Law Updates

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Summary: The Pollution Control Committee (PCC) issued a circular on 29 September 2026, directing industries handling hazardous waste in Dadra and Nagar Haveli and Daman and Diu to register on the National Hazardous Waste Tracking System (NHWTS). The circular gives covered industrial units 15 days from the date of issue to complete the registration. The direction applies to industrial establishments involved in activities such as hazardous waste generation, transportation, storage, recycling, utilisation and disposal. The system, developed by the Central Pollution Control Board (CPCB), is designed to track how hazardous waste is managed across different stages. For factory owners and industrial operators, the circular requires them to check whether their units must register on the NHWTS. They should also review their existing Hazardous Waste Authorisation to confirm that it complies with the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The 15-day deadline has passed. Businesses that have not yet registered should check their current status, and contact the relevant authority to find out how to complete the registration. PCC Circular on NHWTS Registration: Key Details The Pollution Control Committee issued the circular to bring covered hazardous waste activities within the centralised tracking system developed by CPCB. The main details are provided below. Particulars Details Issuing Authority Pollution Control Committee, DNH & DD Circular Dat 29 September 2026 Document Type Official Circular Subject National Hazardous Waste Tracking System (NHWTS) Registration Applicable Rules Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 Relevant Provision Rule 6 Registration Timeline Within 15 days from the issue of the circular Jurisdiction Dadra and Nagar Haveli and Daman and Diu Concerned Establishments Industrial units engaged in specified hazardous waste activities Official Portal https://nhwts.nic.in/ Relevant Central Authority Central Pollution Control Board (CPCB) The circular makes registration on NHWTS a compliance requirement for the industrial establishments it covers. It also reminds authorised occupiers to continue following the hazardous waste rules. Importantly, the circular applies to the jurisdiction of the issuing PCC. It should not be described as a fresh nationwide registration deadline for every industry in India. Understanding the Hazardous Waste Management Rules, 2016 Industries that generate hazardous waste cannot manage it in the same way as ordinary industrial waste. Certain types of waste require controlled handling, storage, transportation, treatment and disposal because they may pose risks to people and the environment. The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, provide the principal legal framework for managing these wastes in India. The Rules cover the responsibilities of occupiers and other entities involved in regulated waste management activities. They also establish requirements relating to authorisation, management, records and other compliance matters. The September 2026 circular does not replace these Rules. It refers to the existing regulatory framework while directing covered establishments to register on NHWTS. Hazardous Waste Authorisation Under Rule 6 Rule 6 deals with authorisation for hazardous and other waste management. Occupiers engaged in covered activities are required to apply for authorisation through Form 1 to the competent pollution control authority, subject to the applicable provisions. This authorisation is relevant to activities such as generation, collection, storage, transportation, recycling, recovery, utilisation, treatment and disposal. Businesses should understand that hazardous waste authorisation and NHWTS registration are two separate compliance matters. Having a valid authorisation does not mean the establishment is registered on NHWTS. In the same way, portal registration does not replace the Hazardous Waste Authorisation required under the applicable rules. Role of PCC and CPCB The Pollution Control Committee carries out pollution control functions within Dadra and Nagar Haveli and Daman and Diu, including responsibilities under the applicable environmental laws. CPCB operates at the central level and has developed the National Hazardous Waste Tracking System to support hazardous waste tracking. Under the September 2026 circular, the PCC has directed covered industrial establishments in its jurisdiction to register on this system. What Is the National Hazardous Waste Tracking System (NHWTS)? The National Hazardous Waste Tracking System (NHWTS) is an online system developed by CPCB to track hazardous waste management activities. It is a GIS-based platform integrated with the Online Consent Management and Monitoring System (OCMMS). The purpose is to support centralised monitoring of hazardous waste activities across different locations and facilities. Hazardous waste does not always remain at the place where it is generated. It may be collected, transported, stored, processed, recycled or sent for disposal. This makes tracking important. Regulators need information about the facilities involved in managing hazardous waste and the activities carried out. NHWTS has been developed to support this process through a common digital system. Activities Covered by Hazardous Waste Tracking The September 2026 circular identifies several activities connected with hazardous waste management. These include: Waste Generation: Hazardous waste produced during industrial or other covered operations. Collection and Storage: Keeping or collecting hazardous waste before further management. Transportation: Movement of hazardous waste between relevant locations or facilities. Processing and Recycling: Activities involving the processing or recovery of waste materials. Utilisation: Use of hazardous waste in permitted industrial processes. Treatment and Disposal: Management of hazardous waste through applicable treatment or disposal arrangements. The circular also refers to packaging, use, recovery, pre-processing, co-processing, offering for sale and transfer in the context of hazardous waste authorisation. The exact compliance requirements depend on the activity and applicable provisions. Registration on NHWTS does not automatically authorise an establishment to undertake every activity listed above. Which Industries Must Register on the NHWTS Portal? As stated in the PCC circular issued in September 2026, industrial units carrying out certain hazardous waste activities in Dadra and Nagar Haveli and Daman and Diu are required to register on the NHWTS portal. The requirement should be assessed according to the waste handled and the activities undertaken by the establishment. A business should not decide whether registration applies solely on the basis of its industry name. Industries Generating Hazardous Waste Industrial units that generate waste covered by the hazardous waste rules should review their position under the PCC circular. The main point is to determine whether the waste generated by the facility falls within the regulated categories and whether the establishment is covered by the registration direction. Where hazardous waste authorisation is required, businesses must also ensure that their authorisation remains appropriate for their activities. Hazardous Waste Storage and Transportation Facilities The circular expressly refers to hazardous waste storage and transportation. Establishments involved in these activities should check their applicable authorisation requirements and NHWTS registration status. Waste storage and transportation may also involve other statutory conditions under the relevant Rules. These continue to apply independently of registration on the national portal. Hazardous Waste Recycling and Recovery Units Facilities engaged in the recycling, recovery, processing, pre-processing or co-processing of hazardous waste should assess whether they come within the circular's scope. These activities are part of the wider hazardous waste management framework and may be subject to specific authorisation conditions. Hazardous Waste Treatment and Disposal Facilities Facilities that treat or dispose of hazardous waste must check whether they need to register on NHWTS. Registration does not change the environmental approvals or waste management conditions they must follow while carrying out these activities. NHWTS Applicability for Different Activities Industrial Activity Relevance to NHWTS Registration  Important Compliance Check Hazardous Waste Generation Covered by the circular's direction Waste classification and authorisation Hazardous Waste Storage Expressly included Applicable storage requirements Hazardous Waste Transportation Expressly included Applicable transport and authorisation requirements Recycling and Recovery Included in the listed activities Authorisation and activity-specific conditions Processing and Co-processing Included in the circular's Rule 6 discussion Applicable permissions Hazardous Waste Utilisation Expressly included Authorised use and regulatory conditions Treatment and Disposal Expressly included Facility authorisation and compliance status Businesses should review the actual activities undertaken at their facility before deciding which requirements apply. NHWTS Registration Deadline Under the September 2026 PCC Circular The Pollution Control Committee issued the circular on 29 September 2026, directing covered industrial establishments to register on NHWTS within 15 days of its issue. The circular places a clear emphasis on completing registration within the specified period. As of 21 October 2026, the original registration period has already elapsed. Businesses should therefore check whether they have complied with the direction. Compliance Requirement Details Circular Issued 29 September 2026 Registration Period Within 15 days of issue Required Action NHWTS Portal Registration Applicable Area DNH & DD Position as of 21 October 2026 Original 15-day period has elapsed Revised Deadline No later extension identified in the official sources reviewed The circular does not separately state the final calendar date for registration. Businesses that have not registered should check the current portal position and seek clarification from the PCC where necessary. A delayed application should not automatically be assumed to resolve any earlier non-compliance. Difference Between NHWTS Registration and Hazardous Waste Authorisation Businesses often need to deal with more than one environmental approval or compliance requirement. In this case, NHWTS registration and hazardous waste authorisation are connected, but they have different purposes. Basis NHWTS Registration Hazardous Waste Authorisation Purpose Tracking hazardous waste activities through a centralised system Authorising covered hazardous waste management activities Framework NHWTS portal and relevant regulatory directions Hazardous and Other Wastes Rules, 2016 Authority CPCB-developed system with applicable PCC direction Competent pollution control authority Main Requirement Registration on the tracking portal Obtaining authorisation where legally required Business Responsibility Complete applicable registration requirements Maintain applicable authorisation and comply with its conditions Does It Replace the Other? No No Is NHWTS Registration Enough for Hazardous Waste Compliance? No. NHWTS registration does not replace hazardous waste authorisation. Businesses undertaking activities that require authorisation under Rule 6 must obtain and maintain that authorisation as required by law. Likewise, establishments already holding hazardous waste authorisation must separately review whether the PCC's NHWTS registration direction applies to them. The two requirements should be considered together when reviewing an establishment's environmental compliance position. How to Register on the NHWTS Portal Industrial establishments covered by the PCC circular should use the official National Hazardous Waste Tracking System portal for registration. The CPCB portal provides an industry registration facility, and its published help manual explains registration and login arrangements for different categories of users. Step 1: Visit the Official NHWTS Website Open the CPCB National Hazardous Waste Tracking System at: https://nhwts.nic.in/ Access the relevant industry registration or login option. Step 2: Check Existing Login Details The official portal supports industry users connected with OCMMS as well as other registered industry users. Businesses should check whether they already have relevant login credentials before creating another account. Step 3: Enter Establishment Information The currently available industry registration form includes fields for: State and district. Industry or facility name. Facility address. Contact or authorised person. Mobile number and email address. Authorisation or application number. Authorisation issue and validity dates. Other establishment information requested by the portal. The form also includes an option for attaching an authorisation application in PDF format. The exact information required should be checked against the live portal. Step 4: Submit the Registration Request Complete the applicable form according to the portal instructions. The NHWTS help manual states that an industry registration request is sent for CPCB approval. The user can log in with the relevant credentials after approval. Step 5: Check Registration Status After submitting the application, businesses should check the status and keep a copy of the acknowledgement or registration details provided by the portal. For any further steps, or portal-related instructions, refer to the official help manual. Does the PCC Circular Specify an NHWTS Registration Fee? The September 2026 PCC circular does not mention any fee for NHWTS registration. Before making a payment, businesses should check the official portal, or contact the concerned authority to confirm whether a registration fee applies. Professional consultancy charges, where applicable, should be distinguished from government fees. Responsibilities of Existing Hazardous Waste Authorisation Holders Industries already holding hazardous waste authorisation should pay attention to the September 2026 circular. The PCC has specifically reminded authorised occupiers to continue following the Hazardous and Other Wastes Rules, 2016, as amended. Businesses should review the following areas. Check Authorisation Validity: Review the existing authorisation and confirm that it remains valid. Where renewal is required, the business should follow the applicable renewal requirements. Match Authorisation with Actual Operations: The hazardous waste activities undertaken at a facility should be reviewed against the activities covered by its authorisation. Where operations have changed, the establishment should assess whether any regulatory action is required. Review NHWTS Registration Status: Existing authorisation holders should check whether their establishments have completed registration under the PCC circular. Holding authorisation should not be treated as automatic proof of NHWTS registration. Maintain Applicable Waste Management Records: Businesses should continue meeting the record-keeping and reporting obligations applicable under the governing Rules. As a practical measure, relevant authorisation details and hazardous waste information should be kept organised and accessible. Impact of NHWTS Registration on Businesses For industrial establishments, the September 2026 circular is more than a reminder to use an online portal. It also highlights the importance of having accurate information about hazardous waste operations, and existing regulatory approvals. Better Visibility of Hazardous Waste Activities NHWTS is designed to help track hazardous waste management through a centralised system. This can support regulatory oversight of establishments involved in different stages of waste handling. Greater Need to Review Existing Approvals Businesses may need to review whether their activities are correctly covered by their existing hazardous waste authorisation. For a facility with several waste management activities, an organised compliance review can help identify issues requiring attention. Improved Internal Compliance Management Environmental compliance teams may benefit from coordinating with production, operations and waste management personnel. The purpose is to maintain consistent information about the establishment's hazardous waste activities and regulatory position. Continued Attention to Legal Responsibilities Businesses must continue to follow the applicable hazardous waste management rules even after NHWTS registration. Registration alone does not fulfil all their legal responsibilities, and they must continue to meet the conditions set out in their authorisation, and other applicable environmental requirements. Businesses must continue following applicable hazardous waste management requirements even after completing registration. Risks of Non-Compliance with NHWTS Registration Requirements The PCC circular directs covered industrial establishments to register within the specified period. Businesses that have not followed the direction may face questions concerning their compliance position. However, the circular does not independently prescribe a specific monetary penalty, automatic suspension or business closure for failure to register on NHWTS. Any enforcement consequences must be assessed under the applicable governing provisions and circumstances. Failure to Follow a Regulatory Direction An establishment that comes within the circular's scope but has not completed registration should review its position promptly. Where clarification is necessary, it should approach the competent authority. Gaps in Hazardous Waste Authorisation An establishment may also face separate compliance concerns if it conducts activities requiring authorisation without meeting those statutory requirements. This issue is distinct from NHWTS registration. Incomplete or Outdated Compliance Information Incorrect details about the facility, expired authorisations or missing records can cause problems during compliance checks and when dealing with the regulatory authorities. Businesses should therefore review their information and address discrepancies where necessary. What Should Industries Do After the PCC Circular? Industries operating in Dadra and Nagar Haveli and Daman and Diu should now focus on checking their existing compliance position. The following actions can help. Check applicability: Determine whether the establishment undertakes hazardous waste activities covered by the circular. Review existing authorisation: Confirm whether the facility holds the necessary hazardous waste authorisation and whether it covers the relevant activities. Check NHWTS Registration: Visit the official portal to check whether your establishment is registered. Complete Pending Registration: If your facility is not registered, follow the portal instructions, and contact the PCC if you need help with the process. Check Facility Records: Review your facility details and Hazardous Waste Authorisation to ensure the information is correct and up to date. Meet Other Legal Requirements: Keep your authorisation valid, submit the required reports and follow the hazardous waste management rules that apply to your establishment. Industries operating in Dadra and Nagar Haveli and Daman and Diu should now focus on checking their existing compliance position. NHWTS Registration and Hazardous Waste Compliance Checklist Compliance Area What Businesses Should Check NHWTS Applicability Whether the facility undertakes activities covered by the PCC circular NHWTS Registration Whether registration has been completed Registration Timeline Whether the original 15-day direction was complied with Hazardous Waste Authorisation Whether authorisation is required and held Authorisation Validity Whether existing permission remains valid Waste Management Activities Whether actual operations match applicable authorisation conditions Regulatory Records Whether required records and returns are maintained Ongoing Compliance Whether the establishment continues following the applicable Rules The registration direction is mandatory for establishments falling within the circular's scope. Some additional checks listed above are practical compliance recommendations, while others arise independently under the existing hazardous waste rules. How Corpseed Can Help with Hazardous Waste Authorisation and Compliance Understanding hazardous waste requirements can be difficult when a business is involved in several activities, such as generation, storage, recycling or treatment. A company may need to assess whether it requires hazardous waste authorisation, review its existing approval or deal with renewal and reporting obligations. Corpseed offers Hazardous Waste Authorisation Services and related regulatory assistance to help businesses address these requirements. Hazardous Waste Authorisation Services Businesses undertaking regulated hazardous waste activities may require authorisation from the competent pollution control authority. Corpseed provides assistance through its Hazardous Waste Management Authorisation service. This can be relevant to businesses seeking professional support with understanding applicable authorisation requirements and completing the authorisation process. Hazardous Waste Authorisation Renewal An existing authorisation must be maintained according to the applicable legal requirements. Businesses seeking renewal support can refer to Corpseed's Hazardous Waste Authorisation Renewal service. Hazardous Waste Annual Return Compliance Depending on the applicable provisions, businesses may also need to maintain records and submit hazardous waste annual returns. Corpseed offers Hazardous Waste Authorisation Annual Return assistance for relevant compliance needs. Environmental Compliance Support for Industries Industrial units dealing with hazardous waste may need help understanding the rules that apply to their operations and the approvals they must hold. The PCC circular focuses on NHWTS registration. Before seeking help from Corpseed with the registration process, businesses should check whether this service is available and what assistance can be provided. Need assistance with Hazardous Waste Authorisation or environmental compliance? Connect with Corpseed to understand the requirements applicable to your industrial establishment and the available professional support. Contact: +91 75586 40644 Website: https://www.corpseed.com/ Key Takeaways The Pollution Control Committee, Dadra and Nagar Haveli and Daman and Diu, issued an NHWTS registration circular on 29 September 2026. Covered industrial establishments were directed to register on the National Hazardous Waste Tracking System within 15 days of the circular's issue. The direction concerns establishments involved in specified hazardous waste activities, including generation, transportation, storage, recycling, utilisation and disposal. NHWTS registration and hazardous waste authorisation are different compliance requirements. Registration does not replace an authorisation required under Rule 6. The original registration period has elapsed. Affected businesses should check their registration status and continue meeting the applicable hazardous waste rules.