing Ministry Ministry of Environment, Forest and Climate Change Document Type Notification / further amendment Notification Number G.S.R. 832(E) Notification Date 22 September 2026 Gazette Gazette of India, Extraordinary Gazette Issue No. No. 762 Gazette Header Date 23 September 2026 Principal Notification G.S.R. 37(E), dated 18 January 2019 Framework Amended Coastal Regulation Zone Notification, 2019 Part Amended Annexure-II Products in Substituted Entries Bitumen, Linear Alkyl Benzene, N-Paraffin and Carbon Black Feedstock Main Activity Discussed Receipt and storage Express Exclusion CRZ-IA Draft Notification G.S.R. 410(E), dated 26 May 2026 Consultation Period 60 days for objections and suggestions Legal Basis Cited Environment (Protection) Act, 1986 and Environment (Protection) Rules, 1986 Separate Effective Date Not expressly specified in the text of this notification The notification is dated 22 September 2026, while the Gazette issue header carries 23 September 2026. These dates should be stated separately rather than being mixed with a commencement date, because G.S.R. 832(E) does not set out a separate effective date clause in its operative text. What Is the Coastal Regulation Zone Notification, 2019? The present amendment sits inside the Coastal Regulation Zone Notification, 2019, not outside it. The Gazette explains that the Central Government had issued G.S.R. 37(E), dated 18 January 2019, declaring specified coastal stretches as Coastal Regulation Zones and placing restrictions on the setting up and expansion of industries, operations and processes in those areas.  That background is important because G.S.R. 832(E) should not be read as a fresh and independent permission for coastal industry. It changes Annexure-II of an existing regulatory framework. In practical terms, a business planning storage or receipt of one of the listed products still needs to understand how its proposed project fits within the wider CRZ framework. Regulatory Framework Behind the 2026 Amendment A clear understanding of the legal basis helps explain where the 2026 amendment fits within the existing coastal regulation framework. The notification refers to the following provisions and documents: Environment (Protection) Act, 1986 The notification states that the Central Government has acted under powers conferred by: Section 3(1) of the Environment (Protection) Act, 1986, and  Clause (v) of Section 3(2) of the Act.  These provisions form part of the legal authority cited for making the amendment.  Environment (Protection) Rules, 1986 G.S.R. 832(E) also refers to Rule 5(3) of the Environment (Protection) Rules, 1986. The article should therefore treat the 2026 notification as part of the statutory environmental framework rather than an advisory note or voluntary industry document. Coastal Regulation Zone Notification, 2019 The 2026 notification expressly describes itself as a further amendment to the Coastal Regulation Zone Notification, 2019. That distinction matters. The original CRZ framework continues to provide the wider regulatory setting. G.S.R. 832(E) modifies a specific part of it. Annexure-II The actual amendment is made in Annexure-II. The Government has substituted serial number (xxiii) and its connected entry with four serial numbers covering Bitumen, Linear Alkyl Benzene, N-Paraffin and Carbon Black Feedstock. Why Was the CRZ Notification Amended? The Gazette gives a clear history behind the change. Various State Coastal Zone Management Authorities had made representations to the Central Government regarding permission for the receipt and storage of three products: Linear Alkyl Benzene,  N-Paraffin, and  Carbon Black Feedstock.  The representations related to CRZ areas other than CRZ-IA.  The Government did not immediately amend the list. The matter first went through technical and regulatory examination. It was considered by the Expert Appraisal Committee for Industry-II, then by the Expert Appraisal Committee for Coastal Regulation Zone Clearances, and later by the National Coastal Zone Management Authority.  Only after those stages did the Government publish a draft amendment for public comments and subsequently issue the final notification. That history is useful because it shows that the change is not simply a renaming exercise. It follows a specific regulatory review concerning whether these products should be included in the Annexure-II framework for receipt and storage. What Does the CRZ Notification Amendment 2026 Actually Permit? The easiest way to understand the amendment is to focus on three things: 1. The product must be one of the identified products: The substantive background concerns: Linear Alkyl Benzene, N-Paraffin, Carbon Black Feedstock. 2. The activity discussed is receipt and storage: The Gazette repeatedly refers to receipt and storage. That wording should not casually be replaced with manufacturing, processing, production, refining or every other industrial use. 3. CRZ-IA is excluded: The regulatory discussion expressly excludes CRZ-IA. This means businesses should not use the 2026 amendment as a blanket statement that any facility handling these products may operate anywhere within the coastal zone. The actual project still matters. Which Products Appear in the Amended Annexure-II? The substituted entries are short and specific. Serial No. Product Position Under G.S.R. 832(E) (xxiii) Bitumen Listed in substituted text (xxiv) Linear Alkyl Benzene Listed (xxv) N-Paraffin Listed (xxvi) Carbon Black Feedstock Listed These are the exact entries appearing in the operative portion of the notification.  One point needs care here. The Gazette does not present Bitumen in the same way as the other three products in its background discussion. The substantive representations and committee consideration described in the notification concern Linear Alkyl Benzene, N-Paraffin and Carbon Black Feedstock. For that reason, it would be misleading to write that all four products were newly introduced by the 2026 amendment without checking the earlier Annexure-II text separately. Linear Alkyl Benzene: Why the Exact Description Matters The Gazette uses the exact term Linear Alkyl Benzene. It does not provide a grade-wise or composition-wise definition in this three-page notification. That means businesses should be careful when matching their commercial material with the regulatory entry. A similar name on an invoice, material sheet or purchase order should not automatically be treated as enough to establish coverage. For project and compliance teams, the practical approach is to make sure the product description remains consistent across: technical documents,  project reports,  environmental submissions,  storage descriptions,  approval applications,  internal compliance records.  N-Paraffin: Do Not Treat the Entry as a Blanket Paraffin Category The Gazette specifically lists N-Paraffin. It does not say “all paraffin products”. That difference may appear small, but it matters from a regulatory drafting perspective. Where a facility handles a product with a different description, the business should confirm whether it genuinely matches the notified entry instead of extending the amendment by assumption. Carbon Black Feedstock: Feedstock and Finished Product Should Not Be Confused The entry used in the Gazette is Carbon Black Feedstock. The notification does not say that finished carbon black, every feedstock used by the carbon black industry, or every related petroleum stream falls under the same entry. For businesses, correct identification becomes especially important where commercial terminology differs from the wording used in the regulatory document. Why Product Identification Is a Compliance Issue The amendment is product-specific. That means a business cannot safely rely on the notification only because its material is chemically related to one of the named substances. A compliance review should answer: What is the exact commercial name of the product?  How is it described in technical documents?  What description appears in the existing project approval?  Does the wording match the notified Annexure-II entry?  Is the facility receiving and storing the named product or undertaking a wider industrial activity?  These are practical checks rather than a new statutory filing process created by G.S.R. 832(E). Which CRZ Areas Are Covered by the Amendment? The Gazette repeatedly states that receipt and storage of the products was considered within CRZ areas excluding CRZ-IA.  This is not a minor qualification. A project developer cannot simply confirm that a facility is within a Coastal Regulation Zone and stop the analysis there. The precise CRZ category matters. A project in an eligible category may present a different regulatory position from a project falling within CRZ-IA. Why CRZ-IA Needs Separate Attention G.S.R. 832(E) expressly keeps CRZ-IA outside the permission discussed in the notification. That should be clearly stated in any business-facing summary because overlooking this exclusion could lead to an overly broad interpretation. The notification itself does not give a fresh definition of CRZ-IA and does not explain all activities permitted or prohibited in that category. Therefore, where a project touches CRZ-IA, the wider CRZ Notification, 2019 should be examined separately. Receipt and Storage Are Not the Same as Manufacturing This is where a lot of compliance content can become misleading. The Gazette deals with receipt and storage of the specified products. It does not say that every activity connected with those products is permitted. Activity Position Based on G.S.R. 832(E) Receipt of the named products Expressly discussed Storage of the named products Expressly discussed Manufacturing Not expressly authorised by this amendment Processing Not expressly addressed Refining Not expressly addressed New industrial establishment Not automatically approved by this amendment Expansion of an existing plant Not automatically approved by this amendment Other handling activity Requires separate review where relevant A project involving storage alone may therefore raise a different question from a project involving manufacture or processing. Businesses should keep the two issues separate. What Has Changed in Annexure-II? The actual legal change is compact. Annexure-II now contains the following substituted entries: (xxiii) Bitumen,  (xxiv) Linear Alkyl Benzene,  (xxv) N-Paraffin,  (xxvi) Carbon Black Feedstock.  This is the part of G.S.R. 832(E) that has direct legal effect. The rest of the Gazette explains why the amendment was considered and how the Government reached the final position. Old Position vs. 2026 Position The attached Gazette does not reproduce the full pre-amendment wording of Annexure-II. For that reason, a detailed old-versus-new comparison should not be invented from memory. What can safely be stated from the source is: Regulatory Point Position Evident from the Notification Earlier framework CRZ Notification, 2019 Issue raised before Government Receipt and storage of LAB, N-Paraffin and Carbon Black Feedstock Geographic qualification CRZ areas excluding CRZ-IA Amendment method Substitution in Annexure-II Final substituted entries Substitution in Annexure-II This is more accurate than filling an “earlier position” column with text that the attached Gazette itself does not reproduce. How the Amendment Reached the Final Stage Step 1: Representations from State CZMAs The Central Government received representations from various State Coastal Zone Management Authorities regarding receipt and storage of the three specified products outside CRZ-IA.  Step 2: Industry-II Expert Appraisal Committee Review The matter was referred to the concerned sectoral Expert Appraisal Committee. The Industry-II EAC considered whether the products could be included in the approved Annexure-II list for storage in CRZ areas other than CRZ-IA.  Step 3: CRZ Expert Appraisal Committee Review The sectoral EAC for CRZ clearances also examined the proposal. It recommended that receipt and storage of the identified chemicals may be considered permissible in CRZ areas excluding CRZ-IA under the CRZ Notification, 2019.  Step 4: NCZMA Consideration The proposal then went before the National Coastal Zone Management Authority. Step 5: Draft Notification A draft amendment was issued as G.S.R. 410(E), dated 26 May 2026. Step 6: Public Consultation Objections and suggestions were invited for 60 days. Step 7: Final Notification After considering the responses received within the consultation period, the Central Government issued G.S.R. 832(E).  What Did the National Coastal Zone Management Authority Recommend? The proposal was placed before the National Coastal Zone Management Authority at its 48th meeting held on 26 September 2025. According to the Gazette, NCZMA considered the chemical characteristics of these products to be comparatively less hazardous than products already permitted. On that basis, it unanimously recommended allowing receipt and storage of: Linear Alkyl Benzene,  N-Paraffin, and  Carbon Black Feedstock  in CRZ areas excluding CRZ-IA through an amendment to Annexure-II.  The wording here needs care. The notification records a comparative assessment. It should not be rewritten to say that these chemicals are harmless, risk-free or free from environmental controls. Draft Notification and Public Consultation The final amendment was preceded by a draft notification. The Government published G.S.R. 410(E), dated 26 May 2026, inviting objections and suggestions from persons likely to be affected. The consultation period was 60 days from the date on which copies of the Gazette containing the draft notification were made available to the public.  The final notification also records that objections and suggestions received within that period were duly considered by the Central Government. This distinction is useful because the May 2026 notification was a draft stage, while G.S.R. 832(E) is the final amendment. CRZ Amendment 2026 Timeline Event Date What Happened Principal CRZ Notification 18 January 2019 G.S.R. 37(E) issued NCZMA 48th Meeting 26 September 2025 Proposal considered and recommended Draft Amendment 26 May 2026 G.S.R. 410(E) issued Public Consultation 60 days Objections and suggestions invited Final Amendment 60 days G.S.R. 832(E) issued Gazette Issue Header 23 September 2026 Gazette Extraordinary No. 762 The note at the end of the Gazette also records that the principal notification was last amended earlier through S.O. 5495(E), dated 24 November 2022.  Does G.S.R. 832(E) Give Automatic CRZ Clearance? No such automatic approval is stated in the notification. G.S.R. 832(E) changes Annexure-II. It does not contain wording saying that every individual project involving one of these products is deemed approved. This distinction is central for project developers. A project still needs to be looked at in its own factual setting. Relevant questions include: Where is the facility located?  What is the site's CRZ classification?  Is CRZ-IA involved?  What activity will take place?  Is the project limited to receipt and storage?  What does the existing approval permit?  Has the project configuration changed?  Do any other project-specific legal requirements apply?  This is why CRZ clearance services may still be relevant even where the product itself appears in the amended Annexure-II. Product Permissibility and Project Approval Are Two Different Questions Question What It Means Is the product listed in Annexure-II? Checks whether the named substance appears in the amended list Is receipt/storage covered by the notification background? Checks whether the proposed activity matches the issue considered Is the project outside CRZ-IA? Checks the express geographical limitation Is the project already approved? Depends on project-specific clearance and conditions Can an existing facility add the product immediately? Cannot be assumed from G.S.R. 832(E) alone Are other approvals relevant? Must be checked under the applicable project framework This table captures the core compliance point: a product entry answers one question. It does not answer every question about the project. What the Notification Does Not Say The short wording of G.S.R. 832(E) makes its limits equally important. The notification does not expressly say that: all CRZ categories are covered,  CRZ-IA is included,  all petroleum products are permitted,  all chemical storage is permitted,  manufacturing is covered by the amendment,  processing is covered,  every port project is approved,  every existing clearance is automatically amended,  CRZ clearance is abolished,  other environmental permissions no longer apply.  This does not mean all these activities are necessarily prohibited. It simply means G.S.R. 832(E) should not be cited as proof for conclusions it does not contain. Does the Amendment Cover Similar Petroleum Products? The Gazette names specific substances. Therefore, businesses should avoid using a broad assumption such as: “LAB is allowed, so a related petroleum stream must also be allowed.” That is not what the document says. Where a product has a different chemical, technical or commercial description, its regulatory position should be checked separately. This is particularly important for businesses that store several related feedstocks at the same coastal facility. Who Should Pay Attention to the Amendment? Coastal Storage Terminal Operators The amendment may be relevant where a terminal receives or stores one of the specified products. The main review should focus on product identity, CRZ classification and existing project conditions. Petroleum and Chemical Companies Companies dealing in LAB, N-Paraffin or Carbon Black Feedstock now have express Annexure-II wording to consider while assessing eligible coastal storage operations. Port-Linked Businesses Businesses operating port-linked tanks, terminals or handling facilities may need to check whether their proposed activity fits within the receipt-and-storage context described in the Gazette. Existing CRZ Clearance Holders An existing facility should read the wording of its own clearance before making any operational change. New Project Developers For new projects, the amendment may support early-stage regulatory planning, but it does not remove the need to assess the proposed site and activity. Environmental and Compliance Teams Internal teams should make sure the amendment is not interpreted more broadly than its actual text. Impact on Existing Coastal Storage Projects An existing project may already have approvals that describe: the location,  project activity,  product handled,  storage facilities,  operational restrictions,  environmental conditions.  G.S.R. 832(E) does not expressly say that those conditions automatically change because the Annexure-II list has changed. A company looking to introduce LAB, N-Paraffin or Carbon Black Feedstock at an existing terminal should therefore compare the new proposal with the approval already held. Where the activity falls outside the approved project description, the business may need a separate regulatory assessment before implementation. Impact on New Projects For a new project, the amendment can form part of the planning review at an early stage. However, product inclusion should not be the first and last check. The project developer should also look at: Location: Is the proposed site within the relevant CRZ area? CRZ Category: Does any part of the site fall within CRZ-IA? Product: Does the actual material match the notified description? Activity: Is the proposal limited to receipt and storage, or does it also include manufacturing or processing? Existing Regulatory Framework: What other parts of the CRZ Notification apply to the proposed project? This kind of review can prevent a business from reaching a commercial decision based on an incomplete reading of the notification. Can an Existing CRZ Approval Be Treated as Automatically Modified? The Gazette does not say so. That means businesses should avoid assuming that an existing approval now automatically permits the newly listed products. The existing clearance may contain very specific wording about: product type,  tank configuration,  project capacity,  permitted activity,  project layout,  conditions imposed by the authority.  If a proposed change falls outside that approval, the regulatory position should be checked separately. What Other Environmental Requirements May Need Review? G.S.R. 832(E) does not contain a complete checklist of every permission that may apply to a coastal storage facility. Accordingly, businesses should not convert a practical list into a statement that every approval below is mandatory in every case. Compliance Area What Businesses Should Review CRZ framework Site category and activity Existing CRZ approval Whether proposed product/activity is already covered Environmental approval Applicability based on the project Pollution-control permissions Applicability to the facility and operation Chemical safety requirements Nature and handling of the substance Port/terminal permissions Where the project is port-linked Project conditions Existing restrictions, monitoring and operational requirements The correct mix of approvals depends on the actual project. What Businesses Should Verify Before Using the 2026 Amendment A practical review can be carried out in the following order. Identify the Product Properly: Confirm the exact product name and make sure it matches the Annexure-II entry. Identify the CRZ Category: Check the site rather than relying on a broad description such as “coastal area”. Confirm Whether CRZ-IA Is Involved: The amendment expressly excludes CRZ-IA from the receipt-and-storage permission discussed. Define the Activity: Clearly separate storage and receipt from manufacture, processing or expansion. Read the Existing Approval: Existing facilities should check their current clearance conditions. Compare Project Documents: The product description should remain consistent across technical and regulatory records. Check Whether Any Additional Regulatory Action Is Needed: This should be decided from the actual project rather than assumed from the Annexure-II amendment. Compliance Review Checklist Review Point Question to Ask Nature of Check Product identity Is the substance exactly one of the notified products? Applicability CRZ classification Which CRZ category covers the site? Location review CRZ-IA Does the project touch the excluded category? Critical scope check Proposed activity Is it receipt/storage or something wider? Activity review Annexure-II entry Does the product match the amended wording? Source-based check Existing clearance Is the product already covered? Project-specific review Approval conditions Are there restrictions on activity or storage? Compliance review Other approvals Does another legal framework apply? Due diligence Documentation Are project descriptions consistent? Internal control Benefits for Businesses The amendment provides clearer treatment for the named products within Annexure-II. For businesses considering eligible receipt and storage operations outside CRZ-IA, this may help in several ways. Better Regulatory Clarity: The product names now appear directly in the amended text. Easier Early-Stage Review: Project teams can identify the relevant Annexure-II entry without trying to fit the product into another description. Better Project Documentation: The amendment gives businesses a clear regulatory reference to use while preparing or reviewing project documents. More Informed Investment Decisions: A developer can assess the product's regulatory position before committing to a coastal storage project. These benefits should not be confused with guaranteed clearance or lower project costs. Challenges Businesses Still Need to Manage The amendment may provide more clarity in some cases, but businesses still need to check the details of their own projects. The applicable CRZ category, product, activity and existing approvals can all affect how the provision applies. CRZ Classification Can Still Change the Answer The amendment is not useful in exactly the same way across every CRZ category. The Product Must Match the Entry Similar products should not automatically be included. Existing Approvals May Have Their Own Limits A general amendment cannot simply be substituted for the wording of an individual project approval. Activity Matters A facility involved in manufacturing or processing should not rely only on a provision dealing with receipt and storage. Multiple Teams May Need to Coordinate Legal, environment, project, engineering and commercial teams may all be using different product descriptions. That can create avoidable confusion if documents are not aligned. Compliance Risks to Avoid Businesses should be especially careful about the following: treating CRZ-IA as covered,  describing the amendment as permission for all petroleum products,  assuming storage permission includes manufacturing,  using a similar product name without checking the exact entry,  assuming existing project approval automatically changes,  relying only on a commercial product name,  overlooking project-specific clearance conditions,  treating G.S.R. 832(E) as a replacement for the entire CRZ Notification, 2019.  The biggest risk is not necessarily missing the notification. It is reading more into it than the text actually provides. Business Opportunities Created by the Amendment The change may make certain project discussions more commercially relevant for businesses dealing with the named products. Possible areas include: coastal storage infrastructure,  terminal planning,  port-linked storage proposals,  modification of existing storage facilities,  regulatory due diligence,  CRZ applicability review,  environmental compliance consulting.  These are possible business opportunities arising from greater regulatory clarity. The Gazette does not provide market projections, investment estimates or revenue forecasts. Is This a Regulatory Relief or Does Compliance Still Matter? For businesses dealing with LAB, N-Paraffin or Carbon Black Feedstock, the amendment can reasonably be seen as a useful regulatory clarification. The products now have clear entries in Annexure-II. But the relief is not unlimited. CRZ-IA remains outside the permission discussed. The Gazette also does not convert the product entry into automatic approval for a specific project. So, while the amendment may remove one layer of uncertainty around the listed products, it does not remove the need for project-level compliance review. Business and Regulatory Perspective The 2026 amendment has implications for regulators, businesses and project teams dealing with activities covered by the CRZ framework. Each group may need to look at the amendment from a different perspective, depending on its role and the nature of the proposed activity. From the Regulator's Side The Gazette shows that the proposal moved through several levels of review before the final amendment. State CZMA representations were considered, Expert Appraisal Committees examined the issue, NCZMA gave its recommendation, and a draft notification was put out for objections and suggestions. From the Business Side The clearer product list may help companies understand whether their proposed storage activity falls within the Annexure-II framework. That can be useful when reviewing the feasibility of coastal terminals or storage facilities. From the Compliance Side The amendment reduces ambiguity around the named products but does not remove the need to read project approvals and CRZ classifications carefully. Impact on Different Stakeholders Stakeholder Likely Impact Main Point to Review Coastal storage terminals Clearer Annexure-II position for named products Site and product Petroleum companies Greater clarity for eligible storage planning Exact activity Chemical companies Direct relevance for named products Product identity Port-linked facilities Possible relevance for receipt/storage Project approval Existing clearance holders Need to compare current approval with new proposal Approval conditions New project developers Amendment can support early planning CRZ category Compliance teams Need to prevent overbroad interpretation Scope of notification What Businesses Should Do Next First: Check the Product: Confirm whether the material is genuinely LAB, N-Paraffin or Carbon Black Feedstock. Second: Check the Site: Establish the exact CRZ classification. Third: Check CRZ-IA: Do not overlook the express exclusion. Fourth: Define the Activity: Make sure the proposal is correctly described as receipt/storage if that is what is being relied upon. Fifth: Read Existing Approvals: Do not assume older clearance conditions have changed automatically. Sixth: Review Other Applicable Requirements: Where another permission may apply, check it separately. Seventh: Keep Documents Aligned: Regulatory, technical and commercial descriptions should not contradict one another. How Corpseed Can Help with CRZ Clearance and Environmental Compliance A short notification can create a surprisingly detailed project question. A business may know that its product now appears in Annexure-II but still be unsure whether the proposed location, project activity and existing clearance allow it to rely on the amendment. This is where a project-specific CRZ applicability assessment becomes useful. Corpseed can support businesses with: 1.    CRZ Applicability Assessment Reviewing the project location, proposed activity and relevant product against the applicable CRZ framework. 2. CRZ Clearance Services Supporting businesses where a project requires CRZ clearance services, regulatory documentation or project-specific compliance review. 3. Existing Clearance Review Checking whether the existing approval already covers the proposed product and activity. 4. Annexure-II Applicability Review Comparing LAB, N-Paraffin or Carbon Black Feedstock with the exact wording of the amended entries. 5. Environmental Compliance Gap Assessment Identifying gaps between the proposed activity and the regulatory documents already held by the project. 6. Regulatory Documentation Support Helping project teams organise and align technical, environmental and regulatory information. 7. Environmental Compliance Services Supporting projects where CRZ requirements sit alongside other applicable environmental approvals or conditions. 8. Ongoing Compliance Support Assisting businesses in tracking project-specific conditions and later regulatory changes. A CRZ clearance consultant should not treat the presence of a product in Annexure-II as automatic permission for the project. The more useful approach is to check the product, location, activity and existing approval together. For businesses planning receipt or storage of Linear Alkyl Benzene, N-Paraffin or Carbon Black Feedstock in coastal areas, Corpseed's CRZ clearance services can help determine how G.S.R. 832(E) applies to the actual project before an operational or investment decision is taken. Key Takeaways MoEFCC issued G.S.R. 832(E), dated 22 September 2026, as a further amendment to the Coastal Regulation Zone Notification, 2019.  Annexure-II now carries entries for Bitumen, Linear Alkyl Benzene, N-Paraffin, and Carbon Black Feedstock.  The background to the amendment concerns receipt and storage of LAB, N-Paraffin and Carbon Black Feedstock.  CRZ-IA is expressly excluded from the permission discussed in the notification.  The amendment does not expressly give blanket permission for manufacturing or processing.  Annexure-II inclusion is not the same as automatic approval of an individual coastal project.  Existing clearance holders should check their own approval conditions before changing products or activities.  The final amendment followed committee review, NCZMA consideration and a 60-day public consultation process.

Subject

Summary: The Ministry of Environment, Forest and Climate Change has issued a draft proposal for an Eco-Sensitive Zone (ESZ) around Nagarahole Tiger Reserve in Karnataka. The draft was issued as S.O. 4862(E) on 2, September 2026, under the Environment (Protection) Act, 1986 and the Environment (Protection) Rules, 1986. It is open for public objections and suggestions and should not yet be read as the final Nagarahole ESZ notification.  The proposal is particularly relevant for businesses with land, projects or operations around Nagarahole. Hotels, resorts, construction companies, industrial units, mining and quarrying businesses, infrastructure developers, MSMEs and landowners could all be affected differently depending on where the project lies and what activity is proposed. The draft places some activities in the prohibited category, keeps others regulated, and separately identifies activities that are to be promoted. That distinction matters. Being located inside an Eco-Sensitive Zone does not automatically mean that every business activity stops. The real answer depends on the exact location, land use, type of project and the category in which the activity falls. Nagarahole Eco-Sensitive Zone Draft Notification at a Glance Particular Details Issuing Authority Ministry of Environment, Forest and Climate Change Notification Number S.O. 4862(E) Date 2 September 2026 Status Draft Notification Legal Basis Environment (Protection) Act, 1986 and Environment (Protection) Rules, 1986 Protected Area Nagarahole Tiger Reserve State Karnataka Tiger Reserve Area Mentioned 843.96 sq. km Proposed ESZ Area 573.959 sq. km General ESZ Extent Stated 0 to 7.5 km Villages Covered 101 villages, wholly or partly Village Area 271.61 sq. km Notified Reserve Forest Area 302.36 sq. km Consultation Objections and suggestions invited Consultation Period 60 days from the date Gazette copies containing the notification are made available to the public Final Effective Date Not yet specified because this is a draft Important Business Sectors Hotels, tourism, construction, industries, mining, infrastructure, agriculture and land development The draft places Nagarahole Tiger Reserve in Mysore district and Kodagu district and records an area of 843.96 sq. km for the reserve.  What Is the Nagarahole Tiger Reserve Eco-Sensitive Zone Proposal? The proposal seeks to create a controlled area around Nagarahole Tiger Reserve where development would be managed more carefully. An Eco-Sensitive Zone is not the same as the Tiger Reserve itself. Land falling inside the ESZ does not automatically become part of the National Park or Tiger Reserve. Instead, the surrounding area is subject to a separate set of controls designed to reduce development pressure near an ecologically sensitive protected area. Under the Nagarahole draft, businesses would broadly fall into one of three situations: the activity may not be allowed,  the activity may continue or be undertaken subject to regulation and approval, or  the activity may be encouraged because it is considered more compatible with the surrounding environment.  For a business owner, this means the first question should not simply be, "Is my land near Nagarahole?" A more useful set of questions would be: Is the land actually within the proposed ESZ boundary?  Which activity is proposed on that land?  Is that activity prohibited, regulated or promoted?  Is it a new project or expansion of an existing activity?  Does another environmental approval also apply?  Those questions give a much clearer picture of the regulatory position. Why Has the Government Proposed an Eco-Sensitive Zone Around Nagarahole? The Gazette spends considerable space explaining why the landscape around Nagarahole needs protection. Nagarahole forms part of the Nilgiri Biosphere Reserve and is also part of the Mysore Elephant Reserve. It connects with other important wildlife landscapes, including Bandipur Tiger Reserve and Wayanad Wildlife Sanctuary. The document also notes links through reserve forests towards the Brahmagiri landscape.  The area is also important from a water perspective. The reserve acts as a catchment for perennial streams and tributaries linked to the Kaveri, Lakshmanathirtha and Kabini rivers. The Gazette records extensive floral and faunal diversity, including tiger, elephant, leopard, gaur, deer species, reptiles and hundreds of recorded bird species.  The concern, therefore, is not only what happens inside the Tiger Reserve. Development immediately outside a protected area can also affect wildlife movement, water bodies, forest edges, noise levels, traffic and habitat quality. The proposed ESZ is meant to place tighter controls on such pressure while leaving room for compatible local, and economic activity. Is the Nagarahole ESZ Notification Final or Still a Draft? It’s still a draft. S.O. 4862(E), dated 2 September 2026, has been published for public consideration. The Ministry has invited objections and suggestions before the proposal moves towards finalisation.  This distinction should remain clear throughout any business or legal assessment. For example, it would be inaccurate at this stage to say: the Nagarahole ESZ has finally been notified under S.O. 4862(E),  every proposed restriction is already permanently in force,  the final ESZ boundary is settled,  or the 2026 draft itself creates a final compliance deadline.  The final notification may retain the draft as it is, amend individual provisions, correct drafting issues or change parts of the proposed framework. Businesses should therefore treat the document seriously, but also keep its draft status in mind when making long-term decisions. Public Consultation: How Can Stakeholders Submit Objections or Suggestions? The Ministry has given interested persons an opportunity to submit objections or suggestions on the proposal. The Gazette says submissions may be sent to: The Secretary Ministry of Environment, Forest and Climate Change Indira Paryavaran Bhawan Jorbagh Road, Aliganj New Delhi- 110003 The draft also mentions the email address: esz-mef@nic.in  What is the consultation period? The notification refers to 60 days from the date on which copies of the Gazette containing the notification are made available to the public. That wording matters. The Gazette does not simply say "60 days from 2 September 2026", so an exact last date should not be assumed without separately verifying when the Gazette copies were made available. Who may want to review the draft? The consultation may be especially relevant for: existing hotels and resorts,  landowners,  industrial units,  mining or quarrying interests,  developers,  local businesses,  infrastructure companies,  tourism operators,  farmer or livelihood groups, and  businesses planning investment near the proposed ESZ.  A representation is more useful when it identifies a specific problem, such as a boundary issue, inconsistent figure, effect on an existing project or unclear wording. What Area Will the Proposed Nagarahole Eco-Sensitive Zone Cover? The draft gives the proposed ESZ an area of 573.959 sq. km. It states that the zone will extend from 0 to 7.5 km around the boundary of Nagarahole Tiger Reserve.  The direction-wise figures given in the document are: Direction Distance Mentioned in Draft North 1–6.9 km North-East 5.20 km East 7.4 km South-East 0 km South 0 km South-West 0 km West 1 km North-West 24.08 km* The 24.08 km entry does not appear consistent with the stated maximum ESZ extent of 7.5 km and needs clarification. Why Is the ESZ Zero Kilometres in Some Directions? The Gazette itself gives the reason. It says the ESZ has been kept at zero kilometres towards the south-east, south and south-west because those directions meet the interstate boundary with Kerala.  How Many Villages Are Included? The proposal covers 101 villages, either fully or partly, with a combined geographical area of 271.61 sq. km. The notified reserve forest area within the proposed ESZ is given as 302.36 sq. km. This does not mean every parcel of land in all 101 villages has the same regulatory position. For a project-level decision, actual coordinates and the official boundary should be checked. Important Drafting Issue: 0-7.5 km ESZ vs 24.08 km North-West Entry One figure in the draft deserves closer attention. The document describes the ESZ as extending from 0 to 7.5 km around Nagarahole Tiger Reserve. Yet the direction table gives 24.08 km as the north-west extent.  These two figures do not appear to match. The safest approach is not to "correct" the number on assumption. Until MoEFCC clarifies the matter, businesses with projects in the north-western side of the proposed zone should check: Annexure IA,  Annexure IB,  Annexure II map,  Annexure III geographical coordinates,  Annexure IV village details,  and any clarification or final notification subsequently issued.  For land purchase, construction planning or project finance, relying only on the headline "7.5 km ESZ" may therefore be risky. How Can Businesses Check Whether Their Land or Project Falls Within the Proposed ESZ? Location verification should be done with more than a simple online map search. The Gazette provides several reference points for determining the proposed boundary: Annexure IA- boundary of Nagarahole Tiger Reserve,  Annexure IB- ESZ boundary description,  Annexure II- map,  Annexure IIIA and IIIB- prominent geographical coordinates,  Annexure IV- villages within the proposed zone,  Annexure V- adjoining reserve forest areas.  A practical review should cover three levels 1. Village check First see whether the village appears in Annexure IV. This is only the first filter. 2. Coordinate check Match the project site's actual latitude and longitude with the proposed ESZ boundary information. 3. Activity check Once location is established, determine how the business activity is classified. This order is useful because a project may be geographically affected but still fall under a regulated or promoted category rather than a prohibited one. For businesses making large investments, an environmental due diligence review before land acquisition or construction can help identify such risks early. The Regulatory Framework Behind the Draft Notification The proposal has been issued under the Environment (Protection) Act, 1986 and the Environment (Protection) Rules, 1986.  The draft also refers to several other legal and regulatory frameworks. These include: Wildlife (Protection) Act, 1972,  forest-related legislation,  Environmental Impact Assessment Notification, 2006,  Karnataka Forest Act, 1963,  Karnataka Forest Rules, 1969,  pollution-control laws,  and other applicable Central and State requirements.  This means ESZ compliance would sit alongside existing approvals rather than replace them. A project may still have to consider matters such as: Environmental Clearance,  Consent to Establish,  Consent to Operate,  waste-management compliance,  groundwater or water-use permissions,  construction approvals,  forest-related conditions,  tourism requirements,  and land-use permissions.  The exact combination depends on the project. What Is the Proposed Zonal Master Plan for Nagarahole ESZ? The Zonal Master Plan is central to how development may eventually be managed inside the proposed ESZ. The draft says the Karnataka Government would prepare this plan within two years from publication of the final notification in the Official Gazette.  The two-year period therefore does not automatically start from 2 September 2026. Which departments would be involved? The plan is to be prepared in consultation with departments dealing with: environment,  forests and wildlife,  agriculture,  revenue,  urban development,  tourism,  rural development,  irrigation and flood control,  municipal administration,  Panchayati Raj, and  public works.  What would the Zonal Master Plan cover? The plan is expected to address: forests,  villages and urban settlements,  agricultural land,  fertile land,  parks,  green areas,  horticulture,  orchards,  lakes,  water bodies,  groundwater,  catchment areas,  degraded land,  infrastructure,  and community needs.  It would also act as a reference point for the Monitoring Committee once approved.  For a developer, this is important because the final ESZ notification may provide the broad rule, while the Zonal Master Plan could provide more detailed location-level development controls. What Happens to Existing Land Use and Existing Activities? The draft gives some comfort to approved existing uses, but it should not be read too widely. It says the Zonal Master Plan should not restrict approved existing land use, infrastructure and activities unless specifically provided for in the notification.  That is different from saying every existing activity can continue unchanged. For instance: expansion of an existing polluting industry is treated separately,  tourism expansion has its own conditions,  land conversion can face restrictions construction can be restricted other permits may still be needed Existing businesses should review current land-use approval pollution-control consents environmental clearance, where applicable any proposed capacity increase,  new construction plans,  land conversion,  and whether the business appears in a prohibited or regulated activity category.  A compliance gap assessment can be useful where an existing unit has several approvals issued at different times. Land Use Conversion Rules Within the Proposed Eco-Sensitive Zone The draft proposes restrictions on converting certain categories of land for intensive development. Forests, horticulture areas, agricultural areas, parks and open spaces earmarked for recreation are not proposed to be freely converted into: major commercial development,  major residential complexes, or  industrial areas.  Certain conversions may still be considered for local residential and related needs, but these are linked to the recommendation of the Monitoring Committee and prior approval from the competent authority. The draft mentions activities such as: roads,  civic amenities,  small non-polluting industries,  village and cottage industries,  convenience stores,  local eco-tourism facilities,  and other promoted activities.  The practical point is simple: land ownership and development permission are not the same thing. A buyer may own the land but still need to check whether the intended use is permitted at that location. Which Activities Are Prohibited, Regulated or Promoted in the Proposed Nagarahole ESZ? This is one of the most useful parts of the draft for businesses. Category Broad Meaning Examples Prohibited Activity proposed not to be allowed, subject to stated exceptions Mining, polluting industries, new sawmills, brick kilns Regulated Activity may be allowed subject to conditions, permissions or applicable law Hotels, construction, roads, industries, water extraction Promoted Activity the proposed framework seeks to encourage Organic farming, rainwater harvesting, renewables, green technology Prohibited Activities The draft identifies several activities that would not be permitted within the proposed ESZ. These include mining, polluting industries, waste-related activities and certain other commercial activities. 1. Commercial Mining, Quarrying and Crushing The draft proposes a ban on new and existing mining, quarrying, and crushing activities, except in limited cases involving the domestic needs of bona fide local residents. It also refers to multiple Supreme Court orders relating to mining. 2. Polluting Industries The proposal says no new polluting industries should be set up inside the ESZ and expansion of existing polluting industries should not be permitted. 3. Other Activities Listed as Prohibited The draft also places the following in the prohibited category: thermal and major hydroelectric projects in the English text,  hazardous substances,  discharge of untreated effluent,  new solid-waste disposal facilities,  common or individual incineration facilities in specified cases,  new sawmills,  expansion of existing sawmills,  brick kilns,  commercial firewood use,  new wood-based industries,  certain over-flight tourism activities.  Each activity should still be read together with the exact wording and any exception attached to it. Regulated Activities A regulated activity is not necessarily prohibited. The draft places a much wider group of activities in this category. Hotels and Resorts New commercial hotels and resorts face specific distance restrictions near the Tiger Reserve. Construction Commercial construction is restricted within the specified inner area, while local residential, infrastructure and other specified activities receive different treatment. Non-Polluting Industries Small-scale, service and certain agro-based industries may be permitted subject to classification and competent-authority approval. Tree Felling Tree cutting on forest, government, revenue or private land is linked to prior permission from the competent State authority. Infrastructure Electrical lines, telecom towers, optical-fibre cables, pipelines, civic infrastructure and roads remain subject to regulation and mitigation measures. Water Use Commercial extraction of surface and groundwater and use of open wells or bore wells are also placed under regulatory control. Other Regulated Activities The draft additionally covers: livestock and poultry farms,  hill slopes and riverbanks,  commercial night traffic,  agriculture and horticulture,  wastewater,  solid waste,  exotic species,  eco-tourism,  polythene bags,  and commercial signboards.  Activities the Draft Seeks to Promote Not every economic activity receives restrictive treatment. The proposal actively encourages: rainwater harvesting,  organic farming,  green technology,  cottage industries,  village artisan activity,  renewable energy,  biogas,  solar lighting,  agroforestry,  horticulture,  herbal plantations,  eco-friendly transport,  skill development,  restoration of degraded land and habitat,  environmental awareness.  Businesses should, however, avoid reading "promoted" as "automatically approved". Land, construction, pollution and sector-specific approvals may still be required. What Does the Draft Mean for Hotels, Resorts and Tourism Businesses? Tourism receives detailed treatment in the proposal. The draft says that no new hotel or resort should be allowed within one kilometre from the Tiger Reserve boundary or up to the extent of the ESZ, whichever is nearer, apart from specified small temporary eco-tourism structures.  Beyond one-kilometre, new hotels and resorts would be tied to pre-defined eco-tourism areas under the Tourism Master Plan. New tourism activity and expansion of existing tourism businesses would also need to follow relevant MoEFCC and National Tiger Conservation Authority guidelines.  What should a hotel or resort developer check? Before buying land or preparing a project report, it would be sensible to review: distance from the protected-area boundary,  whether the land lies inside the proposed ESZ,  village and coordinate information,  forest/non-forest status,  Tourism Master Plan implications,  commercial construction restrictions,  pollution-control requirements,  water availability and permissions,  waste-management requirements,  any separate Environmental Clearance applicability.  For hospitality projects, environmental due diligence should ideally happen before major expenditure rather than after construction planning is complete. Construction Restrictions Within and Around the Proposed ESZ The draft takes a stricter view of new commercial construction near the Tiger Reserve. It proposes that no new commercial construction should be allowed within one kilometre from the Tiger Reserve boundary or up to the ESZ limit, whichever is nearer.  However, the provision also recognises certain local needs. These include, subject to applicable conditions: residential construction for local people,  road improvement,  civic infrastructure,  small non-polluting industries,  cottage industries,  local eco-tourism facilities,  and promoted activities.  Beyond one kilometre, the draft says construction would be regulated according to the Zonal Master Plan.  Therefore, saying "all construction is prohibited within one kilometre" would be misleading. The type of construction matters. Which Industries May Operate Within the Proposed Eco-Sensitive Zone? The draft makes a clear distinction between polluting and non-polluting industries. Polluting Industries The English text says: no new polluting industry should be allowed, and  expansion of existing polluting industries should not be permitted.  Businesses planning expansion should therefore pay close attention to how the final notification treats existing industrial units. Non-Polluting Industries Non-polluting industries receive a more favourable position, subject to the CPCB classification referred to in the draft. A company should not simply decide for itself that its activity is non-polluting. Classification should be checked against the relevant regulatory framework. Small-Scale, Service and Agro-Based Industries The regulated-activity table also refers to: non-hazardous small industries,  service industries,  agriculture,  floriculture,  horticulture, and  agro-based industries using indigenous materials.  These may be permitted by the competent authority subject to the applicable conditions.  For MSMEs, this distinction could be important because the proposal is not a blanket industrial ban. What Does the Draft Mean for Mining, Quarrying and Stone-Crushing Units? Mining and quarrying receive particularly strict treatment. The draft proposes that new and existing minor and major mineral operations, stone quarrying and crushing units should be prohibited, apart from the limited local domestic-use exception mentioned in the document.  The wording in the activity table uses "immediate effect", but there is an important legal caution: the document itself is still a draft. It would therefore be unsafe to describe this draft alone as having finally brought the Nagarahole ESZ mining ban into permanent force. Mining leaseholders, quarry operators and related businesses should review the final notification carefully once issued and separately consider the Supreme Court orders referred to in the Gazette. What Does the Draft Mean for Real Estate and Infrastructure Projects? Real estate projects need a land-use and construction review, while infrastructure projects are more commonly placed under regulated activity. The draft allows several forms of infrastructure subject to mitigation measures and applicable law, including: road widening,  new roads,  civic infrastructure,  electricity infrastructure,  telecommunications towers,  optical-fibre cables,  pipelines, and  related facilities.  Underground cabling is specifically encouraged. Hill slopes receive additional protection. The Zonal Master Plan is expected to identify areas where construction should not be permitted, and the draft states that construction should not take place on existing steep slopes or slopes with a high degree of erosion.  For developers, an early land and project compliance assessment can help identify whether environmental restrictions make a site unsuitable before substantial capital is committed. Environmental Compliance Requirements for Businesses Operating in the Proposed ESZ The proposed ESZ does not create a separate replacement for India's wider pollution-control system. Several existing environmental requirements continue to matter. Air Pollution Control The draft links air-pollution control with the Air (Prevention and Control of Pollution) Act, 1981 and applicable rules. Noise Pollution Noise control is linked with the Noise Pollution (Regulation and Control) Rules referred to in the Gazette. Businesses generating substantial noise may therefore need to consider both normal pollution requirements and the added sensitivity of the ESZ location. Wastewater and Effluent Untreated discharge receives strict treatment. For treated wastewater, the draft encourages recycling and reuse and links discharge to applicable standards. Solid Waste The proposal links solid-waste handling to the rules cited in the Gazette and restricts burning, incineration and landfill establishment within the ESZ. Biomedical Waste Biomedical waste is separately addressed, including restrictions on common treatment facilities, or incineration within the ESZ. Plastic Waste The draft also cross-refers to plastic-waste requirements. Construction and Demolition Waste Construction projects would have to consider both ESZ construction restrictions and C&D waste requirements. E-Waste The Gazette separately refers to e-waste management as well.  Where businesses have multiple environmental approvals, environmental compliance services can help bring land-use, pollution, waste and project-level obligations into one review rather than checking each approval in isolation. How Will Projects in the Proposed ESZ Be Scrutinised Under the EIA Framework? The Monitoring Committee is proposed to play a screening and referral role. Projects Covered by the EIA Notification Activities falling within the Schedule to the EIA Notification referred to in the draft would be examined on the basis of site-specific conditions. Where required, the matter would be referred to MoEFCC for prior Environmental Clearance under that framework.  This does not mean that every project inside the ESZ requires Environmental Clearance. The project's category under the EIA framework still matters. Activities Not Covered by the EIA Schedule Activities outside the EIA Schedule may still be reviewed by the Monitoring Committee and referred to the appropriate authority where necessary.  Businesses uncertain about their category may need EIA compliance support or environmental clearance services before filing applications or finalising project design. Protection of Tribal Land and Rights of Forest-Dwelling Communities The draft places specific safeguards around tribal land. It says tribal land should not be used for commercial or industrial development without prior approval under applicable State law and compliance with Article 244 of the Constitution and the forest-rights legislation referred to in the notification.  This becomes relevant for developers because title documents alone may not always settle every question. A project can have issues connected with: land classification,  tribal rights,  forest rights,  conversion,  local approval,  and environmental location.  Each should be checked separately where applicable. Who Will Monitor Compliance with the Nagarahole ESZ Framework? The draft proposes a dedicated Monitoring Committee. Its membership includes representatives from: the Regional Commissioner,  Karnataka's Environment Department,  Urban Development Department,  wildlife conservation organisations,  Karnataka State Pollution Control Board,  State Biodiversity Board,  an ecology expert,  Mysore and Kodagu district administration,  and Nagarahole Tiger Reserve/forest administration.  What Would the Monitoring Committee Do? Its proposed role includes: checking compliance, examining site-specific conditions, scrutinising projects, referring EIA matters, referring non-EIA matters to relevant authorities, dealing with certain land-record issues, inviting experts or industry representatives, and supporting enforcement under the Environment (Protection) Act. How Long Would the Committee Continue? The draft gives the committee a tenure of three years or until reconstitution, after which the State Government would constitute the subsequent committee. Annual Action Taken Report The committee would also submit an annual report. Annexure VI asks for details on: committee meetings,  minutes,  status of the Zonal Master Plan,  Tourism Master Plan,  land-record correction cases,  EIA cases,  non-EIA cases,  complaints, and  other relevant matters.  What Happens Until the Zonal Master Plan Is Approved? The period before approval of the Zonal Master Plan may be especially sensitive for tourism projects. The draft says tourism development or expansion outside forest land may be considered by regulatory authorities based on site-specific scrutiny and Monitoring Committee recommendation. At the same time, the same provision contains restrictive language concerning new hotels, resorts and commercial-establishment construction during this period.  Businesses should therefore avoid two assumptions. First, they should not assume that no Zonal Master Plan means there are no restrictions. Second, they should not treat the current draft wording as a final legal position until MoEFCC publishes the final notification. How Could the Draft Nagarahole ESZ Notification Affect Businesses? Business/Stakeholder Likely Concern What Should Be Checked Hotels and Resorts Distance-based development restrictions ESZ boundary, 1 km rule, Tourism Master Plan Industrial Units Polluting/non-polluting classification CPCB category, expansion plans, pollution approvals Construction Companies Commercial construction controls Location, project type, Zonal Master Plan Real Estate Developers Land conversion and development restrictions Land use, coordinates, construction category Infrastructure Companies Mitigation and approval requirements Project alignment, environmental approvals Mining/Quarrying Units Strict proposed prohibition Lease location, ESZ boundary, court orders MSMEs Classification of activity Pollution category and competent authority Landowners Future development potential Exact boundary and permitted land use Agriculture/Horticulture Businesses Water use and land-use changes Local activity status, extraction permissions What Could the Proposed ESZ Framework Achieve? The proposal has a clear conservation objective. If implemented effectively, the framework could help: reduce pressure from high-impact development close to the reserve, manage tourism expansion, protect wildlife corridors, protect water bodies and catchments, limit polluting industries, improve waste control, encourage lower-impact businesses, restore degraded habitat, and create a structured monitoring system. The success of such a framework, however, depends heavily on boundary clarity, and consistent implementation. What Challenges Could Businesses Face Under the Proposed ESZ Rules? The biggest challenge may not always be an outright prohibition. For many projects, the difficulty will be figuring out exactly which rule applies. 1. Boundary Uncertainty The 0-7.5 km statement and the 24.08 km north-west entry create a clear question for location assessment. 2. Land-Use Limitations A site may be privately owned but still face restrictions on conversion or development. 3. Expansion Constraints An existing unit may be allowed to continue but face restrictions if it wants to expand. 4. Additional Project Scrutiny A project may need review by the Monitoring Committee or another environmental authority. 5. Design Changes Hotels, roads, buildings or infrastructure may need to be redesigned to comply with environmental conditions. 6. Additional Due Diligence Investors may need deeper checks before acquiring land. 7. Approval Coordination A project may involve the ESZ framework, pollution-control consents, environmental clearance, land approvals and sector-specific permissions at the same time. For such cases, environmental regulatory consulting can help a business understand the approval sequence instead of treating each requirement separately. Is the Proposed Nagarahole Eco-Sensitive Zone a Necessary Protection or an Additional Business Burden? Both sides of the issue deserve consideration. Why the Environmental Controls May Be Necessary? Nagarahole is a major wildlife and forest landscape. The Gazette records its ecological connection with tiger, elephant and forest habitats, along with important river systems. Uncontrolled mining, polluting industries or intensive commercial construction close to such an area can create lasting effects that are difficult to reverse. Restrictions on high-impact activities therefore have a clear environmental rationale. Where Businesses May Face Practical Difficulty Businesses need regulatory certainty before investing. A hotel developer, industrial unit or land buyer needs to know the exact boundary and what can legally be built at a particular site. Ambiguous figures, inconsistent dates or different wording between the Hindi and English texts make that job harder. A balanced final framework would therefore need both: meaningful environmental protection, and  clear, workable rules for businesses and local communities.  Which Business Activities Could Find Opportunities Under the Proposed ESZ Framework? The proposal also points towards activities that may fit better with the environmental character of the region. Potential areas include: organic farming,  agroforestry,  horticulture,  herbal cultivation,  renewable energy,  biogas,  solar solutions,  rainwater harvesting,  low-impact eco-tourism services,  green technology,  eco-friendly mobility,  habitat restoration,  and local cottage industries.  There may also be greater demand for: environmental due diligence,  pollution compliance,  project classification,  waste-management support,  environmental audits,  and environmental compliance services.  These are possible business opportunities, not guaranteed markets or government incentives. Which Points in the Draft Require Clarification Before the Final Notification? The draft contains several issues that should ideally be clarified. 1. 0-7.5 km vs 24.08 km North-West Extent: The body of the notification describes an ESZ of up to 7.5 km. The direction table, however, records 24.08 km for the north-west.  For land and project decisions, that is a material difference. 2. CPCB Classification Date Differs: The English version refers to CPCB industry-classification guidelines issued in January, 2025. The Hindi table refers to February 2025 for polluting industries, while another Hindi entry refers to February 2026 for non-polluting small industries. That date should be verified officially. 3. Thermal Project Wording Is Not Fully Aligned: The English table refers to thermal, and major hydroelectric projects. The corresponding Hindi passage shown in the Gazette refers to a major hydroelectric project without the same explicit thermal wording. This is another point that deserves clarification in the final text. What Should Businesses Do Before the Nagarahole ESZ Notification Is Finalised? Businesses do not need to wait for the final notification before reviewing their exposure. A useful sequence would be: Step 1: Confirm the Project Location Use actual coordinates, and the proposed boundary information. Step 2: Check the Village See whether the village appears in the draft annexure. Step 3: Identify the Activity Category Check whether the activity is: prohibited,  regulated, or  promoted.  Step 4: Review Existing Approvals Check: land-use approval,  Consent to Establish,  Consent to Operate,  Environmental Clearance,  waste approvals,  building permissions,  and sector-specific approvals.  Step 5: Review Future Expansion Do not assume an existing project, and its proposed expansion receive the same treatment. Step 6: Verify Pollution Classification Industrial units should confirm their regulatory category. Step 7: Check EIA Applicability Do this separately. ESZ location alone does not automatically determine EC applicability. Step 8: Review Construction and Tourism Restrictions This is particularly relevant for hotels, resorts, real estate and tourism businesses. Step 9: Record Genuine Concerns If the draft directly affects an existing or planned project, prepare a fact-based representation during the consultation period. Step 10: Watch for the Final Notification Final investment and compliance decisions should be checked again once MoEFCC finalises the proposal. Compliance Review Checklist for Projects Near Nagarahole Tiger Reserve Review Area Question to Ask Why It Matters Location Is the site actually inside the proposed ESZ? Determines whether the ESZ framework is relevant Village Is the village listed in Annexure IV? Helps narrow the review Coordinates Does the actual site fall within mapped limits? More reliable than approximate distance Land Use What is the approved present land use? Conversion may be restricted Activity Prohibited, regulated or promoted? Determines regulatory treatment Construction Is new commercial construction planned? Distance conditions may apply Tourism Hotel, resort or tourism project? Separate rules apply Industry Polluting or non-polluting category? Industrial treatment differs EIA Does the project fall under the EIA framework? EC requirement depends on project category CTE/CTO Are Pollution Control Board consents needed? ESZ does not replace normal pollution approvals Expansion Is capacity or built-up area being increased? Expansion can be treated separately Water Is groundwater/surface-water extraction proposed? Water use is regulated Waste What waste streams will the project generate? Separate waste rules apply Consultation Is there a direct concern with the draft? Stakeholder comments may be submitted How Can Corpseed Help Businesses Assess Nagarahole ESZ Compliance? A business planning activity around Nagarahole may have to deal with more than one authority and more than one law. Corpseed can provide environmental compliance services to help businesses understand where ESZ restrictions sit within the wider project-approval framework. ESZ Applicability and Location Review Corpseed can help review: project coordinates,  proposed ESZ boundary information,  village details,  business activity,  land use,  and the applicable regulatory category.  The purpose is to identify possible issues before a project moves too far into investment or construction. Environmental Compliance Gap Assessment For an existing business, a compliance gap assessment can check whether current approvals match the way the business is operating. The review may cover: environmental approvals,  pollution-control consents,  waste compliance,  expansion,  land-use conditions,  and new ESZ-related considerations.  Environmental Clearance and EIA Applicability Support Where a project may fall within the EIA framework, Corpseed can assist with: applicability assessment,  project categorisation,  documentation,  filing support,  PARIVESH-related requirements,  and regulatory coordination.  This should be treated as EIA compliance support, not as an assumption that every ESZ project needs Environmental Clearance. Pollution Control Consent Support Where applicable, businesses can seek assistance for: Consent to Establish,  Consent to Operate,  renewal or amendment support,  pollution-control documentation,  and regulatory follow-up.  A pollution control consent consultant can be particularly useful where an industrial project is also dealing with ESZ-related land or location questions. Environmental Due Diligence for New Projects Before buying land or investing in a project, businesses can undertake environmental due diligence services covering: location,  land use,  ESZ exposure,  environmental approvals,  pollution-control permissions,  waste obligations,  and project-specific risks.  This may be especially relevant for real estate, industrial, tourism and infrastructure investments. Tourism and Hospitality Compliance For hotels, resorts, homestays and eco-tourism projects, Corpseed can assist with reviewing: ESZ location,  construction restrictions,  Tourism Master Plan relevance,  pollution-control requirements,  environmental permissions,  and project documentation.  Regulatory Representation Support Businesses directly affected by the draft may also need help organising an objection or suggestion. Support can include: reviewing the draft provision,  identifying the business concern,  compiling supporting facts,  preparing a structured representation,  and organising relevant regulatory documents.  Submission of a representation does not guarantee that the Ministry will accept the requested change. Key Takeaways MoEFCC issued Draft Notification S.O. 4862(E) on 2 September 2026 for the proposed Nagarahole Tiger Reserve Eco-Sensitive Zone.  The proposal is not yet a final ESZ notification.  The proposed zone covers 573.959 sq. km and includes 101 villages wholly or partly.  The draft generally states an extent of 0 to 7.5 km, but records 24.08 km towards the north-west, which requires clarification.  Mining and polluting industries receive strict proposed treatment.  Hotels, construction, infrastructure, water use and non-polluting industries fall under regulated provisions rather than one blanket prohibition.  Organic farming, renewable energy, green technology, cottage industries and rainwater harvesting are among the promoted activities.  The proposed Zonal Master Plan would be prepared within two years from publication of the final notification.  Businesses should verify coordinates, land use, activity classification and existing approvals before taking investment decisions.  Companies with project-specific questions may need environmental regulatory consulting or broader environmental compliance services before proceeding.

Subject

Summary: The Ministry of Environment, Forest and Climate Change has notified an Eco-Sensitive Zone around Karimpuzha Wildlife Sanctuary in Kerala through S.O. 4867(E) dated 2 September, 2026. The notified ESZ covers 44.24 square kilometres, and is stated to extend from zero to 3.40 kilometres around the sanctuary.  For a business, landowner or project developer, the real issue is not simply whether a site is “near a forest.” The Gazette lays down different rules depending on the exact location and the nature of the activity. Mining, and polluting industries face direct restrictions. Hotels, construction, infrastructure and tourism are regulated. Activities such as organic farming, rainwater harvesting, renewable energy and cottage industries are placed in the promoted category. Therefore, before buying land, expanding a resort, setting up a factory, or starting construction one must check whether the proposed site falls within the notified ESZ, and how close it is to the sanctuary boundary. Notification at a Glance The notification provides the following key details on the declaration, and management of the Eco-Sensitive Zone around Karimpuzha Wildlife Sanctuary: Particular Details Ministry Ministry of Environment, Forest and Climate Change Notification No. S.O. 4867(E) Date 2 September 2026 Protected Area Karimpuzha Wildlife Sanctuary Location Nilambur Taluk, Malappuram Revenue District, Kerala Sanctuary Area 227.97 sq. km Eco-Sensitive Zone Area 44.24 sq. km ESZ Extent Zero to 3.40 km, as stated in the notification Legal Basis Environment (Protection) Act, 1986 and Environment (Protection) Rules, 1986 Earlier Draft S.O. 4442(E), dated 29 September 2025 Zonal Master Plan To be prepared within two years from Gazette publication Main Activity Categories Prohibited, Regulated and Promoted Key Business Areas Industries, hotels, resorts, construction, tourism, infrastructure, mining and land development Karimpuzha Wildlife Sanctuary covers '227.97 sq. km', as well as includes parts of the New Amarambalam Reserved Forest and Vadakkekkota Malavaram vested forest.  The ESZ does not operate as a single “no activity” belt. The rules change according to the type of project and, in many cases, the distance from the protected-area boundary. What Is the Regulatory Framework Behind the Notification? The notification is released by the Central Government in accordance with Rule 5(3) of the Environment (Protection) Rules 1986 and Section 3 of the Environment (Protection) Act, 1986. Development around the wildlife refuge is restricted by the ESZ. While some actions are prohibited, others can only proceed after fulfilling the prerequisites and receiving the proper authorisations. Activities that are deemed appropriate for the location are also encouraged. The Gazette also links ESZ compliance with existing environmental laws dealing with air pollution, water pollution, noise, waste, construction activity and environmental impact assessment. Businesses should therefore avoid treating ESZ compliance as a stand-alone approval. A project may be acceptable under the ESZ table and still require separate permissions under pollution-control, planning, environmental clearance or other applicable laws. From the 2025 Draft to the Final 2026 Notification Before issuing the final order, the Ministry had published Draft Notification S.O. 4442(E) on 29 September 2025. The draft invited objections and suggestions for a period of 60 days from the date on which copies of the Gazette were made available to the public. The final Gazette states that copies were made available on 29 September 2025 and that the Central Government did not receive objections or suggestions from persons or stakeholders.  The final ESZ notification was then issued on 2, September 2026. This does not automatically mean that the final notification is identical to every line of the draft. A clause-by-clause “old vs new” comparison should only be made after separately checking both versions. Why Was the Karimpuzha Eco-Sensitive Zone Notified? The reasons given in the Gazette are closely connected with the geography and biodiversity of the sanctuary. Karimpuzha Forms Part of a Larger Protected Landscape Karimpuzha Wildlife Sanctuary lies on the western slopes of the Nilgiris, and forms part of the Nilgiri Biosphere Reserve. The sanctuary is also linked with other protected areas. It is bordered by Silent Valley National Park (Kerala) to the South and Mukurthi National Park (Tamil Nadu) to the East. These areas are part of a linked protected area network, which would allow wildlife to move. The Gazette calls these areas "movement corridors. The Area Supports Different Forest Types and Water Systems It is lowland forest and highland grassland. The notification lists six forest types in the area. It also refers to some small watersheds which are linked to the rivers and streams in Chaliyar River basin. The forest importance of these water systems is significant and for human beings in Malappuram and Kozhikode districts. Wildlife Diversity Is Another Major Reason The Gazette records more than: 26 mammal species,  100 bird species,  33 reptile species,  43 fish species, and  700 insect species.  It also records 305 tree species and refers to wildlife such as the Nilgiri Tahr, tiger, lion-tailed macaque, slender loris, bison and endangered Malabar Mahseer.  The ESZ has therefore been drawn around an area that already forms part of an important wildlife and forest landscape. What Is the Extent of the Karimpuzha Eco-Sensitive Zone? The notification states that the Eco-Sensitive Zone covers 44.24 sq. km and varies from zero to 3.40 km around the sanctuary. It includes forest areas falling in the: Karulai Forest Range,  Kalikavu Forest Range under Nilambur South Forest Division, and  Vazhikkadavu Forest Range under Nilambur North Forest Division.  Direction-Wise ESZ Extent Direction Extent Mentioned in Gazette Boundary Context North 0 to 1 km Mukurthi National Park boundary North-East 0 km Mukurthi National Park boundary East 0 km Mukurthi National Park boundary South-East 0 km Mukurthi National Park and Silent Valley buffer South 0 km Silent Valley National Park buffer South-West 0.6 to 1 km Habitations and Silent Valley buffer West 1 to 3.20 km Western side of ESZ North-West “2 to 1.20 km” as printed Exact boundary should be checked from maps/coordinates There Is an Apparent Difference in the Gazette Figures One point deserves careful attention.  The main paragraph says that the ESZ varies up to 3.40 km but the direction table records the western extent as up to 3.20 km. The North-West figure is printed as “2 to 1.20 kilometre.” The notification does not explain these figures further in the summary table. Businesses should therefore not attempt to “correct” the Gazette on their own. For an actual project, the safer approach is to examine the official boundary description, maps and geo-coordinates given in the annexures. Why Is the ESZ Zero Kilometres in Some Directions? The zero-kilometre entries have a specific reason. The Gazette explains that in some directions the sanctuary already adjoins another protected area or the interstate boundary. These include Mukurthi National Park, Silent Valley National Park and the Tamil Nadu boundary.  A zero-kilometre entry does not mean that environmental safeguards disappear on that side of the sanctuary. It only describes how this particular ESZ boundary has been drawn because another protected landscape, or boundary already lies next to it. Which Villages Fall Inside the Karimpuzha Eco-Sensitive Zone? Annexure IV names four villages falling inside the ESZ. Village Taluk District Vazhikadav Nilambur Malappuram Moothedam Nilambur Malappuram Karulai Nilambur Malappuram Amarambalam Nilambur Malappuram The Gazette also provides GPS coordinates for each of these villages.  Being situated in an ESZ does not automatically mean that residents cannot build, farm or carry on local livelihoods. The notification itself continues to recognise several local activities. The real question is what activity is being undertaken and under which regulatory category it falls. What Is the Zonal Master Plan? The State Government has to prepare a Zonal Master Plan for the Eco-Sensitive Zone within two years from the date of publication of the notification in the Official Gazette. The plan is to be prepared in consultation with local people and aligning with the ESZ notification, relevant Central and State laws and government guidelines.  The Zonal Master Plan will be one of the key documents that will guide future development in the area. The State Government has to prepare a Zonal Master Plan for the Eco-Sensitive Zone within two years from the date of publication of the notification in the Official Gazette. The plan is to be prepared in consultation with local people and in line with the ESZ notification, relevant Central and State laws and applicable government guidelines.  The Zonal Master Plan will be one of the main documents used to manage future development in the area. Which Departments Will Participate? The notification requires consultation with a wide range of State departments including: Environment,  Forest and Wildlife,  Local Self Government,  Agriculture,  Revenue,  Urban Development,  Tourism,  Rural Development,  Irrigation and Flood Control,  Municipality,  Panchayati Raj,  Public Works Department, and  Kerala State Pollution Control Board. This makes sense as development in an ESZ involves a number of subjects simultaneously. Land, forest, local-body, infrastructure and environmental issues can be considered together in a road project. What Will the Zonal Master Plan Cover? The plan must look at environmental protection as  well as existing local needs. Among other things, it has to cover: restoration of denuded land,  conservation of existing water bodies,  catchment and watershed management,  groundwater management,  soil and moisture conservation,  local community requirements,  villages and settlements,  agricultural areas,  parks and other green areas,  horticultural land,  orchards,  lakes and other water bodies, and  existing and proposed land use.  Once approved, it will also become an important reference document for the Monitoring Committee. What Happens Before the Zonal Master Plan Is Ready? Projects do not get a free window during the two-year planning period. The notification says that all new construction and other developmental activities are to be referred to the Monitoring Committee until the Zonal Master Plan is prepared.  Tourism has an additional rule. Until the Zonal Master Plan is prepared and approved, tourism development and expansion of existing tourism activity may be considered by the relevant regulatory authorities after site-specific scrutiny and recommendation of the Monitoring Committee.  A referral should not be mistaken for permission. A project still has to satisfy the applicable ESZ conditions and any separate environmental or planning requirement. Land-Use Rules Inside the Eco-Sensitive Zone Land use is one osf the areas where businesses need to be particularly careful. The notification does not allow forests, horticultural areas, agricultural areas, parks and recreational open spaces to be freely converted for: major commercial complexes,  major residential complexes, or  industrial activities.  Can Land Use Ever Be Changed? Certain changes involving agricultural or other land may be considered for the residential needs of local residents. That route is not automatic. It is linked with: recommendation of the Monitoring Committee,  prior approval of the competent authority,  applicable regional town-planning law,  other Central or State rules, and  the provisions of the ESZ notification itself.  The notification refers to local needs such as roads, civic infrastructure, non-polluting small industries, cottage industries, convenience facilities and certain eco-tourism-related local amenities.  Special Position of Tribal Land Tribal land receives additional protection. Commercial or industrial development cannot be undertaken on tribal land without the required prior approval and compliance with applicable protections referred to in the Gazette, including Article 244 of the Constitution and the Scheduled Tribes and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006.  What About Errors in Land Records? The State Government can correct an error contained in the land records if it has received the views of the Monitoring Committee. Just fixing an error doesn't amount to a change in the permitted land use. The Gazette clearly distinguishes the two. Which Activities Are Completely Prohibited? The notification places ten broad activities in the prohibited category. Activity Position Under Notification Important Detail Commercial mining, quarrying and crushing Prohibited Limited local domestic-use exception Polluting industries New units and expansion not permitted Non-polluting industries treated separately Major hydroelectric projects Prohibited No general exception stated Hazardous substances Prohibited Use, production or processing covered Untreated effluent discharge Prohibited Applies to natural water bodies and land Solid-waste disposal/incineration facilities Prohibited Includes specified treatment facilities Large commercial livestock/poultry farms Prohibited Applies to firms, corporates and companies Aerial tourism activities Prohibited Limited government conservation drone use allowed New or expanded saw mills Not permitted Applies within ESZ Brick kilns Prohibited Direct prohibition Commercial Mining, Quarrying and Crushing: Commercial mining, stone quarrying and crushing units are prohibited.     The Gazette states that this applies with immediate effect to new and existing operations, except where earth is required for the domestic needs of bona fide local residents, such as construction or repair of houses.     The provision is also correlated to Supreme Court orders mentioned in the notification.  Polluting Industries: New polluting industries cannot be set up inside the ESZ. The activity table also notes that polluting industries can't expand.      This is one of the clearest business restrictions in the Gazette. Major Hydroelectric Projects: The establishment of a major hydroelectric project is placed directly in the prohibited category. Hazardous Substances: The use, production or processing of hazardous substances is prohibited as stated in the Gazette.     Businesses dealing with chemicals, or hazardous industrial processes should therefore carry out a location check before assuming that an existing industrial approval elsewhere will be enough. Untreated Effluent: Untreated effluent cannot be discharged into natural water bodies or onto land within the ESZ. Solid-Waste Disposal and Incineration Facilities: The notification does not permit a solid-waste disposal site, or solid-waste treatment/processing facility within the ESZ.     It also prohibits common or individual incineration facilities for waste generated from specified industrial and healthcare establishments. Large Commercial Livestock and Poultry Farms: Large-scale commercial livestock and poultry farms set up by firms, corporates or companies are prohibited.     This wording should not be stretched to cover every small local dairy or household livestock activity. Local dairy and farming activities are dealt with separately under the regulated/permitted category. Aerial Tourism Activities: Commercial tourism involving hot-air balloons, helicopters, drones, microlights and similar aircraft over the protected area and ESZ is prohibited.     The notification provides a narrow exception for Forest and Wildlife Departments using drones for non-commercial conservation-awareness documentaries. Saw Mills and Brick Kilns: No new saw mill or expansion of an existing saw mill is permitted inside the ESZ.     Brick kilns are also prohibited.  Which Activities Are Regulated Instead of Banned? The regulated category is wider. These activities are not automatically prohibited, but businesses may need to follow conditions under the ESZ notification, master plans and other applicable laws. Activity Main Position Hotels and resorts Distance and Tourism Master Plan controls Construction Restricted near sanctuary, regulated elsewhere Small non-polluting industries State approval/CPCB classification Tree felling Prior permission required Forest produce/NTFP Applicable law Towers and cables Regulated, underground cabling encouraged Civic infrastructure Mitigation measures Road development Mitigation and applicable EIA Hill slopes and river banks Regulated Commercial night traffic Regulated Local farming/dairy/fisheries Permitted under applicable laws Treated wastewater Reuse encouraged, discharge regulated Surface/groundwater extraction Regulated Wells and borewells Regulated and monitored Solid-waste management Regulated Exotic species Regulated Eco-tourism Regulated Polythene bags Thickness/GSM rules apply Signboards and hoardings Regulated Small Non-Polluting Industries Small non-polluting industries may be permitted if they fall under the relevant CPCB classification and receive approval from the competent State authority. This is very different from the treatment of polluting industries. Tree Felling Trees on forest, Government, revenue or private land cannot simply be cut because the land is privately owned. Prior permission from the competent authority is required, and tree felling continues to be governed by the relevant Central and State laws. Roads and Infrastructure Road widening, strengthening and new road construction are regulated. The Gazette refers to mitigation measures and appropriate environmental impact assessment under applicable laws and guidelines. Local Agriculture and Livelihoods Ongoing agriculture and horticulture by local communities, along with dairies, dairy farming, aquaculture and fisheries, are permitted under applicable laws for local use. This provision is important because it shows that the ESZ has not been written as a blanket ban on local livelihoods. Polythene Bags The Gazette states that plastic carry bags should not be less than 120 microns, while non-woven plastic carry bags should not be less than 60 GSM. Which Activities Are Actively Promoted? A separate list identifies environmentally compatible activities that the authorities intend to encourage. These include: Rainwater harvesting- encouraged to improve local water conservation.  Organic farming- placed in the promoted category.  Green technology- adoption across activities is encouraged.  Cottage industries- village artisans and small traditional livelihoods are supported.  Renewable energy- biogas and solar lighting are specifically mentioned.  Agroforestry- promoted as a compatible land-use activity.  Horticulture and herbal plantation- encouraged.  Eco-friendly transport- listed as a promoted activity.  Skill development- included in the positive activity list.  Restoration of degraded land and habitat- actively encouraged.  Environmental awareness- also placed in the promoted category.  The notification does not say that these activities automatically receive a subsidy, tax benefit or funding support. “Promoted” here should be read as an environmental-policy classification. What Are the Rules for Hotels and Resorts? Hotel and resort developers need to pay close attention to the distance rule. The Gazette says that no new commercial hotel, or resort may be established within one kilometre from the protected-area boundary or up to the extent of the ESZ, whichever is nearer, except small temporary structures for eco-tourism activities.  This means the exact distance from the sanctuary boundary should be checked before: buying or leasing land,  preparing architectural plans,  seeking finance,  starting civil work, or  planning an expansion.  What Happens Beyond One Kilometre? Beyond the specified distance, new tourist activities or expansion of existing tourism activity must conform to the Tourism Master Plan and applicable guidelines.  What Is the Tourism Master Plan? The State Tourism Department will prepare the Tourism Master Plan in consultation with the Environment and Forest Departments. The plan will form part of the Zonal Master Plan and is to be based on the carrying capacity of the ESZ. The Gazette also refers to Central Government tourism guidelines, and the eco-tourism guidelines of the National Tiger Conservation Authority.  Until the plan is ready, tourism development is not automatically frozen, but it becomes a site specific regulatory matter involving the Monitoring Committee and relevant authority. What Are the Construction Rules? One of the biggest mistakes would be to say that “all construction is prohibited in the ESZ.” That is not what the Gazette says. New Commercial Construction: New commercial construction is not permitted within one kilometre from the protected boundary, or up to the extent of the ESZ whichever is closer. Construction by Local Residents: Local residents may undertake construction on their own land for their use, subject to applicable building bye-laws and the conditions mentioned in the notification.     This allows residential and local needs to be treated differently from large commercial development. Small Non-Polluting Industrial Construction: Construction connected with a small-scale non-polluting industry is not treated in the same way as a major commercial project.     Such construction is to be regulated, kept to the minimum and undertaken with prior permission of the competent authority under applicable rules. Construction Beyond One Kilometre: Beyond the one-kilometre distance, construction is to be regulated through the Zonal Master Plan. Hill Slopes: The rules become stricter on sensitive slopes. The Zonal Master Plan must identify hill-slope areas where construction should not be permitted, and construction on existing steep slopes, or slopes with a high degree of erosion is not allowed. What Does This Mean for Industrial Units? For industries, the first check should be classification. New Polluting Industry A new polluting industry cannot be set up within the notified ESZ after publication of the Gazette. Expansion of Existing Polluting Industry The activity table goes further and says expansion of an existing polluting industry is also not permitted. Non-Polluting Industry Non-polluting industries may be allowed under the classification contained in CPCB guidelines issued in February 2016, as amended from time to time. For small-scale units, the Gazette also refers to approval of the competent State authority. Cottage and Village Industries Cottage industries receive more favourable treatment. They appear in both the land-use provisions and the promoted-activity list. A business should still remember that ESZ permissibility is only one part of the regulatory picture. Pollution-control consents, local approvals or other licences may separately be relevant. Pollution Control and Waste Management Rules The ESZ does not replace India's existing pollution-control system. Noise Pollution Noise has to be controlled in accordance with the Noise Pollution (Regulation and Control) Rules, 2000, as amended. Air Pollution Air-pollution control continues under the Air (Prevention and Control of Pollution) Act, 1981. Effluent Treated effluent must be handled in accordance with the Water (Prevention and Control of Pollution) Act, 1974. The activity table encourages businesses to recycle and reuse treated wastewater instead of discharging it into natural water bodies. Solid Waste Solid-waste management must follow the Solid Waste Management Rules referred to in the Gazette. The notification also allows environmentally sound management of waste using recognised technologies where it complies with existing rules. Bio-Medical Waste Bio-medical waste must be managed under the relevant Bio-Medical Waste Management Rules. Plastic Waste Plastic-waste management remains subject to the Plastic Waste Management Rules referred to in the notification. Construction and Demolition Waste Construction projects must follow the applicable Construction and Demolition Waste Management Rules. E-Waste Electronic waste within the ESZ is also subject to the e-waste rules referred to by the Gazette. Businesses looking for pollution control compliance services should therefore assess the ESZ condition together with the normal pollution-control requirements applicable to their activity. How Will Environmental Clearance Work for Projects in the ESZ? This is another area where the distinction between authorities matters. The Monitoring Committee does not itself become the environmental clearance authority. For activities falling within the Schedule to S.O. 1533(E), dated 14, September 2006 the Monitoring Committee will examine the proposal based on the actual site conditions. Where applicable, the case may then be referred to the Ministry of Environment, Forest and Climate Change, or the State Environment Impact Assessment Authority for prior environmental clearance.  What About Projects Not Covered Under the EIA Schedule? Activities not covered under that Schedule, but located inside the ESZ and not prohibited, may still be scrutinised by the Monitoring Committee. The committee can then refer them to the concerned regulatory authority.  That is why an environmental clearance consultant, or environmental compliance consultant should first assess the project category rather than assuming that every ESZ project needs the same approval route. Monitoring Committee: Who Will Review ESZ Compliance? The Central Government has constituted a Monitoring Committee for implementation of the notification. Committee Member Position District Collector, Malappuram Chairman, ex officio President, District Panchayat, Malappuram Member, ex officio Environment/wildlife NGO representative Member Ecology/environment expert Member State Biodiversity Board member Member, ex officio Kerala Pollution Control Board representative Member, ex officio Divisional Forest Officer, Nilambur South Division and Wildlife Warden, Karimpuzha Wildlife Sanctuary Member Secretary, ex officio What Can the Committee Do? The committee can: examine projects on the basis of actual site conditions,  review activities covered by the EIA framework,  look at activities not covered by the EIA schedule,  refer matters to the proper regulatory authority,  invite experts or stakeholder representatives where required, and monitor implementation of the ESZ notification. Reporting, Complaints and Enforcement The Gazette gives certain officials power to initiate complaints where the notification is violated. The Member Secretary of the Monitoring Committee, concerned Collector or concerned Deputy Conservator of Forests may file a complaint under Section 19 of the Environment (Protection) Act, 1986.  The Monitoring Committee also has an annual reporting duty. Its Action Taken Report must reflect the position as on 31 March every year and must be submitted to the Chief Wildlife Warden by 30 June.  This is a committee reporting obligation. Businesses should not misread it as a new annual return that every private company in the ESZ has to file. What Do the Annexures Tell Us? The annexures are not merely supporting paperwork. They are central to identifying where the ESZ actually lies. Annexure I- Boundary Description: This contains the detailed description of the ESZ boundary using coordinate points, rivers, forest areas and neighbouring protected areas. Annexure II- Maps: The notification contains: a toposheet map,  a Google map, and  a toposheet map with geo-coordinates.  Annexure III- Coordinates: The Gazette lists the geo-coordinates of the sanctuary, and separate coordinates for ESZ Points 1 to 19.  Annexure IV- Villages: This contains the village list and corresponding GPS coordinates. Annexure V- Action Taken Report: This gives the format for annual reporting by the Monitoring Committee. For businesses, this means a project should not be classified as “inside” or “outside” the ESZ only by looking at the district name. Exact coordinates matter. What About Existing Land Use and Existing Businesses? The notification says that the Zonal Master Plan should not impose a restriction on approved existing land use, infrastructure and activities unless otherwise specified in the notification. It also asks for existing infrastructure and activities to be improved so that they become more efficient and environmentally friendly.  But this provision cannot be read on its own. If an existing activity is specifically covered by a prohibition, or regulation elsewhere in the Gazette that specific provision still matters. For example, the notification separately deals with existing polluting industries, saw mills and tourism expansion. Existing businesses should therefore carry out an environmental compliance gap assessment instead of assuming that an old approval automatically settles the ESZ position. Which Businesses Are Likely to Feel the Biggest Impact? The ESZ provisions can affect businesses in different ways, depending on their activity, and how close the project is to the sanctuary boundary. 1. Hotels and Resorts The main problem is that of location. A proposed hotel along the protected boundary may be subject to a direct restriction whereas something further away may still need to meet the requirements of the Tourism Master Plan. 2. Real Estate and Construction Developers There is strong management of commercial construction near the sanctuary. Therefore, it is important that site selection, and project design are done considering the boundary of the ESZ. 3. Industrial Units Some of the bolder restrictions are imposed on polluting industries. For non-polluting businesses, the path is different, but need to be verified with classification done by CPCB, and State-level approvals. 4. Mining and Quarrying Operators Commercial mining, quarrying and crushing operations are directly affected by the prohibition. 5. Infrastructure Developers Roads, utility networks, towers and civic infrastructure are regulated rather than simply prohibited. Mitigation and environmental assessment may be relevant. 6. Tourism Operators Tourism businesses must consider the Tourism Master Plan, site-specific scrutiny and restrictions on aerial tourism activity. 7. Waste and Healthcare Facilities Waste-disposal and incineration restrictions may be particularly relevant for operators handling solid or bio-medical waste. Business Impact Matrix Business/Project Main Issue First Compliance Check Hotel or resort Distance restriction Exact distance from protected boundary Commercial construction Restricted zone ESZ map and coordinates Polluting industry New/expanded activity restricted CPCB/activity classification Non-polluting industry Conditional approval State authority + other approvals Quarry/crusher Prohibition Whether site falls inside ESZ Tourism business Master-plan controls Tourism Master Plan Road/infrastructure project Regulated Mitigation/EIA applicability Landowner Land-use limitation Proposed land use Local cottage business More favourable treatment Applicable local laws What Benefits Can the ESZ Framework Bring? The Gazette works to exclude all damaging development from sensitive areas of land while not blocking any local economic activity. The advantages are apparent in a few aspects: Better Control of High-Impact Development: Mining, polluting industries and similar activities are dealt with much more strictly. Protection of Water Resources: Catchments, water bodies, groundwater and watershed management are built into the Zonal Master Plan requirements. Support for Low-Impact Local Activity: Organic farming, cottage industries, agroforestry and horticulture are not treated in the same way as high-impact industrial development. Greener Infrastructure and Technology: T he promoted list encourages renewable energy, rainwater harvesting, green technology and eco-friendly transport. More Structured Tourism Development: Tourism continues to be possible, but limited by planning, carrying capacity and environmental guidelines in suitable locations. What Challenges Can Businesses Face? The notification does not prescribe a single rupee amount as an ESZ compliance cost. However, businesses may face additional work and expense in several areas. Site Verification: A business may need proper coordinate-based assessment before finalising land. Project Design: If there is a distance or location restriction that conflicts with the original design of a proposed hotel, road or commercial building, a redesign of the building may be required. Multiple Regulatory Checks: A project can be acceptable under one law and still require separate environmental, pollution-control or planning approval. Extended Pre-Investment Due Diligence: Projects near to the sanctuary can benefit from a regulatory assessment before substantial financial investment is made. Restriction on Site of Industrial Location: Industrial polluting processes might need to seek alternative sites outside ESZ. These are operational implications, not fixed government fees as provided for in S.O. 4867(E). Is the Notification a Right Decision or an Additional Burden for Businesses? There are two sides to the issue. From the Environmental Side Karimpuzha Wildlife Sanctuary forms part of a connected protected landscape that includes the Nilgiris, Mukurthi National Park and Silent Valley National Park. Controlling mining, polluting industries and large commercial development near such areas has a clear conservation purpose. The framework also avoids treating every livelihood as harmful. Local agriculture, cottage industries and other low-impact activities continue to have space within the rules. From the Business Side Project planning becomes more complicated. A developer may need to check: coordinates,  distance from the sanctuary,  activity category,  master-plan status,  environmental clearance requirements, and  other State or local approvals.  That means more due diligence before money is committed. The practical effect is therefore not “business is banned.” It is closer to business being filtered by location and environmental impact. What Business Opportunities Can Come from the ESZ Framework? The promoted activities may create room for businesses working in areas such as: rainwater-harvesting systems,  solar energy,  biogas solutions,  organic farming,  agroforestry,  horticulture,  herbal cultivation,  eco-friendly mobility,  cottage and village industries,  low-impact tourism services,  pollution-control solutions,  environmental approval services, and  environmental regulatory consulting.  None of these should be described as automatically approved merely because they appear in the promoted category. What Should a Developer Check Before Starting a Project? Compliance Check Why It Matters Exact latitude/longitude of site Establishes location accurately Official ESZ boundary Determines whether site falls in notified zone Applicable ESZ distance Different directions have different widths Project activity category Identifies prohibited/regulated/promoted status One-kilometre restriction Important for hotels and construction Current Zonal Master Plan status Development is linked to it Tourism Master Plan Relevant for tourism/hospitality Monitoring Committee requirement New development may need scrutiny EIA Notification applicability Determines EC route where relevant Pollution-control requirements Separate laws may still apply Compliance Checklist for Businesses Before committing to a project, an internal compliance file can include: Location Records land coordinates,  survey/site map,  ESZ map comparison,  boundary-distance assessment.  Project Information type of activity,  capacity/scale,  construction details,  land-use proposal.  Environmental Review prohibited/regulated/promoted classification,  EIA applicability,  pollution-control requirements, waste-management obligations. Existing Approvals land-related approvals, environmental approvals, where relevant, pollution-control consents, where applicable, local authority permissions.  This is a practical due-diligence list. The ESZ notification itself does not prescribe a single universal “document list” for every business Risks of Getting ESZ Compliance Wrong Non-compliance can create both regulatory, and commercial problems. From the legal side, the notification allows designated officers to file complaints under Section 19 of the Environment (Protection) Act. The Monitoring Committee can also scrutinise projects and refer matters to the competent authorities.  From a business side, an incorrect location assessment can lead to: project delays,  redesign,  problems with approvals,  difficulty using the land for its planned purpose, or  the need to shift the project to another site.  The Gazette itself does not prescribe a separate fixed monetary penalty specifically for this ESZ notification, so one should not be invented. What Should Businesses Do Now? 1. Check the Site Before Checking the Licence Start with geography. Identify the precise location and also verify with the notified boundary. 2. Identify the Activity Category Determine whether the proposal is prohibited, regulated or promoted. This one step can change the entire project strategy. 3. Review the Distance Rule Special consideration should be given to hotels and commercial construction due to the fact that distance from the boundary of the protected area directly impacts what can be built. 4. Check the Master Plans The Zonal Master Plan position should be consulted for general development. Also, refer to the Tourism Master Plan for tourism. 5. Assess Environmental Clearance Requirements Projects falling under the EIA framework may need separate environmental clearance. 6. Assess Environmental Clearance Requirements Projects falling under the EIA framework may need separate environmental clearance. 7. Check Pollution-Control Approvals Industries, waste facilities and other projects should separately review their responsibilities under pollution-control laws. 8. Review the Project Before Spending Heavily It is far easier to change a project on paper than after land purchase, civil work or equipment investment. How Corpseed Can Help Projects located near protected areas often need more than one compliance check. The ESZ boundary, project activity, environmental clearance framework, pollution-control requirements and local approvals may all overlap. Corpseed's environmental compliance services can support businesses at the planning, approval and operational stages. 1. ESZ Location and Applicability Assessment: Corpseed can review available site coordinates against the notified ESZ boundary and help businesses understand whether the proposed location falls within the regulated zone. This is particularly useful for: hotel projects,  industrial sites,  construction developments,  tourism facilities, and  infrastructure projects. 2. Environmental Regulatory Assessment: An environmental compliance consultant can assess the proposed activity against the ESZ notification and other environmental requirements that may apply separately. The review can look at: project type,  site location,  scale,  industry category,  likely regulatory authorities, and  environmental approvals that may need further examination.  3. Environmental Clearance Support: Where an environmental clearance requirement applies, Corpseed can support the business with environmental clearance consultancy, documentation and the applicable approval process. The requirement should be checked project by project. Being inside an ESZ does not automatically mean every activity follows the same EC process. 4. Pollution Control Compliance Services: Industries and other operating projects may separately require pollution-control approvals. Corpseed can help businesses assess requirements relating to: Consent to Establish,  Consent to Operate,  air-pollution compliance,  water-pollution compliance,  waste-related permissions, and  ongoing pollution-control obligations, where these arise under applicable laws. 5. Environmental Compliance Gap Assessment: Existing businesses may benefit from an environmental compliance gap assessment, particularly where operations were established before the new ESZ notification. The review can compare current operations with applicable restrictions, approvals and environmental conditions. 6. Project Documentation Review: Corpseed can assist with reviewing relevant records such as: land and location documents,  project reports,  site maps,  existing approvals,  environmental documentation, and pollution-control records. 7. Hospitality and Tourism Compliance Support: Hotel, resort and tourism developers can use project-specific environmental regulatory consulting to check distance restrictions, Tourism Master Plan requirements and other approvals before moving ahead. 8. Infrastructure Project Compliance: Road, tower, utility and civic-infrastructure developers can also seek project-based review where mitigation measures, EIA requirements or other environmental approvals may apply. Early assessment can save a business from discovering a location restriction after substantial investment has already been made. Key Takeaways The Ministry of Environment, Forest and Climate Change issued S.O. 4867(E) on 2 September 2026 for the Karimpuzha Wildlife Sanctuary Eco-Sensitive Zone.  The Gazette states that the ESZ covers 44.24 sq. km and extends from zero to 3.40 km.  The State Government has to prepare a Zonal Master Plan within two years from Gazette publication.  Mining, new and expanded polluting industries, major hydroelectric projects, brick kilns and several other activities are prohibited.  Hotels, construction, infrastructure, non-polluting industries, roads and tourism are regulated rather than automatically banned.  Organic farming, renewable energy, rainwater harvesting, green technology and cottage industries are among the promoted activities.  New construction and other development must be referred to the Monitoring Committee until the Zonal Master Plan is prepared.  Businesses should rely on official maps, coordinates and site-level assessment before making a development decision.  The Gazette contains an apparent difference between the stated maximum ESZ extent of 3.40 km, and certain figures in the direction table, so the official boundary, and coordinates should be checked for project-level decisions.

Subject

Summary: The Commission for Air Quality Management in NCR and Adjoining Areas (CAQM) has pulled up the Haryana State Pollution Control Board (HSPCB) over continued gaps in the monitoring of construction and demolition sites. A review meeting was organized on 8 September 2026 following the observations made by CAQM in terms of malfunctioning links between web-cameras installed at the registered C&D facilities. The Commission had been using HSPCB's portal for sample-based remote checks and found problems ranging from incorrect login details to offline cameras and links that did not open as expected.  The issue matters to builders and project owners because the Statutory Directions referred to in the release cover C&D projects with a plot area of 500 sq. metres or more. Such projects are required to be registered and have functional video-monitoring arrangements so that dust-control measures can be checked remotely. The September development does not create a fresh C&D monitoring regime. It is mainly about whether the existing system is actually being implemented and enforced. Notification at a Glance Particular Details Authority raising the issue Commission for Air Quality Management in NCR and Adjoining Areas State authority reviewed Haryana State Pollution Control Board Development Review of compliance with CAQM Statutory Directions Review meeting 8 September 2026 PIB release 9 September 2026 Sector Construction and demolition Main threshold mentioned Plot area of 500 sq. metres or more Main requirement referred to Registration and functional video monitoring Monitoring method Remote monitoring through the State/GNCTD web portal Monitoring period discussed 19 June 2026 to 22 June 2026 Observations communicated 8 July 2026 Main problem found Web-camera links at most sites were non-functional Enforcement direction Stronger monitoring, corrective action and enforcement Possible action Closure of non-compliant sites New effective date Not separately specified New compliance deadline Not separately specified The focus of the release is therefore not on adding another layer of paperwork. CAQM's concern is whether the monitoring arrangement that already exists can actually be used for checking dust-control measures at C&D sites.  What Is the Regulatory Framework Behind C&D Site Monitoring? CAQM is responsible for coordinating and directing measures for the prevention and control of air pollution in the National Capital Region and adjoining areas. Construction activity comes under regulatory attention because dust generated from excavation, demolition, movement of materials, and other site activities can contribute to local air-pollution levels when prescribed controls are not followed. For the present update, the most relevant point is what the PIB release itself says: CAQM's Statutory Directions mandate registration of C&D projects with a plot area of 500 sq. metres or above, along with the installation of functional video-monitoring systems through the relevant State/GNCTD web portal.  The portal allows authorities to view sites remotely and check whether prescribed dust-mitigation measures are being implemented. The release does not state the number of each underlying CAQM direction. It is therefore safer to describe the September action as an enforcement and implementation review of existing directions, rather than presenting it as a newly introduced rule. Why Did CAQM Call HSPCB for a Review Meeting? The review meeting followed repeated monitoring problems rather than a single technical failure. As per CAQM, sample-based remote monitoring was being done using the HSPCB website portal from 2024. However, during the sample checking process, it was observed that there were some recurring problems related t o web-camera access. The problems were communicated to HSPCB from time to time for corrective action. CAQM had also advised the Board to deploy a dedicated team so that remote monitoring through the portal could be managed more effectively. According to the release, a dedicated team had not been deployed, and substantial improvement was not seen. CAQM therefore called HSPCB for the 8 September review and sought information on the compliance position, action taken, and notices already issued.  So, this was not merely a routine coordination meeting. It came after earlier deficiencies had continued. What CAQM Directions Apply to Construction and Demolition Projects? The press release points to two basic requirements for the C&D projects covered by the relevant directions: registration of the project and availability of a functional video-monitoring system. Registration of Covered C&D Projects The threshold mentioned in the release is straightforward: C&D projects having a plot area of 500 sq. metres or more. The wording matters. The document speaks about plot area. It should not automatically be rewritten as built-up area, carpet area, floor area, or total construction area. Functional Video Monitoring For covered projects, merely installing a camera does not appear to satisfy the purpose of the monitoring framework if that camera cannot be accessed remotely. A monitoring arrangement may fail in practice when: the camera link does not open,  login credentials are wrong,  the feed remains offline,  the URL is incomplete, or  access requires steps that prevent normal remote monitoring.  Connection With the Web Portal The release refers to functional video-monitoring systems made available through the relevant State/GNCTD web portal. This allows authorities to remotely check whether dust-mitigation measures are being followed at the site.  The PIB release does not prescribe camera models, storage periods, image quality, internet speed, or technical placement standards. Those details should not be added unless they are separately supported by an applicable official direction. Which Construction and Demolition Projects Are Covered? The clearest applicability point in the release is the 500 sq. metre plot-area threshold. Project Category Position From the Release Directly relevant to HSPCB monitoring C&D project with plot area of 500 sq. metres or more Covered by the requirement referred to by CAQM Registration and functional video monitoring are relevant Project below 500 sq. metres Same monitoring requirement not established by this release Other environmental rules may still apply separately Registered Haryana C&D sites Directly relevant to HSPCB monitoring Camera access and dust-control monitoring need attention A small contractor working on a large project should also avoid confusing the threshold with the contractor's own business size. The criterion mentioned by CAQM relates to the project's plot area, not whether the contractor is an MSME or a large company. How Does CAQM Remotely Monitor C&D Sites? The monitoring system is intended to give authorities a way to check site conditions without physically visiting every project each time. In simple terms, the process referred to in the release works like this: Covered C&D projects are registered.  Relevant video-monitoring links are connected to the portal.  Authorities open those links during remote checks.  The camera feed is used to view the site.  The feed supports checking prescribed dust-mitigation measures.  CAQM says sample-based monitoring through the HSPCB portal has been carried out since 2024.  That makes continuous functionality important. A camera link that worked when first submitted may later become unusable because of a password change, technical failure, network issue, or an offline camera. What Problems Did CAQM Find During Remote Monitoring? The deficiencies reported by CAQM were not all of the same type. Some were concerned with access, some were related to incorrect credentials, while others involved camera availability itself. Incomplete or Insufficient Web-Camera Links Some links did not provide adequate access for remote monitoring. From a compliance point of view, a portal entry is of limited use if the regulator cannot reach the relevant camera feed through it. Incorrect User ID or Password CAQM also found incorrect login credentials. A camera may be running at the project site, but the monitoring system still fails if the authority cannot access it using the credentials provided. Links Prompting Mobile-App Installation Certain links reportedly asked users to install a mobile application. The release identifies this as one of the discrepancies. It does not, however, state that the use of mobile applications is prohibited in every circumstance. The problem should therefore be explained as an access issue observed during monitoring, rather than turned into a wider legal prohibition. Non-Working Web Links A number of web links were found to be non-functional. This is important because simply uploading or registering a URL does not provide meaningful monitoring when the link itself cannot be used. Cameras Remaining Offline After Login In some cases, CAQM was reportedly able to log in but still found that the cameras were offline. That makes the distinction between having access details and having an operational monitoring system especially important.  What Did CAQM Find During the June 2026 Monitoring Exercise? One of the more important parts of the release is the monitoring exercise conducted from 19 June 2026 to 22 June 2026. CAQM checked registered active C&D sites through the HSPCB portal across Panipat, Sonipat, Faridabad, Gurugram (North) and Gurugram (South). The Commission reported that web-camera links at most of these sites were non-functional. The findings were communicated to HSPCB on 8 July 2026.  The figures in the release should be read as data relating to the active registered sites referred to in this monitoring exercise. They should not be presented as the total number of every construction project operating in Haryana. District-Wise Status of C&D Sites and Web-Camera Links Area Active C&D Sites Mentioned Functional Links Specifically Reported Panipat 213 Not separately stated Sonipat 457 Not separately stated Faridabad 168 4 Gurugram (North) 691 6 Gurugram (South) 484 5 The release specifically records functional links at 4 sites in Faridabad, 6 sites in Gurugram (North), and 5 sites in Gurugram (South).  It does not separately provide a number of functional links for Panipat and Sonipat. For that reason, it would be inaccurate to write “zero functional cameras” for those two locations unless another official record confirms it. The wider finding is clear enough without making that assumption: CAQM said the links on most sites were non-functional. Why Are Functional Web Cameras Important for Dust-Control Compliance? The cameras are not meant to exist only as an entry in a compliance file. Their purpose is to make remote checking possible. A working system can allow an authority to see whether the site is accessible for monitoring and whether dust-control measures can be observed through the feed. From a regulatory perspective, this helps in several ways: Remote verification: Authorities do not have to depend only on physical inspections.  Identification of gaps: Broken or unavailable feeds can be noticed during routine checks.  Follow-up: Sites showing monitoring deficiencies can be examined more closely.  Better oversight: Regulators can compare portal information with what is actually visible at the project site.  A camera cannot prove complete environmental compliance on its own. It is simply one monitoring tool. CAQM's concern was that when the links do not work, the basic purpose of the web portal, remote monitoring and verification of dust-control measures, is weakened.  Why Did CAQM Treat the Continued Non-Compliance Seriously? The seriousness of the matter comes from the fact that the deficiencies were not being reported for the first time. CAQM had already communicated the monitoring problems and had advised HSPCB to strengthen its system. The Commission also recommended the deployment of a dedicated team for portal-based monitoring. The release states that neither the dedicated team was deployed nor was substantial improvement observed. Against this background, CAQM treated the continued discrepancies and non-compliance as wilful non-compliance on the part of the designated authority responsible for enforcement of its directions.  That wording needs to be handled carefully. It does not mean that CAQM declared every builder, contractor or project owner in Haryana to be in wilful non-compliance. The observation in the release is directed at the enforcement and implementation position of the designated authority. Individual C&D sites may still face action where they themselves do not comply with applicable requirements, but those are separate questions. What Directions Has CAQM Now Given to HSPCB? After reviewing the position, CAQM directed HSPCB to ensure strict compliance with the Commission's Orders and Statutory Directions. The Board was asked to take corrective steps so that the monitoring system works properly and enforcement improves at the site level. The main directions arising from the meeting include: ensuring strict compliance with applicable CAQM Orders and Statutory Directions,  taking corrective measures against deficiencies,  keeping remote monitoring of C&D sites effective and uninterrupted,  strengthening the overall monitoring mechanism,  improving enforcement on the ground,  ensuring prescribed dust-mitigation measures are actually followed, and  taking action against non-compliant C&D sites.  The Commission also indicated that corrective measures may include closure of non-compliant sites.  No fresh universal deadline is stated in the PIB release. Can Non-Compliant C&D Sites Face Closure? Yes. Closure is expressly mentioned in the PIB release as one of the corrective measures that may be taken against non-compliant sites.  That statement should not be exaggerated into a blanket closure order. CAQM has not said in this release that: every registered C&D site in Haryana will be closed,  every broken camera link automatically results in closure,  all monitored sites have already received closure orders, or  projects have been given a common shutdown deadline.  The position is narrower. HSPCB has been asked to strengthen enforcement and take necessary corrective measures, including closure where sites are found non-compliant. No new monetary penalty, fixed closure period, or automatic prosecution mechanism is stated in this particular PIB release. What Does This Mean for Builders, Developers and C&D Project Operators? For businesses, the most practical message is simple: paper compliance and working compliance are not always the same thing. A project may be registered and may even have cameras installed. That does not solve the problem if the regulator cannot access those cameras when monitoring takes place. Builders and Developers Builders responsible for covered C&D projects should verify whether the monitoring arrangement remains functional after it is set up. The review should not stop at asking whether cameras have been installed. The real question is whether the feed can be opened remotely. Project Owners Project owners should know: whether registration is applicable,  whether the registration is in place,  whether camera links remain active,  whether credentials work, and  whether dust-control measures visible at site are being maintained.  EPC and Construction Contractors Where contractors manage day-to-day site operations, they may be involved in maintaining dust controls or monitoring infrastructure. The exact legal responsibility of each contractor depends on the contractual arrangement and applicable regulatory requirement. It should not automatically be assumed merely from this PIB release. Environmental and Compliance Teams Environmental teams should pay particular attention to operational gaps. A broken link may appear to be an IT issue, but if that link forms part of a regulatory monitoring system, it can become a compliance concern as well. MSME Contractors Smaller contractors working on larger projects should not interpret the 500 sq. metre threshold as an MSME exemption. The threshold mentioned in the release relates to the project plot area. C&D Site Remote-Monitoring Compliance Checklist The following checklist combines the source-based concerns with practical internal controls. Compliance Area What Should Be Checked Nature Applicability Whether the project falls within the relevant CAQM requirement Regulatory review Plot area Confirm whether the 500 sq. metre threshold is met Source-based Registration Check registration where required Source-based Camera installation Confirm required video-monitoring arrangement exists Source-based Camera functionality Check whether cameras are actually operating Source-based concern Web link Open each regulator-facing link and verify access Source-based concern Credentials Test User ID/password details Source-based concern Camera status Check whether feed shows online rather than offline Source-based concern Dust measures Review actual implementation at the site Source-based compliance area Internal ownership Assign responsibility for periodic monitoring checks Recommended control Rectification record Keep a record when technical problems are corrected Recommended control Compliance review Periodically check wider environmental obligations Recommended control An internal control marked as “recommended” should not be presented as a separate legal requirement created through the September press release. What Are the Risks of Weak C&D Site Monitoring Compliance? There are two different kinds of risk here: regulatory risk that is expressly supported by the release, and practical business risk that may follow from poor compliance. Regulatory and Enforcement Risks The clearest regulatory concern is stronger enforcement. CAQM has instructed the concerned authorities to improve monitoring and take corrective action. The release specifically refers to the closure of non-compliant sites.  The document does not set out a new fine or environmental-compensation amount, so no such figure should be attached to this update without a separate legal basis. Practical Business Risks Weak monitoring can also create operational problems, such as: urgent technical rectification,  greater regulatory attention,  difficulty demonstrating that remote monitoring is functional,  time spent responding to notices or compliance queries,  disruption if enforcement action is taken, and  coordination problems between site, IT and environmental teams.  These are practical consequences, not automatic statutory penalties. Why Is CAQM Strengthening Dust-Control Enforcement in NCR? CAQM has linked effective implementation of its directions with the broader objective of preventing and controlling air pollution in the National Capital Region. Construction-site monitoring only works when two things happen together: the monitoring system remains operational, and  prescribed dust-mitigation measures are actually implemented at the site.  A portal filled with registered projects cannot serve its intended purpose if regulators cannot access the cameras attached to those projects. For this reason, CAQM has asked agencies to strengthen both monitoring and on-ground enforcement rather than treating portal registration as the end of the compliance process.  Is Stronger Remote Monitoring the Right Approach or an Additional Burden? Stronger remote monitoring can improve regulatory oversight, but it also places an ongoing operational responsibility on project teams. Where Stronger Monitoring Helps A functional remote-monitoring system can make it easier to: identify unavailable feeds quickly,  check sites without waiting for a physical visit,  focus inspections on locations showing possible gaps,  maintain more regular regulatory visibility, and  verify whether dust-control arrangements can actually be seen at the site.  From an enforcement point of view, that makes the monitoring system more useful than relying only on one-time documentation. Where Businesses May Feel the Burden Project operators may have to deal with regularly: camera downtime,  internet or network interruptions,  changed login credentials,  broken portal links,  hardware maintenance,  coordination with IT teams, and  quick rectification when a problem is detected.  For businesses with limited compliance staff, these tasks can add another layer of site management. Even then, the September review suggests that the regulator's concern is not simply whether equipment has been purchased. The emphasis is on whether the entire arrangement remains usable. What Should C&D Project Operators Do Next? Businesses do not need to wait for a regulatory query before checking their own systems. Step 1: Check Whether the Project Is Covered Confirm the plot area and assess whether the relevant CAQM monitoring requirement applies. Step 2: Verify Registration Where registration is required, check whether the project is properly reflected on the relevant portal. Step 3: Open the Camera Link From Outside the Site A local camera display is not enough. Test whether the actual remote link can be accessed. Step 4: Recheck Login Credentials Ensure that the User ID and password provided for monitoring purposes are up-to-date. Step 5: Look for Offline Cameras A working login does not help if the camera itself remains offline. Step 6: Review Dust-Control Measures The monitoring system should reflect actual environmental compliance on the ground. Project teams should therefore review the prescribed dust-mitigation measures rather than focusing only on camera connectivity. Step 7: Rectify Technical Problems Quickly Broken links, incorrect credentials, and offline feeds should be corrected once detected instead of being allowed to remain unresolved. Step 8: Create Clear Internal Responsibility The site team should know who is responsible for checking the monitoring system. This is a practical control rather than a new duty created by the PIB release. Step 9: Review Regulatory Communications Carefully If CAQM, HSPCB or another authority sends a notice or seeks information, the business should compare that communication with the actual site position and the applicable direction before responding. Where the issue is unclear, taking support from an environmental compliance consultant may help the business organise the facts and supporting records before filing a response. Will CAQM Continue Monitoring C&D Site Compliance? Yes. The Commission has expressly stated that it will continue to closely monitor compliance and take necessary measures for effective mitigation of air pollution in the region.  For project operators, this is a reason to treat camera functionality as an ongoing compliance matter. A system that worked six months ago may not work today. Passwords change, hardware fails, and internet links become unavailable. Regular internal checks can therefore be useful even though the PIB release does not prescribe a new inspection frequency or periodic testing schedule for businesses. How Can Corpseed Help With C&D and Environmental Compliance? Environmental compliance at a construction project often involves more than obtaining a document and keeping it in a file. Actual site conditions, applicable pollution-control requirements, records, and monitoring arrangements also need attention. Corpseed's environmental compliance services can support builders, developers, and project operators who need help reviewing applicable requirements and identifying compliance gaps. 1. Applicability Assessment Corpseed can assist corporations in evaluating the relevance of various environmental and pollution control standards to an intended or existing construction project. The assessment may consider factors such as: project activity,  location,  scale,  plot area, and  applicable regulatory framework.  2. Environmental Compliance Gap Assessment A compliance gap assessment can help identify the difference between what a project is expected to maintain and what is actually happening at the site. The review may cover documentation, operational controls, and supporting compliance records, depending on the scope of work. 3. Construction Environmental Compliance Support Projects dealing with construction and demolition activities can seek construction environmental compliance services for assistance with applicable regulatory requirements and documentation. The service should be matched to the actual requirement instead of adding licences or approvals that do not apply to the project. 4. Pollution Control Compliance Services Corpseed can assist businesses with relevant pollution control compliance services, including support around applicable environmental approvals, regulatory documentation and compliance requirements where required. 5. Documentation and Record Review Regulatory problems are harder to manage when records are scattered across site, legal, environmental and administrative teams. Corpseed can support businesses in organising relevant documents and checking whether supporting information is available for compliance review. 6. Compliance Notice Support  Whenever the project has been communicated by the pollution control authority, the very first thing is to know exactly what was asked for. Corpseed can help in: reviewing the regulatory communication,  identifying documents needed for response,  organising factual information,  checking the applicable compliance position, and  preparing supporting documentation.  7. Ongoing Environmental Compliance Support Businesses that manage multiple sites may also require regular environmental regulatory compliance services rather than addressing each issue only after a notice is received. The objective of continuous support is to detect deficiencies as early as possible and maintain compliance duties in an organized manner. This will not provide approval nor prevent any authority from acting on the non-compliance.

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Summary: The Central Pollution Control Board ( CPCB ) has released draft guidelines for managing Category III multilayered plastic packaging waste, or MLP waste. Issued in September 2026, the document is currently open for public consultation, which means it is still a draft and should not be treated as a final or legally effective guideline yet. The draft looks at what should happen to Category III packaging after it becomes waste. It covers collection, segregation, Material Recovery Facilities, transportation, recycling, aluminium and paper recovery, end-of-life treatment, quality testing and monitoring through the Extended Producer Responsibility framework. CPCB has also discussed how newer recycling technologies may be evaluated and how packaging design itself could become easier to recycle in the future.  For Producers, Importers and Brand Owners, Plastic Waste Processors , packaging companies and recyclers, the document gives a clear indication of the direction CPCB is considering for difficult-to-process multilayer packaging. CPCB Draft Guidelines at a Glance Particular Details Document Guidelines on the Environmentally Sound Management of Category III Multilayered Plastic Packaging Waste Authority Central Pollution Control Board Ministry Ministry of Environment, Forest and Climate Change Status For Public Consultation Date September 2026 Main subject Management of Category III MLP waste Packaging category covered Category III Existing framework referred PWM Rules, 2016, EPR Guidelines and SWM Rules, 2026 Main stakeholders PIBOs, PWPs, ULBs, SPCBs/PCCs, CPCB and waste generators Main subjects Collection, segregation, recycling, EOL, testing, EPR monitoring and technology evaluation Effective date of this consultation draft Not expressly specified Separate compliance deadline Not expressly specified The draft is meant to provide technical and operational guidance across the complete Category III waste-management chain rather than dealing only with final disposal.  Why Has CPCB Proposed New Guidelines for Category III Multilayered Plastic Packaging Waste? The story behind these guidelines begins with proceedings before the National Green Tribunal. According to the CPCB document, an NGT order dated 12 November 2025 directed CPCB to explore whether common guidelines could be prepared for multilayered plastic packaging waste . A later order dated 9 February 2026 referred to the need to examine solutions for separating plastic and aluminium layers or finding suitable alternatives. CPCB filed a status report on 15 April 2026, and the matter was subsequently heard on 16 April 2026.  There was already an older CPCB framework. In 2018, CPCB had issued guidelines dealing with disposal of the non-recyclable fraction of multilayered plastic waste. A lot has changed since then. The draft itself points to: amendments made to the Plastic Waste Management Rules,  introduction of EPR Guidelines for Plastic Packaging,  the Solid Waste Management Rules, 2026,  development of newer recycling technologies,  practical experience gained from implementation.  CPCB therefore considers it necessary to update the approach to Category III waste so that recovery, recycling, traceability and final processing are looked at together.  Regulatory Framework for Category III Multilayered Plastic Packaging Waste The September 2026 draft does not operate in isolation. It sits alongside rules and EPR requirements that already govern plastic packaging. Plastic Waste Management Rules, 2016 The Plastic Waste Management Rules, 2016 form the basic legal framework. Among other things, the rules deal with segregation, handling and management of plastic waste and assign responsibilities to different entities involved in the waste chain.  For EPR purposes, the draft refers to producers, importers, brand owners, Plastic Waste Processors, manufacturers and importers of plastic raw material and certain manufacturers of compostable or biodegradable plastic items. The source also records specific exclusions for micro and small enterprises in particular producer and brand-owner categories, so applicability should always be checked against the actual entity and activity.  EPR Guidelines for Plastic Packaging The EPR Guidelines for Plastic Packaging were published on 16 February 2022 under the PWM framework. EPR links the quantity and category of plastic packaging placed on the market with corresponding obligations for collection, recycling or other permitted processing. PIBOs can use mechanisms such as: collection points,  Material Recovery Facilities,  deposit-refund systems,  buy-back arrangements,  other collection networks.  The waste eventually needs to reach an appropriate registered or authorised processing route.  Solid Waste Management Rules, 2026 The draft also relies heavily on source segregation. Under the Solid Waste Management framework referred to by CPCB, plastic waste forms part of the dry waste stream. Separate handling at the point of generation makes secondary segregation and recycling easier later.  Earlier CPCB Guidelines CPCB's 2018 guidance focused more heavily on managing non-recyclable MLP fractions. The 2026 consultation draft takes the discussion further. Instead of looking only at disposal, it explores how different components of multilayer packaging can be recovered before the remaining fraction is sent to an authorised end-of-life route. What Is Category III Multilayered Plastic Packaging? This is one of the most important points for businesses. For the draft, Category III MLP means multilayer packaging containing at least one plastic layer and at least one layer made from a material other than plastic. The non-plastic layer may be made from material such as: aluminium foil,  paper,  paperboard,  another qualifying non-plastic barrier material.  CPCB expressly states that multilayer packaging made entirely from different types of plastic belongs to Category II and is outside the scope of these Category III guidelines.  In practice, the packaging structure matters more than how the pack looks from the outside. Category II vs Category III Multilayered Plastic Packaging The distinction can be especially important for companies selling food, pharmaceutical, beverage, cosmetics and FMCG products. Point Category II Category III Basic structure Flexible plastic packaging, including multilayer plastic structures Plastic combined with at least one non-plastic layer Non-plastic layer required No Yes Possible construction BOPP/PE or other all-plastic multilayer structure Plastic + aluminium, plastic + paper, paperboard + plastic + foil Covered by September 2026 draft No Yes Relevant EPR category Category II Category III Main processing consideration Polymer compatibility Separation/recovery of plastic and non-plastic components For example, CPCB says multilayer PE milk or oil pouches that do not contain a non-plastic layer remain Category II. By comparison, qualifying aseptic cartons containing paperboard, plastic and aluminium fall under Category III.  Which Packaging Products May Fall Under Category III? CPCB gives several examples of waste streams that may fall within Category III, subject to their actual material construction. These include: Foil-Based Food and Confectionery Packaging Some biscuit wrappers and confectionery packs contain plastic together with aluminium foil. Where the material structure meets the Category III definition, the packaging may be considered for: material separation,  delamination,  aluminium recovery,  authorised EOL treatment where recovery is not suitable.  Foil-Based Sachets and Pouches These may combine PET or another plastic with aluminium foil or another non-plastic layer. Small sachets are difficult to collect because they are light and dispersed. Aggregation therefore becomes particularly important. Aseptic Cartons Paperboard-based cartons containing plastic and aluminium are treated as Category III. The draft discusses hydropulping to recover paper fibre, followed by treatment or recovery of the remaining PolyAl fraction. Laminated Tubes Qualifying aluminium-barrier or other plastic/non-plastic laminated tubes may be sent for material recovery, aluminium recovery, composite product manufacture or authorised processing. Pharmaceutical Strip Packs and Lidding Foils Pharmaceutical packaging containing plastic together with aluminium foil is another stream specifically discussed by CPCB. Post-Industrial Converter Waste Trims, rejects and skeleton waste generated during packaging conversion can also fall under Category III where plastic is combined with non-plastic material. Post-industrial waste may be easier to process because its composition is often known and it is normally cleaner than post-consumer packaging.  Who Will Be Affected by the CPCB Draft Guidelines? The proposed system spreads responsibility across the waste chain. Producers, Importers and Brand Owners PIBOs have a direct connection with EPR because they introduce plastic packaging into the market. Their role can involve: correct packaging categorisation,  EPR reporting,  supporting collection,  working with registered processors,  maintaining waste movement records,  fulfilling applicable EPR obligations.  The existing PWM and EPR framework already contains duties in this area. The consultation draft adds more technical detail around Category III collection and recovery.  Plastic Waste Processors PWPs are the facilities that actually recycle or process the collected plastic waste. Their work can include: recycling,  material recovery,  EOL processing,  uploading processing data,  maintaining mass balance,  generating eligible EPR certificates under the applicable framework.  Urban Local Bodies ULBs are an important link between households, commercial generators and recycling facilities. The draft discusses responsibilities connected with: source segregation,  dry waste collection,  MRF operation,  transportation,  record maintenance,  integration of waste pickers,  linkage with registered processors.  SPCBs and PCCs State Pollution Control Boards and Pollution Control Committees are concerned with registration, monitoring and environmental enforcement. The draft discusses verification of: processor capacity,  processing records,  material inputs,  recovered outputs,  rejects,  residues,  mass balance,  EPR Portal data,  environmental safeguards.  Waste Pickers and Aggregators This group matters because individual MLP packs have little value and are scattered across large areas. Aggregators, waste picker organisations, cooperatives and SHGs can bring together small quantities until there is enough material for economical transport to a processing facility.  Stakeholder Responsibilities at a Glance Stakeholder Main Responsibility MoEF&CC Policy, rules and amendments CPCB Guidelines, EPR Portal, monitoring and technology evaluation SPCBs/PCCs Registration, inspections, authorisation and enforcement ULBs Collection, segregation, MRF operation and transportation PIBOs Collection support and fulfilment of EPR obligations PWPs Recycling/processing and eligible EPR certificate generation Waste generators Segregating waste and handing it over through the proper system CPCB itself presents MLP management as a shared system where each stakeholder has a different function.  What Do the CPCB Draft Guidelines Propose? Rather than treating MLP waste as a single mixed material, the proposed approach begins by asking what can actually be recovered from it. The main areas covered are: source segregation,  organised collection,  secondary sorting,  MRF-based aggregation,  channelisation to registered facilities,  polymer recovery,  paper recovery,  aluminium recovery,  mechanical recycling,  advanced recycling,  authorised EOL processing,  testing of recycled material,  digital EPR monitoring,  evaluation of new technology,  better packaging design.  The practical message is simple: recyclable material should be recovered first, and only the fraction that cannot reasonably be recovered should move towards an authorised end-of-life route. Current Category III MLP Processing Infrastructure in India CPCB's draft gives specific processing data as of 25 June 2026. Particular Capacity/Number Registered Category III PWPs 615 Registered recyclers 440 Authorised EOL processors 175 Total authorised processing capacity 63,35,379 TPA Recycling capacity 10,04,392 TPA EOL processing capacity 53,30,987 TPA According to the draft, this registered infrastructure shows that there is already substantial capacity for recycling and EOL processing of Category III waste in India. CPCB also links this infrastructure with its central EPR Portal for monitoring and traceability.  These figures describe registered infrastructure. They should not be treated as estimates of market value, revenue or actual annual waste generation. How Should Category III MLP Waste Be Collected and Channelised? A recycling system cannot work properly if the material never reaches the recycler. CPCB therefore spends considerable space on collection. The basic flow is: Waste generation → Source segregation → Collection → MRF/aggregation → Secondary sorting → Registered recycler or authorised EOL processor Step 1: Source Segregation MLP waste should first be separated as part of the dry recyclable waste stream. Keeping food waste, wet waste and other contaminants away from MLP can improve the quality of the material reaching the recycler. Step 2: Collection Depending on the location, waste can move through: door-to-door collection,  Dry Waste Collection Centres,  Material Recovery Facilities,  buy-back centres,  deposit-refund systems,  reverse logistics,  collection drives,  SHGs,  waste pickers,  authorised collection agencies.  The draft does not assume that one collection method will work everywhere.  Step 3: Aggregation and Secondary Segregation At a MRF or aggregation point, the material can be sorted further. The draft suggests broad segregation into: recyclable MLP,  paper-based MLP,  foil-based MLP,  contaminated/non-recyclable fractions.  Step 4: Channelisation The processing route should then depend on the material. For instance: Recyclable MLP waste can be sent to a registered recycler. Paper-based aseptic packaging may go through hydropulping or another suitable recovery process. Foil-based laminates can be treated through delamination or aluminium recovery. Non-recyclable MLP waste should be sent to an authorised End-of-Life (EOL) facility.  Collection Models for MLP Waste Different areas will need different collection systems. Collection Model Suitable Setting Lead Entity Door-to-door collection Urban ULB MRF-based collection Urban ULB DWCC Urban/semi-urban ULB Deposit-refund/buy-back Urban and semi-urban PIBO Plastic banks/collection drives Rural and urban PIBO/ULB Waste-picker/SHG-led collection Rural and urban ULB/Panchayat Cluster-based MRF Smaller ULBs/rural areas ULB/Panchayat/PIBO Mobile collection Rural ULB/Panchayat/PIBO For smaller towns and rural locations, setting up a separate recycling facility in every local area may not be economically sensible. CPCB therefore discusses cluster systems where material from adjoining areas is collected, aggregated and transported together.  Role of PIBOs in Collection and Channelisation PIBOs can become more involved in the physical collection side of EPR. The draft says they may support: collection points,  aggregation centres,  MRFs,  storage,  baling infrastructure,  transportation,  buy-back arrangements,  other incentive-linked collection methods.  They may also work with: ULBs,  Gram Panchayats,  aggregators,  waste picker organisations,  SHGs,  NGOs,  authorised agencies.  The draft separately refers to keeping records of collection, transport, weighment, transfer and receipt by the processing facility.  Documents and Traceability Records for Category III MLP Waste For EPR compliance , physical waste and paperwork need to tell the same story. The proposed traceability framework covers the complete movement from waste generation to final processing. Record What It Shows Quantity collected Actual waste volume Source details Where material came from MRF/aggregation record Intermediate handling Transport details How and when material moved PWP details Where it was sent PWP registration number Whether the processor is registered Processing route Recycling or EOL Final utilisation What happened after processing GST invoice, where applicable Evidence of transfer E-way bill, where applicable Transport movement Delivery challan Delivery record Weighbridge slip Weight evidence Processing/output record Material actually recovered Mass-balance record Relationship between input, output and residue The draft says relevant tax invoices and transport records should support actual movement of MLP waste and help verify quantities reported under EPR.  This is particularly important where businesses purchase or use EPR certificates . Data that exists only on the portal, without supporting physical records, can create compliance risk. Which Recycling Technology Is Suitable for Category III MLP Waste? The answer depends on what the packaging contains. A plastic-paper pack cannot automatically be treated in the same way as plastic-aluminium foil. Even two foil laminates may need different processes if their polymers and adhesives are different. The draft says technology selection should consider: material composition,  waste quality,  level of contamination,  degree of segregation,  available proven recycling technology,  environmental performance,  recovery efficiency,  quality of the recovered product,  marketability,  economic viability.  Where material recycling is technically workable, CPCB gives it priority over final disposal.  Recycling Technology Comparison Technology Suitable Waste Main Output Main Issue to Check Mechanical recycling Cleaner, compatible polymer waste Recycled plastic Polymer quality Hydropulping Paper-based/aseptic packaging Paper fibre + PolyAl PolyAl management Physical separation Liberated aluminium-plastic fraction Aluminium + plastic Proper liberation Delamination Complex laminates Separate material layers Chemical/solvent management Chemical recycling Hard-to-mechanically-recycle plastic Oil/monomer/feedstock Emissions and residue EOL processing Non-recyclable residue Energy/resource recovery Authorised facility Mechanical Recycling of MLP Waste Mechanical recycling is the most established technology discussed in the draft for suitable waste. The process does not chemically break the polymer into new molecules. Instead, it cleans, reduces, mixes and reprocesses the plastic into a usable form. Stage 1: Collection and Baling Loose flexible plastic is extremely light. The draft refers to a loose bulk density of around 20-40 kg/m³ and discusses hydraulic bales in the 50-500 kg range. Baling makes the material easier and cheaper to transport.  Stage 2: Sorting The incoming material is sorted to remove: paper,  textile,  metal,  PVC,  incompatible plastics,  other contaminants.  Advanced plants may also use Near-Infrared sorting systems. Stage 3: Shredding Sorted MLP is cut into smaller flakes. The draft refers to: roughly 20-50 mm flakes after shredding,  further size reduction below 10 mm where needed.  Stage 4: Washing and Drying Not every material needs washing. Clean industrial MLP may move directly towards densification after dust removal. Contaminated post-consumer packaging may need washing. Where washed, the draft refers to drying flakes to below 3% moisture before extrusion.  Stage 5: Agglomeration Thin flakes do not feed easily into an extruder. Agglomeration turns them into denser material that can be processed more consistently. Stage 6: Extrusion and Pelletisation The final stage can include: melt filtration,  removal of contaminants,  degassing,  additive dosing,  pellet formation.  The output is recycled MLP granulate that may be used in suitable non-food-contact applications.  Advanced Recycling Technologies for Category III MLP Some packaging structures are too mixed or contaminated for straightforward mechanical recycling. For those streams, CPCB discusses more specialised technologies. Pyrolysis Pyrolysis heats suitable plastic-rich waste without oxygen. Possible outputs include: pyrolysis oil,  combustible gas,  char.  Where aluminium foil is present, some of it can remain in the solid residue and may later be recovered. Solvent-Based Dissolution This process uses a suitable solvent to dissolve a polymer layer selectively. The dissolved polymer is then recovered and purified, while other materials such as paper or aluminium may remain separated. Depolymerisation Certain polymers, particularly PET-based layers, may be chemically broken into smaller molecular components that can be used again as feedstock. Gasification Gasification partially oxidises waste at high temperature to produce synthesis gas. The draft stresses that such technologies need appropriate environmental controls, residue management and documented mass balance.  How Can Aluminium Be Recovered from Foil-Based MLP? Foil packaging contains a valuable material that does not necessarily need to be lost during disposal. The draft discusses several recovery routes. Eddy Current Separation Eddy Current Separation is a physical method used to separate conductive aluminium from non-conductive material. There is one important condition: the aluminium should first be released from the plastic or paper laminate. Pre-treatment may involve delamination, solvent dissolution, pyrolysis or hydropulping to free the aluminium from the other packaging layers. For properly separated foil, CPCB’s draft indicates 80-95% recovery and 90-98% aluminium purity under optimised conditions. Actual results will depend on the material and operating conditions, so these figures are not guaranteed for every facility. Electrostatic Separation Another option discussed is electrostatic separation. The broad process involves: crushing,  fine grinding,  particle screening,  aluminium liberation,  high-voltage separation based on electrical conductivity.  The draft describes recovery of about 99% and product purity above 97% under optimised conditions for the technology discussed.  Other Aluminium-Recovery Routes The consultation document also refers to: chemical delamination,  solvent dissolution,  recovery from pyrolysis residue,  processing of PolyAl recovered from aseptic cartons.  Hydro-Pulping of Aseptic Cartons Aseptic cartons are different from ordinary plastic laminates because paperboard forms a major part of their structure. Mechanical Hydro-Pulping Water and mechanical action are used to separate paper fibre from the polyethene-aluminium layer. The recovered paper fibre can go into products such as recycled paper and paperboard. The residual PolyAl can be used for: composite boards,  roofing sheets,  moulded products,  further plastic/aluminium recovery.  Enzymatic Hydro-Pulping CPCB also discusses an enzyme-assisted version of the process. Here, enzymes help weaken the adhesive and fibre interface so the layers can separate more easily. Potential advantages discussed include: improved fibre recovery,  reduced chemical use,  lower water requirement,  lower energy requirement,  less fibre damage.  The draft is careful not to present enzymatic recycling as fully mature. It says wider deployment should depend on demonstrated technical feasibility, environmental performance, economic viability and statutory compliance.  Environmental Safeguards for MLP Recycling Facilities A recycling technology is useful only if the recycling process itself does not create another pollution problem. The draft therefore discusses safeguards for advanced facilities. Depending on the process, these may include: pollution-control equipment, emission control, dust control, feed preparation, solvent recovery, wastewater treatment, proper residue management, batch-wise records, recovery records, mass-balance documentation. Advanced recycling facilities are also expected to operate with the statutory environmental approvals applicable to their activities.  What Products Can Be Made from Recycled MLP? Recycled MLP does not have only one end use. CPCB identifies two broad routes. Granulate-Based Conversion In this method, MLP waste is first processed into pellets or granules, which can then be used in regular plastic-processing machines. It may be used to make products such as pallets, crates, benches, dustbins, pipes, cable ducts, plastic lumber, sheets and other moulded items. Direct Conversion Some MLP waste can also be used directly after shredding or agglomeration, without first turning it into granules. It may then be converted into products such as boards, sheets, panels or other suitable recycled items.  The draft mainly refers to non-food-contact applications, so the presence of recycled MLP should not automatically be treated as approval for food-contact packaging.  What Happens to MLP That Cannot Be Recycled? Some material will remain unsuitable for useful material recovery even after sorting and processing. The draft sets out a practical hierarchy. First Preference: Material Recycling Recover plastic, paper, aluminium or another usable material wherever technically possible. Second Preference: Direct Conversion When granulates cannot be produced, some fractions can be used for direct conversion to product forms like boards and road material. Remaining Fraction: Authorised EOL Route Possible controlled routes include: cement kiln co-processing,  waste-to-energy,  pyrolysis,  other authorised applications.  The draft makes it clear that open burning and improper landfill disposal are not acceptable routes for MLP waste.  Quality Control and Testing of Recycled MLP Producing recycled material is only half the job. The buyer also needs to know whether different batches are reasonably consistent. CPCB therefore provides an indicative testing regime. Parameter Indicative Method Frequency Typical Basis Mentioned Melt Flow Index IS 13360-4 / ISO 1133 Every batch Within ±20% of declared grade Density IS 13360-3 / ISO 1183 Every batch 0.91-1.05 g/cm³ per grade Ash content ISO 3451-1 Every batch Typically <8% polyolefin grade and <15% mixed grade Moisture Halogen/oven method Every batch <0.3% at despatch Filtration fineness Screen/process record Continuous ≥80 mesh declared Tensile/impact ISO 527 / ISO 179 Periodic Declared product data Odour/volatiles Sensory/VDA-270 type Periodic Fit for intended use These figures appear in a public consultation draft. They should not be presented as final mandatory standards unless they are retained or otherwise made operative. For direct-conversion products such as boards or sheets, CPCB says quality assessment may need to shift from granulate properties to the performance of the finished product.  How Will EPR Compliance for Category III MLP Be Monitored? The central CPCB EPR Portal connects regulatory data with actual plastic processing. The portal covers functions such as: registration,  packaging data submission,  EPR obligation calculation,  processor reporting,  EPR certificate generation,  compliance monitoring.  PIBOs placing Category III packaging on the market should report it under the correct category. CPCB specifically says Category II all-plastic multilayer packaging should not be treated as Category III.  PWPs upload processed quantities. Eligible EPR certificates are then linked with verified processing. The draft also discusses automatic cross-checking between quantities reported by PIBOs and PWPs. Where figures differ, the lower quantity is taken for compliance purposes. Annual returns, inspections and audits provide an additional check.  For businesses using Plastic Waste EPR Registration and ongoing EPR compliance systems, this means data accuracy is not enough on its own. Supporting physical records also matters. Environmental Compensation and Compliance Risk The draft mentions Environmental Compensation where applicable EPR obligations are not met. However, it does not introduce any new fixed penalty amount in this section. Businesses should therefore pay more attention to the compliance gaps that can create problems, such as: reporting waste under the wrong category, incorrect quantity details, using an unregistered processor, missing weighment, invoice or transport records, differences between input and output data, weak residue records, unsupported processing claims, and unauthorised dumping or burning. A proper EPR record should clearly show how the waste moved from collection to its final authorised processing facility. How does CPCB evaluate New MLP Recycling Technologies? CPCB does not treat every new recycling machine or process as automatically acceptable. The draft refers to its Protocol for Evaluation of Technology for Waste Management, developed in June 2021. It also refers to an MoEF&CC Office Memorandum dated 9 July 2026 connected with directions of the NGT. For proposals involving dissolution techniques, the draft says evaluation should take place under CPCB's technology-evaluation protocol. Where feasible, a Standing Committee chaired by the Member Secretary, CPCB, is involved in the approval route described in the document.  This distinction matters for technology companies. A process being technically promising is not the same thing as it being automatically accepted as a regulatory processing route. What Alternatives to Conventional MLP Does CPCB Discuss? The consultation paper also asks a bigger question: can some difficult multilayer structures be redesigned before they become waste? CPCB discusses several alternatives. 1. Mono-Material Packaging Pouches made mainly from a single polymer family, such as PE or PP, can be easier to recycle than complex multi-material structures. 2. Compostable Bio-Based Films The draft refers to materials such as PLA, PHA and cellulose films for suitable applications. These materials still need the right collection and processing infrastructure. 3. Paper-Based Barrier Packs Paper with suitable barrier coatings may provide an alternative for some products. Its recyclability or compostability will depend on the coating used and the actual structure. 4. Recycled-Content Plastics Post-consumer recycled plastics might help to minimize reliance on virgin plastic if they are deemed appropriate for certain applications. 5. Biodegradable Coatings Starch-based coatings and biopolymers are mentioned as potential substitutes for coatings in some cases. These options are presented for evaluation rather than as a compulsory replacement schedule.  Packaging Redesign and the Future of MLP in India The final part of the draft looks beyond waste plants and focuses on the packaging itself. CPCB discusses reducing material complexity and looking at developments such as: aluminium-free aseptic cartons,  renewable-feedstock-based polymers,  high-barrier coatings,  improved recyclability,  design-for-circularity.  The draft refers to products used in European markets but does not say they should be copied in India. Before wider adoption, businesses would need to consider: product safety,  shelf life,  Indian climatic conditions,  existing recycling infrastructure,  raw material availability,  cost,  Indian standards and regulations.  PIBOs may also consider pilot projects or technical studies before changing large packaging portfolios.  How Could These Draft Guidelines Affect Businesses? The likely effect will differ from one industry to another. Business Possible Impact FMCG companies Packaging classification, EPR data, collection and design review Food brands Review of foil laminates and aseptic packs Pharmaceutical companies Mapping blister packs, strip packs and lidding foils Importers Correct EPR categorisation of imported packaging Packaging converters Material composition records and post-industrial waste handling Recyclers Technology choice, mass balance, pollution controls and testing MRF operators Improved sorting and aggregation Compliance teams Better link between packaging, EPR and waste-processing records FMCG and Food Brands These companies may need better information from packaging suppliers about the exact laminate structure. A pack described only as “flexible plastic” may not provide enough information to decide whether it belongs in Category II or Category III. Pharmaceutical Companies Foil-containing strip packs and lidding material deserve particular attention because the draft specifically discusses aluminium recovery from these streams. Importers Importers may need to check the packaging that comes with imported products, not just the imported product itself. Correct EPR categorisation remains important. Recyclers Recyclers may face closer expectations around: feedstock suitability,  input-output balance,  residue management,  pollution controls,  testing,  product quality.  Challenges and Cost Implications The draft does not give a standard implementation cost. That makes sense because the cost for a national FMCG brand will be completely different from the cost for a small recycler. Collection Cost MLP is light and spread across large areas. Even when a large volume exists, transporting loose packaging may not be economical. Sorting Cost Material has to be separated by: contamination,  polymer family,  paper content,  aluminium content,  recoverability.  Processing Cost Recyclers may need: balers,  shredders,  washers,  dryers,  extrusion equipment,  delamination systems,  aluminium recovery systems,  pollution-control systems.  Testing Cost Where recycled granulate is sold as a consistent industrial material, routine quality testing adds another operating requirement. Documentation Cost Traceability also takes people and systems. Invoices, weighment slips, transport documents, batch records and portal data need to match. The draft itself recognises that collection and channelisation remain a major constraint for MLP because the waste is low in weight and dispersed.  Business Opportunities Created by Better MLP Waste Management The same framework that creates compliance work can also create demand for new services and infrastructure. Possible areas include: Registered Recycling Better collection can provide processors with more consistent MLP feedstock. Waste Aggregation Aggregation businesses may become more valuable where individual quantities are too small to transport economically. Material Recovery Facilities MRFs can perform secondary segregation and prepare material before it reaches specialised processors. Aluminium Recovery Foil-based waste may create additional demand for: delamination,  eddy current separation,  electrostatic separation,  secondary aluminium recycling.  Recycled Products Recovered material can support manufacturing of: boards,  sheets,  panels,  pallets,  plastic lumber,  certain construction products.  Technology Providers The proposed framework may also create more opportunities for companies supplying recycling and waste-processing technology. This could include equipment for sorting, baling, shredding, hydropulping, aluminium recovery, chemical recycling and pollution control. CPCB also notes that recycling clusters could offer shared infrastructure for smaller recyclers and newer technology providers, subject to the required environmental and statutory approvals. Is the CPCB MLP Framework a Right Decision or an Additional Burden? There is a fair argument on both sides.  Area Possible Benefit Possible Burden Collection More MLP reaches authorised processing More logistics cost Recycling Higher recovery of valuable material Technology investment EPR Better data credibility More record-keeping Aluminium recovery Value recovered from foil Specialised processing needed MRFs Better segregation Infrastructure cost Smaller recyclers More feedstock and cluster opportunity Upgrade cost Packaging redesign Easier future recycling R&D and testing cost Environment Lower littering and burning Implementation depends on enforcement The strongest part of the proposal is its focus on material recovery before disposal. Plastic, aluminium and paper can all have value. Throwing them away together loses that value. The difficult part is collection. A lightweight sachet may technically be recyclable, but recycling becomes meaningless if it costs too much to collect and transport. The success of the final framework will therefore depend on whether the collection model is workable at ground level, especially outside major cities. What Should PIBOs, Recyclers and Businesses Do Now? The September 2026 guidelines are still at the public-consultation stage. Businesses should therefore avoid treating every recommendation as a new legal duty. A practical approach is to divide work into two buckets. A. Continue Existing Compliance Organizations should look at compliance duties that they must fulfill under the existing PWM and EPR regime. These may include, depending on the entity: EPR registration,  correct packaging categorisation,  accurate reporting,  annual returns,  use of registered processors,  valid environmental approvals,  required record-keeping.  Companies needing support with EPR Registration Services should deal with their existing applicable requirements rather than waiting for the consultation process to finish. B. Prepare for the Proposed Direction At the same time, companies can begin reviewing: 1. Which packs are actually Category III? Obtain laminate structures from packaging suppliers.  2. Where does the waste go today? Map collectors, aggregators and processors.  3. Can the processor handle that particular laminate? Registration alone does not answer every technology question.  4. Is the paperwork complete? Check invoices, weighment records and transport evidence.  5. Can difficult packaging be redesigned? Packaging and procurement teams can start evaluating easier-to-recycle alternatives.  6. Is the final CPCB guidance being monitored? A draft can change before publication.  What Could Change After Public Consultation? The September document should be read as CPCB's current proposal. After consultation, CPCB could: retain the existing draft,  modify technical values,  change recommended processes,  clarify stakeholder duties,  revise technology sections,  change implementation language,  add further operational guidance.  Businesses should therefore track the final CPCB publication and any subsequent instructions rather than using the consultation draft as if it were already a final notification. The document itself also speaks about periodic review, capacity building and continued adoption of emerging technologies.  How Corpseed Can Help with EPR Registration and Plastic Waste Compliance Managing plastic packaging compliance is rarely limited to one registration. Businesses often need to connect packaging classification, EPR data, processing records, recycler details and environmental approvals. Corpseed can support businesses across these areas through EPR Registration Services, EPR Compliance Services and Environmental Compliance Services, depending on the nature of the entity and its actual regulatory obligations. 1. EPR Applicability Assessment Before filing anything, the first question should be whether EPR applies and in what capacity. Corpseed can support businesses in reviewing: business activity,  producer/importer/brand-owner status,  plastic packaging used,  packaging categories,  applicable registration requirements.  This helps avoid filing under an incorrect category. 2. EPR Registration Services Businesses that fall within the applicable framework can use Corpseed's EPR Registration Services for support with: application preparation,  information review,  documentation organisation,  filing assistance,  clarification support during the process.  No approval should be assumed until it is granted by the competent authority. 3. Plastic Packaging Category Review The problem of improper classification of plastics is common. Corpseed can help businesses assess whether available packaging data suggests: Category I,  Category II,  Category III,  Category IV,  Category V,  subject to the actual legal definition and technical composition. For complicated laminates, technical material information from the packaging manufacturer may still be required. 4. Plastic Waste EPR Registration Support Importers, producers and brand owners that require Plastic Waste EPR Registration may need help organising entity and packaging data before filing. Support can include: packaging-data review,  application information,  supporting documents,  portal filing assistance.  5. EPR Compliance and Annual Return Support Registration is only the starting point. Ongoing compliance may include: packaging quantity records,  category-wise data,  recycling/EOL records,  certificate records,  annual return data,  internal compliance tracking.  Corpseed's EPR Compliance Services can assist businesses with organising and reviewing these records. 6. Plastic Waste Processor Compliance Support Recyclers and processors may have to meet a different range of compliance standards. This includes: registration paperwork, environmental approval checks, capacity data, processing logs, traceability, and gap analysis.  7. Recycler and PWP Documentation Review PIBOs should not rely only on the EPR certificate. The supporting records behind the transaction are equally important as the EPR. Corpseed can help review documents such as: processor registration details, invoices, weighment slips, waste-transfer records, processing proof, and traceability documents. 8. Environmental Compliance Services Recycling and processing units may need different environmental approvals depending on their activity, process and location. Corpseed can assist in identifying the applicable requirements and provide support for relevant environmental consents, authorisations and compliance documentation. 9. Regulatory Monitoring Plastic waste compliance can change through CPCB directions, rule amendments, EPR Portal updates and new guidance. Corpseed can help businesses keep track of these changes so they can review their compliance requirements and take timely action where needed. Businesses can use ongoing compliance support to track: CPCB updates,  MoEF&CC changes,  EPR Portal developments,  SPCB/PCC instructions,  finalisation of the Category III MLP guidelines.  For businesses looking for a CPCB EPR Registration Consultant, the better approach is to start with applicability and packaging classification before moving to registration and ongoing compliance. Key Takeaways The CPCB September 2026 document gives businesses a much clearer picture of how Category III MLP waste could be collected, processed and monitored in the coming years. The main points are: The CPCB document is still open for public consultation, so businesses should not treat it as a final compliance requirement yet. Category III covers multilayer packaging that combines plastic with at least one non-plastic material. Packaging made only from different plastic layers continues to fall under Category II. One of the biggest practical issues is collecting and bringing scattered MLP waste together in workable quantities. Recycling should be the first option wherever the material can be recovered properly. Different materials such as plastic, paper and aluminium may need different recycling or recovery methods. The draft looks at both mechanical recycling and newer recycling technologies for difficult MLP waste. Proper testing, processing records and mass-balance details are becoming more important for traceability. The CPCB EPR Portal remains an important part of reporting, processing data and EPR certificate compliance. Existing EPR responsibilities continue to apply even while these draft guidelines are under consultation. Businesses should keep track of the final CPCB publication before treating any proposal in the draft as a compulsory requirement.