JSA Newsletter | Environment_ESG | May to July 2026 Edition

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Supreme Court

Supreme Court allows operation of formaldehyde manufacturing units despite absence of prior Environmental Clearance

The Supreme Court of India (“Supreme Court”), in its judgement dated May 6, 2026, in the case of Neetu Solvents and Ors. vs. Vineet Nagar and Ors.[1], held that industrial units established and operating with valid Consent to Establish (“CTE”) and Consent to Operate (“CTO”) granted by the concerned State Pollution Control Boards (“SPCBs”) cannot be directed to shut down merely due to non-obtaining of prior Environmental Clearance (“EC”), where such non-compliance arose from a bona fide understanding by both the industries and regulatory authorities that EC was not required.

The case concerned several formaldehyde manufacturing units operating in the States of Rajasthan and Haryana, which had obtained CTE and CTO from the respective SPCBs. Subsequently, proceedings were initiated before the National Green Tribunal (“NGT”), alleging that the units were functioning without prior EC as required under the Environment Impact Assessment (“EIA”) Notification, 2006, since formaldehyde manufacturing falls under the category of synthetic organic chemical industries. The NGT directed closure of the units and disconnection of electricity supply for failure to obtain prior EC.

The Supreme Court, relying on its earlier decision in Pahwa Plastics Private Limited and Anr. vs. Dastak NGO and Ors., observed that the present case involved units that had commenced operations after obtaining statutory approvals from the SPCBs and were not cases of deliberate violation of environmental regulations. The Supreme Court noted that the SPCBs themselves were initially unaware of the applicability of EC requirements to formaldehyde manufacturing units and subsequently directed the industries to apply for EC. The Court further observed that the units had already initiated the EC process and had completed various stages, including screening, scoping and grant of Terms of Reference.

Accordingly, the Supreme Court set aside the NGT’s closure directions and permitted the units to continue operations, subject to compliance with the EC process. The Court directed that applications for EC be decided in accordance with law and clarified that electricity supply should be restored, if disconnected, subject to applicable conditions. The judgement reaffirmed that while prior EC requirements must ordinarily be complied with, closure of operational units is not justified where the lapse is technical in nature and arises from a genuine regulatory misunderstanding rather than deliberate non-compliance.

 

Supreme Court constitutes High-Powered Committee to examine definition and protection of Aravalli Hills and Ranges

The Supreme Court, in its order dated May 25, 2026, in a Suo motu proceeding titled In Re: Definition of Aravalli Hills and Ranges and Ancillary Issues[2], constituted a five-member High-Powered Committee comprising domain experts to undertake a comprehensive evaluation of the definition, demarcation and ecological implications of the Aravalli Hills and Ranges.

The proceedings arose from concerns regarding the scientific basis and environmental impact of the proposed definition of the Aravalli Hills and Ranges, particularly the criteria limiting protected areas based on elevation thresholds and distance between hill formations. Notably, the court noted that only 1,048 (one thousand forty eight) of 12,081 (twelve thousand eighty one)  hills in Rajasthan meet the proposed 100 (one hundred) metre elevation threshold, raising concern that the remaining hills would lose environmental protection altogether. The Supreme Court observed that such restrictive parameters may result in ecologically contiguous areas being excluded from protection and could potentially facilitate unregulated mining and other activities affecting the fragile Aravalli ecosystem.

The Supreme Court emphasised that decisions having significant environmental consequences must be supported by expert evaluation and scientific assessment. It observed that the Aravalli Hills possess ecological importance due to their biodiversity, geological characteristics and natural resources, and that any regulatory framework must ensure sustainable development while preventing irreversible environmental degradation.

Accordingly, the Supreme Court constituted a High-Powered Committee comprising experts from forestry, geology, environmental science and biodiversity fields, including representatives from the Indian Council of Forestry Research and Education, Forest Survey of India, Geological Survey of India and other relevant disciplines. The Committee has been directed to examine the ecological, geological and environmental implications of the proposed definition, identify areas covered or excluded under the criteria, assess the impact of regulated mining activities, and undertake a scientific mapping of the Aravalli region.

The Supreme Court further directed the Committee to issue a public notice inviting suggestions from all stakeholders, including State Governments, environmental organisations, conservation groups, mining stakeholders, local communities and other affected persons, to ensure a balanced and comprehensive assessment. The Committee has been directed to submit its report by August 31, 2026.

 

Supreme Court issues directions for prevention of illegal sand mining in National Chambal Sanctuary and protection of endangered aquatic wildlife

The Supreme Court, in its order dated May 26, 2026, in the case of In Re: Illegal Sand Mining in the National Chambal Sanctuary and Threat to Endangered Aquatic Wildlife[3], directed the States of Rajasthan, Madhya Pradesh and Uttar Pradesh, along with other concerned authorities, to undertake comprehensive measures for preventing illegal sand mining, strengthening enforcement mechanisms and protecting the ecological integrity of the National Chambal Gharial Sanctuary.

The Supreme Court observed that protection of environmentally sensitive areas is a continuing constitutional obligation under Articles 21, 48A and 51A(g) of the Constitution of India and expressed concern over illegal sand mining, inadequate surveillance systems, operation of unregistered vehicles and threats to wildlife and public infrastructure. The Court also noted that large-scale vacancies in Forest Guard posts unfilled for approximately four years had significantly weakened field-level enforcement capacity.

The Supreme Court directed the concerned States to strengthen enforcement capacity, establish surveillance infrastructure, take strict action against vehicles and persons involved in illegal mining activities, and ensure investigation against owners, financiers and other stakeholders facilitating such activities. The States were directed to complete recruitment to vacant Forest Guard posts within 1 (one) year and to operationalise surveillance infrastructure within 6 (six) months, with the Chief Secretaries of all three States required to file compliance affidavits and review progress at least once every 2 (two) months. The Supreme Court also directed the National Highways Authority of India to install surveillance systems near the National Highway-44 bridge over the Chambal River and required authorities to undertake measures for river conservation, maintenance of environmental flows and promotion of sustainable livelihood initiatives in affected communities.

 

Supreme Court directs time-bound removal of encroachments and restoration of Agasthyamalai landscape in Tamil Nadu

The Supreme Court, in its judgement dated May 29, 2026 in the case of A. John Kennedy and Ors. vs. State of Tamil Nadu and Ors.[4] addressed issues concerning protection of reserved forests, wildlife sanctuaries and tiger reserves in the Agasthyamalai landscape, along with rehabilitation claims of displaced tea estate workers of Bombay Burma Trading Corporation Limited (“BBTCL”).

The Court considered reports submitted by the Central Empowered Committee (“CEC”) regarding widespread encroachments, illegal non-forestry activities and degradation of protected forest areas, including the Srivilliputhur-Megamalai Tiger Reserve (“SMTR”), Kalakad-Mundanthurai Tiger Reserve (“KMTR”) and Kanyakumari Wildlife Sanctuary. The CEC highlighted that approximately 4,601 (four thousand six hundred one) persons had encroached upon 5,072.653 (five thousand seventy-two point six five three) hectares of reserved forest land in Theni district, while 553 (five hundred fifty three) encroachers occupied 427.404 (four hundred and twenty-seven point four zero four) hectares in the Kanyakumari Wildlife Sanctuary.

The Supreme Court observed that protection of forests, wildlife and ecological systems constitutes a constitutional obligation flowing from Articles 21, 48A and 51A(g) of the Constitution of India. It emphasised that conservation measures must adopt an eco-centric approach and that ecological restoration of degraded ecosystems is an essential obligation of constitutional courts.

While acknowledging the humanitarian concerns involved in relocating long-term occupants of forest areas, including economically vulnerable communities and former workers, the Supreme Court held that rehabilitation cannot become a ground for indefinitely postponing legally mandated eviction and restoration measures.

Accordingly, the Supreme Court issued the following directions:

• The State Government must prepare and implement a time-bound, division-wise encroachment eviction plan with defined timelines, measurable milestones and officer-level accountability, and submit the plan to the CEC within one month.
• The eviction plan must provide for physical eviction, rehabilitation wherever applicable, legal action against wilful violators and post-eviction ecological restoration.
• Disciplinary and legal action shall be initiated against 118 (one hundred eighteen) identified serving or retired government employees found to be encroachers, with consideration of environmental restitution and restoration charges payable to the Tamil Nadu State CAMPA fund.
• A moratorium shall be imposed on welfare schemes, public utilities, transport facilities, electricity supply and infrastructure support within encroached forest areas to prevent legitimisation of illegal occupation.
• No new non-forestry activity or diversion proposal under the Forest (Conservation) Act, 1980 shall be approved within the Agasthyamalai landscape until encroachments are removed and illegal infrastructure is dealt with in accordance with law.
• Government establishments, facilities and unauthorised infrastructure situated within forest areas, including SMTR, shall be discontinued, relocated, dismantled and removed within six months.
• Illegal resorts, commercial establishments and tourism-related infrastructure operating within forest areas shall be made non-operational and dismantled, with unauthorised electricity connections and transmission lines removed.
• The Forest Survey of India must undertake survey, demarcation, geo-referencing and digitisation of the boundaries of KMTR, SMTR and Kanyakumari Wildlife Sanctuary within six months and submit reports on encroachments.
• The State Government must examine, in consultation with the CEC, the retention, relocation or removal of infrastructure belonging to BBTCL within KMTR.
• Monthly compliance reports must be submitted by the States to the CEC, which must conduct ground verification and submit quarterly status reports before the Supreme Court.
• State Law Department must track all pending encroachment court cases and report their status to the Court.
• Officials who approved or permitted illegal construction in forest areas (not just the encroachers) face disciplinary, penal, and criminal action.
• Kerala must hand over all original land records/maps of Kanyakumari Sanctuary to Tamil Nadu within 3 (three) months.
• Forest, police, and revenue officials doing the eviction work are protected from prosecution for genuine, good-faith actions.
• If Tamil Nadu fails to comply, paramilitary forces may be deployed to carry out the evictions.

The Court directed the CEC to submit its report in a sealed cover by August 28, 2026, and listed the matter for further hearing on September 1, 2026.

 

Supreme Court upholds one-time regularisation window for EC but strikes down perpetual ex post facto clearance regime

The Supreme Court, in its judgement dated July 29, 2026, in Vanashakti vs. Union of India[5], reaffirmed that prior EC under the Environmental Impact Assessment Notification, 2006 is mandatory before commencing projects requiring environmental approval. The Supreme Court held that projects commenced without prior EC cannot ordinarily be regularised through post facto approvals, as such an approach would undermine the objectives of environmental protection and the precautionary principle. The proceedings concerned the validity of the Notification dated March 14, 2017, which provided a one-time window for regularisation of projects that had commenced operations without obtaining prior EC, and the Office Memorandum dated July 7, 2021, which established a continuing mechanism for granting ex post facto ECs. The petitioners challenged both measures as being contrary to the Environment (Protection) Act, 1986 and the Environmental Impact Assessment Notification, 2006. The Supreme Court held that the Central Government possesses the power under Section 3 of the Environment (Protection) Act, 1986, read with Section 21 of the General Clauses Act, 1897, to issue a narrowly tailored, one-time amnesty notification in exceptional circumstances and in the larger public interest. Accordingly, the Court upheld the validity of the March 14, 2017 Notification as a limited legislative measure intended to regularise past violations within a specified timeframe.

However, the Supreme Court declared the Office Memorandum dated July 7, 2021 to be ultra vires, holding that an administrative instruction cannot create a perpetual regime permitting ex post facto ECs. The Court held that the Office Memorandum was inconsistent with the Environmental Impact Assessment Notification, 2006 and violative of Articles 14 and 21 of the Constitution of India, and accordingly quashed it prospectively. The Supreme Court further directed that no fresh applications for ex post facto ECs shall be entertained under either the March 14, 2017 Notification or the July 7, 2021 Office Memorandum. While protecting ECs already granted, the Court directed that pending applications be decided in accordance with the directions issued in the judgement. The Court also overruled its earlier decisions in Pahwa Plastics Private Limited v. Dastak NGO and D. Swamy v. Karnataka State Pollution Control Board to the extent they upheld the validity of the July 7, 2021 Office Memorandum, while clarifying that its power under Article 142 of the Constitution to grant appropriate relief in exceptional cases remains unaffected.

 

Supreme Court modifies restrictions on industrial approvals in the Taj Trapezium Zone

The Supreme Court, in its order dated July 23, 2026, in In Re: Regulation of Industries in the Taj Trapezium Zone[6], Suo Motu Writ Petition modified its earlier directions restricting the establishment, expansion and relocation of industries within the Taj Trapezium Zone (“TTZ“), permitting the TTZ Authority to process pending and future applications subject to enhanced environmental safeguards and expert oversight.

The matter arose from an application filed by the TTZ Authority seeking modification of the Supreme Court’s order dated October 14, 2024, which prohibited the establishment of new industries or expansion of existing industries within the TTZ without prior leave of the Court. The TTZ Authority submitted that approximately 410 (four hundred ten) applications relating to the establishment, expansion and relocation of predominantly small and medium-scale industries remained pending due to the blanket restriction, despite the preparation of sector-specific guidelines for certain industries and the submission of an interim report by the National Environmental Engineering Research Institute (“NEERI“) on the classification of non-polluting industries.

The Supreme Court observed that although the Vision Document for the TTZ, the Cumulative Impact Assessment Study and the final report on the definition of “non-polluting industries” were still under preparation, the pendency of these exercises should not indefinitely delay the consideration of industrial applications. The Court emphasised that the precautionary principle must continue to guide all decisions affecting the environmentally sensitive TTZ while ensuring that legitimate economic activity is not unnecessarily impeded.

Accordingly, the Supreme Court permitted the TTZ Authority to process pending and future applications, subject to the participation of expert representatives from the CEC and NEERI in every meeting. The Court directed that applications objected to by either expert body must continue to require prior approval of the Supreme Court, whereas applications unanimously approved by the TTZ Authority, CEC and NEERI may be processed in accordance with law without further judicial approval. The Court further directed that all decisions be uploaded on the CEC’s website to facilitate public objections and suggestions, which must be considered before finalisation. These directions will remain operative until the Vision Document, the Cumulative Impact Assessment Study and the final classification of non-polluting industries are completed.

 

National Green Tribunal

NGT upholds EC for Vadodara–Mumbai Expressway Phase I

The NGT, Western Zone Bench, Pune, in its judgment dated June 2, 2026, in Gujarat Khedut Samaj and Ors. v. Ministry of Environment, Forest and Climate Change and Ors.[7], has dismissed an appeal challenging the EC dated February 11, 2016, granted for Phase I of the Vadodara–Mumbai Expressway, thereby upholding the validity of the environmental approval. The appeal alleged procedural irregularities in the EC process, including deficiencies in public hearings, inadequate disclosure of draft environmental impact assessment reports, and concerns regarding the project’s impact on agricultural land, forests and local communities. After examining the matter, the Tribunal upheld the EC granted by the Ministry of Environment, Forest and Climate Change (“MoEFCC”) for the project. The judgement affirms the validity of the EC for the 274.022 (two hundred seventy-four point zero two two) km Phase I of the expressway spanning Gujarat, Dadra and Nagar Haveli and Maharashtra, allowing the project to proceed in accordance with the applicable environmental conditions and statutory requirements.

 

NGT declines compensation in suo motu proceedings arising from illegal firecracker manufacturing incident

The NGT, in its order dated July 16, 2026, in News Item Titled “Two Killed 3 Injured in Firecracker Explosion in Gonda” Appearing in the Times of India dated October 7, 2024, vs. Uttar Pradesh Pollution Control Board and Ors.[8], declined to award compensation in suo motu proceedings arising from a firecracker explosion in Gonda, Uttar Pradesh, holding that the deceased and injured persons were themselves engaged in the illegal manufacture of firecrackers at the time of the incident. The proceedings were initiated suo motu based on a news report regarding an explosion at an unauthorised firecracker manufacturing unit, which resulted in the death of three persons and injuries to others. During the proceedings, the Uttar Pradesh Pollution Control Board relied on the report of a joint inspection committee and the First Information Report, which revealed that the deceased and injured persons were actively involved in illegally manufacturing firecrackers in an abandoned building without the requisite authorisations.

The NGT took note of the inspection findings and the provisions of the Public Liability Insurance Act, 1991, particularly the definition of “owner” and the statutory liability imposed on persons handling hazardous substances. The Tribunal observed that, in the facts of the case, the deceased and injured persons themselves were the violators engaged in the unauthorised handling of hazardous substances and, therefore, the matter did not warrant the grant of compensation in the exercise of its suo motu jurisdiction. Accordingly, the NGT dismissed the original application and declined to issue any directions for payment of compensation.

 

NGT examines alleged dumping of Okhla landfill waste near the Yamuna and seeks compliance with Solid Waste Management Rules

The NGT, in News Item titled “Okhla Landfill Waste Dumped Near Yamuna” appearing in the Times of India dated April 2, 2026 vs. Municipal Corporation of Delhi & Ors.[9], took suo motu cognisance of a newspaper report alleging that legacy waste from the Okhla landfill was being transported and dumped on land near the banks of the River Yamuna at Madanpur Khadar, purportedly to expedite the clearance of the Okhla, Bhalswa and Ghazipur landfill sites. The Tribunal observed that the allegations raised substantial issues relating to compliance with environmental laws, including the Environment (Protection) Act, 1986, the Water (Prevention and Control of Pollution) Act, 1974, and the applicable regulatory framework governing solid waste management.

During the proceedings, the Central Pollution Control Board (“CPCB“) submitted that the Solid Waste Management Rules, 2026 establish a comprehensive framework for the environmentally sound collection, transportation, processing, biomining and disposal of municipal solid waste, including legacy waste. CPCB further referred to its Guidelines for Disposal of Legacy Waste, 2019, which prescribe the scientific utilisation of screened waste fractions, testing of recovered bio-earth for heavy metals, and environmentally sound disposal of residual materials. CPCB also informed the Tribunal that biomining operations were underway at the Okhla, Bhalswa and Ghazipur landfill sites in accordance with the applicable regulatory framework.

The proceedings remain pending before the NGT for consideration of the responses filed by the concerned authorities and for examining whether the alleged dumping activities comply with the Solid Waste Management Rules, 2026 and other applicable environmental laws.

 

Regulatory updates

Advisory on emerging advanced artificial intelligence tools for vulnerability detection

The Securities and Exchange Board of India (“SEBI”), vide circular dated May 5, 2026, has constituted a task force, namely cyber-suraksha.ai, comprising representatives from market infrastructure institutions, qualified registrars and transfer agents, all qualified regulated entities, and other related stakeholders with the mandate to:

• closely examine the cybersecurity risks posed by Artificial Intelligence (“AI”) based models and devise a uniform mitigation strategy against the risks posed by such models;
• facilitate sharing of threat intelligence, best practices on vulnerability management, use cases and playbooks to respond to the threat vector;
• report on a priority basis, cyber incidents or malicious activities, significant attack vectors, information on vulnerabilities that may be relevant to strengthen the cybersecurity posture of the securities markets; and
• review the cybersecurity posture of the third-party application service providers including empanelled vendors.

The task force convened a meeting to review potential risks posed by AI platforms and to discuss mitigating measures and issued an advisory that should be read in conjunction with applicable SEBI circulars (including but not limited to the Cybersecurity and Cyber Resilience framework).

Key takeaway: Several Indian regulators are proactively addressing the threat of cyber risks by issuing the procedural guidelines. This advisory reflects SEBI’s stance in addressing emerging systemic cyber risks arising from advanced AI tools that can identify and potentially exploit vulnerabilities at unprecedented speed and scale. By constituting the ‘cyber-suraksha.ai’ task force, SEBI has institutionalised a coordinated, sector-wide approach to threat intelligence sharing and vulnerability management, recognising that in an interconnected securities market ecosystem, a breach at one node can cascade across the entire market infrastructure.

 

Delegation of powers to District Collectors for implementation of Solid Waste Management Rules, 2026

MoEFCC, vide notification dated May 18, 2026, has delegated the powers vested in the Central Government under Section 5 of the Environment (Protection) Act, 1986 to all District Collectors across the country for a period of 1 (one) year, pursuant to the directions of the Supreme Court in its order dated May 5, 2026, in Civil Appeal No. 6174 of 2023. The delegated powers are to be exercised exclusively for supervising, administering and implementing the Solid Waste Management Rules, 2026 within their respective jurisdictions. The notification further provides that the Central Government may revoke such delegation of powers in respect of District Collectors or itself exercise powers under Section 5 of the Environment (Protection) Act, 1986 where it considers such action necessary in the public interest.

Key takeaway: Solid-waste enforcement is now closer to the district level. Every District Collector holds Section 5 powers for one year to supervise and implement the Solid Waste Management Rules, 2026. Waste operators and local bodies should engage with the relevant Collector and keep compliance records ready. They should also account for MoEFCC’s power to revoke or re-assume the delegation.

 

Draft amendments to the Island Coastal Regulation Zone Notification, 2019

MoEFCC, vide draft notification dated May 26, 2026, has proposed amendments to the Island Coastal Regulation Zone (“ICRZ”) Notification, 2019 to permit the receipt and storage of certain petroleum products within Coastal Regulation Zone (“CRZ”) areas, excluding CRZ-IA. The proposed amendments have been issued following representations received from various State Coastal Zone Management Authorities and recommendations of the concerned Expert Appraisal Committees and the National Coastal Zone Management Authority. The draft proposes to amend Annexure II of the ICRZ Notification, 2019 by including Linear Alkyl Benzene, N-Paraffin and Carbon Black Feedstock in the list of petroleum products permitted to be received and stored within CRZ areas, excluding CRZ-IA.

Key takeaway: If finalised, the ICRZ proposal could permit the receipt and storage of LAB, N-Paraffin and CBFS in CRZ areas other than CRZ-IA, expanding options for coastal chemical logistics. Coastal operators and project counsel should assess affected sites and file objections or suggestions within 60 (sixty) days. Existing CRZ permissions will remain controlling until the proposal is final.

 

Aadhaar authentication notified for availing benefits under the Biogas Programme

The Ministry of New and Renewable Energy (“MNRE”), vide notification dated May 29, 2026, has notified Aadhaar authentication as the means of establishing the identity of beneficiaries for availing benefits under the Biogas Programme in accordance with Section 7 of the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016. The notification seeks to facilitate seamless delivery of Central Financial Assistance under the scheme by simplifying beneficiary identification and enhancing transparency in the disbursement process. Further, the notification provides that individuals seeking benefits under the Biogas Programme are required to undergo Aadhaar authentication or furnish proof of possession of an Aadhaar number. Individuals who have not been assigned an Aadhaar number are required to enrol for Aadhaar and may continue to avail benefits by producing the prescribed enrolment acknowledgement and alternative identity documents until an Aadhaar number is assigned. The notification further requires the Ministry and Programme Implementing Agencies to facilitate Aadhaar enrolment, undertake awareness measures, and adopt alternative authentication mechanisms, including one-time password based authentication and offline verification of Aadhaar credentials, where biometric authentication is unsuccessful.

Key takeaway: Biogas Programme benefits now require Aadhaar authentication or proof of possession of an Aadhaar number, but applicants awaiting an Aadhaar number may use enrolment evidence and prescribed identity documents. Beneficiaries and implementing agencies are directly affected. Implementing agencies must offer one-time password or offline alternatives, must not deny benefits to children, and must retain exception records to avoid payment delays or exclusion.

 

Draft amendments to the Ecomark Rules, 2024

MoEFCC, vide draft notification dated June 8, 2026, has proposed amendments to the First Schedule of the Ecomark Rules, 2024 to revise the criteria for grant of the Ecomark certification for specified product categories. The draft amendments seek to strengthen the environmental performance standards applicable to products by incorporating updated sustainability, resource efficiency, and regulatory compliance requirements.

Some of the key amendments proposed are as follows:

• the criteria for grant of Ecomark in respect of paints, varnishes and powder coatings have been revised to prescribe limits on volatile organic compounds, heavy metals, preservatives and hazardous substances, require the use of recyclable, reusable or biodegradable packaging, mandate display of critical ingredients and QR code-based product information, and require compliance with Extended Producer Responsibility (“EPR”) obligations, use of 25% renewable energy and possession of a valid ISO 14001:2015 certification;
• the revised criteria for batteries require manufacturers to obtain registration under the Battery Waste Management Rules, 2022, comply with EPR obligations under the battery and plastic waste management frameworks, increase the use of domestically recycled lead in lead-acid batteries, ensure environmentally sound waste disposal and recycling, adopt energy-efficient manufacturing practices and maintain ISO 14001:2015 certification; and
• the criteria for paper products have been updated to promote the use of recycled and sustainably sourced raw materials, require elemental chlorine-free or total chlorine-free bleaching processes, prescribe limits for adsorbable organically bound halogens and pentachlorophenol, prohibit the use of carcinogenic or mutagenic biocides, and require compliance with the relevant Bureau of Indian Standards (“BIS”) specifications for paper products intended for food contact applications.

Key takeaway: The draft would make Ecomark certification materially harder by tying paints, batteries, paper, wood substitutes, fire extinguishers and coir to tighter product and facility criteria. Manufacturers seeking certification should test their formulations, review consent requirements and assess packaging, EPR compliance and ISO 14001 readiness. They should also submit comments within 60 (sixty) days. The changes are not yet final.

 

Extension of compliance timelines under the SEBI (Merchant Bankers) framework

SEBI, vide circular dated June 11, 2026, has extended the timelines for compliance with certain provisions of its circular dated January 2, 2026, issued pursuant to the SEBI (Merchant Bankers) (Amendment) Regulations, 2025. The revised timelines have been introduced in view of representations received from the industry highlighting operational challenges in implementing the Separate Business Unit (“SBU”) framework and seeking alignment of the compliance timelines for net worth and liquid net worth requirements with the end of the financial year.

Some of the key provisions are as follows:

• the timeline for transfer of activities to SBUs under Regulation 13A of the SEBI (Merchant Bankers) Regulations, 1992 and compliance with Clause 11.2.10 of the January 2, 2026, circular has been extended from July 3, 2026, to December 31, 2026;
• the Phase I and Phase II timelines for compliance with the prescribed net worth and liquid net worth requirements have been extended from January 2, 2027, and January 2, 2028, to March 31, 2027, and March 31, 2028, respectively; and
• the timeline for intimation to SEBI regarding categorisation as a Category I or Category II Merchant Banker has been extended from January 2, 2027, to March 31, 2027.

The circular further clarifies that all other provisions of the January 2, 2026, circular will remain unchanged and continue to be applicable to merchant bankers.

Key takeaway: Merchant bankers have more time to implement the new SBU and capital requirements, reducing immediate restructuring pressure without changing the underlying obligations. Registered merchant bankers must transfer activities to SBUs and comply with Clause 11.2.10 by December 31, 2026. They must meet the net-worth and liquid-net-worth requirements in Phases I and II by March 31, 2027 and March 31, 2028, respectively, and notify SEBI of their Category I or Category II status by March 31, 2027.

 

 

PM Electric Drive Revolution in Innovative Vehicle Enhancement (PM E-DRIVE) Scheme notified for electric ambulances

The Ministry of Heavy Industries, vide notification dated June 17, 2026, has notified the operational framework for extending demand incentives to electric ambulances (“e-ambulances”) under the PM E-DRIVE Scheme. The notification prescribes the eligibility conditions, demand incentive structure, performance requirements and phased manufacturing programme applicable to pure electric ambulances, with the objective of promoting the adoption and domestic manufacturing of electric ambulances in India.

Some of the key provisions are as follows:

• demand incentives have been made available for eligible patient transport vehicles (Type B), basic life support ambulances (Type C) and advanced life support ambulances (Type D) complying with the prescribed automotive industry standards, while Central and State Government departments, agencies and public sector undertakings are also eligible to avail such incentives;
• the demand incentive for eligible e-ambulances will be the lower of INR 30,000 (Indian Rupees thirty thousand) per kilowatt-hour of battery capacity or 35% of the ex-factory price of the vehicle, with a total financial outlay of INR 500 crore (Indian Rupees five hundred crore) for supporting the deployment of notified e-ambulances during the financial years 2026–27 and 2027–28;
• the minimum performance and efficiency criteria is prescribed, including range, energy consumption, maximum speed, acceleration and gradeability requirements, for different categories of e-ambulances;
• manufacturers are required to comply with the prescribed phased manufacturing programme, which mandates progressive domestic manufacturing of specified components, including traction battery packs, battery management systems, traction motors, vehicle control units, charging systems and other key electric powertrain components; and
• eligible e-ambulances are required to be supported by a minimum warranty of 5 (five) years or 1,25,000 (one lakh twenty-five thousand) kilometres, whichever is earlier, in respect of the battery, motor and vehicle.

Key takeaway: PM E-DRIVE provides demand support for pure-electric Type B–D ambulances at the lower of INR 30,000 (Indian Rupees thirty thousand) per kWh or 35% of the ex-factory price. Original equipment manufacturers must meet the applicable automotive industry standards and performance standards, satisfy phased domestic-manufacturing milestones that take effect in September 2026 and March 2027, and provide a minimum warranty of 5 (five) years or 125,000 (one hundred twenty five thousand) km, whichever is earlier. Procurers still need separate operational approval under the NAS/NHM guidelines.

 

Mandatory upload of goods and services tax e-invoices for generation of EPR certificates under the Battery Waste Management Rules, 2022

The Central Pollution Control Board, vide advisory dated June 19, 2026, has mandated that recyclers registered under the Battery Waste Management Rules, 2022 upload Goods and Services Tax (“GST”) e-invoices for the sale of recovered key battery metals and metal compounds on the Battery Waste EPR Portal with effect from July 1, 2026. The advisory has been issued to strengthen the verification process for generation of EPR certificates and ensure traceability of transactions undertaken by registered recyclers. The advisory further provides that recyclers not having arrangements for GST e-invoicing must obtain the necessary registration and comply with the applicable GST e-invoicing requirements. It also clarifies that EPR Certificates generated on the basis of sales invoices other than GST e-invoices will not be considered after June 30, 2026. Further, any EPR certificates generated on the basis of non-GST e-invoices beyond the prescribed date will be treated as false certificates and constitute non-compliance under the Battery Waste Management Rules, 2022.

Key takeaway: Battery recyclers risk losing EPR certificates if sales of recovered key battery metals and metal compounds are not supported by GST e-invoices after June 30, 2026. EPR certificates generated on the basis of non-GST e-invoices after that date will be treated as false certificates. Registered recyclers must obtain GST e-invoicing capability immediately and upload the invoices to the Battery Waste EPR Portal from 1 July 2026.

 

Clarification on provisional commissioning of renewable power projects under the Approved List of Models and Manufacturers framework

MNRE, vide Office Memorandum dated June 23, 2026, has issued a clarification to its Office Memorandum dated May 25, 2026, regarding the Approved List of Models and Manufacturers (“ALMM”) framework for renewable power projects other than rooftop solar projects. The clarification has been issued to address concerns regarding delays in commissioning utility-scale and commercial and industrial renewable power projects arising from the implementation of the ALMM List-II requirements. The Office Memorandum provides that renewable power projects, other than rooftop solar projects, may be provisionally commissioned where such projects were installed prior to June 1, 2026, but could not be commissioned before that date due to valid reasons, have applied through the designated MNRE portal seeking exemption from ALMM List-II requirements, and are awaiting a final decision on such application. The clarification seeks to prevent stranded renewable energy capacity while ensuring that the grant of provisional commissioning remains subject to the final outcome of the exemption application under the ALMM framework.

Key takeaway: Eligible utility-scale and commercial and industrial projects installed before June 1, 2026 can avoid stranded capacity through provisional commissioning, but only if a valid reason for the delay is documented, an ALMM List-II exemption application is pending and ALMM List-I modules are used. Developers and commissioning authorities had one month from June 23, 2026 to complete the commissioning. This window did not extend the June 1, 2026 effective date for ALMM List-II.

 

Ministry of Mines notifies commencement of Jan Vishwas amendments to MMDR Act

The Ministry of Mines vide notification dated June 23, 2026, has notified August 1, 2026, as the date on which the provisions of the Jan Vishwas (Amendment of Provisions) Act, 2026, relating to the Mines and Minerals (Development and Regulation) Act, 1957 (“MMDR Act”), will come into force. The notification brings into effect the amendments specified against serial number 27 of the Schedule to the Jan Vishwas (Amendment of Provisions) Act, 2026, as they relate to the MMDR Act.

Key takeaway: The MMDR Act related provisions listed under serial number 27 of the Jan Vishwas (Amendment of Provisions) Act, 2026 take effect on August 1, 2026 and will change the applicable compliance framework for mining and mineral businesses. Operators and counsel should identify affected permits, activities and enforcement procedures before commencement so that filings and internal controls reflect the new regime.

 

Draft amendments to the Greenhouse Gases Emission Intensity Target Rules, 2025

MoEFCC, vide draft notification dated June 26, 2026, has proposed amendments to the Greenhouse Gases Emission Intensity Target Rules, 2025 issued under the Carbon Credit Trading Scheme, 2023. The draft amendments seek to expand the compliance framework by prescribing Greenhouse Gas (“GHG”) emission intensity targets for obligated entities in the iron and steel sector. The draft proposes to insert a Third Schedule in the Greenhouse Gases Emission Intensity Target Rules, 2025 specifying the baseline GHG emission intensity for the financial year 2023–24 and the corresponding emission intensity targets for the compliance years 2025–26 and 2026–27 for identified obligated entities in the iron and steel sector. The proposed targets form part of the compliance mechanism under the Carbon Credit Trading Scheme, 2023 and are intended to facilitate phased reduction in GHG emission intensity by the notified entities.

Key takeaway: The draft would bring the listed iron-and-steel entities into the Carbon Credit Trading Scheme’s emission-intensity regime, using 2023–24 baselines and setting targets for 2025–26 and 2026–27. Affected plants should validate emissions and production data, assess abatement costs and credit exposure, and submit comments within 60 (sixty) days. The targets will apply only after final publication.

 

Electric Vehicles Policy, 2026

The Transport Department, Government of National Capital Territory of Delhi, vide notification dated June 30, 2026, has notified the Delhi Electric Vehicles Policy, 2026 with effect from July 1, 2026. The policy will remain in force until March 31, 2030, and seeks to accelerate the adoption of electric vehicles (“EVs“) through purchase and scrapping incentives, expansion of charging and battery swapping infrastructure, and measures to promote clean mobility and improve air quality in Delhi.

Some of the key provisions are as follows:

• the policy provides purchase incentives for eligible electric two-wheelers, electric auto-rickshaws and electric goods vehicles, with the quantum of incentives reducing progressively over the first three years of the policy. Purchase incentives will be disbursed through direct benefit transfer to eligible beneficiaries for vehicles registered in Delhi, subject to compliance with the prescribed eligibility conditions and empanelment of vehicle models by the Model Approval Committee;
• scrapping incentives have been introduced for replacement of eligible BS-IV and below two-wheelers, three-wheelers, passenger cars, goods carriers and Gramin Sewa vehicles with new electric vehicles, subject to specified conditions, including purchase within six months of issuance of the Certificate of Deposit from an authorised vehicle scrapping facility;
• all eligible electric vehicles registered in Delhi will continue to receive exemption from road tax and registration fees, while electric passenger cars with an ex-showroom price exceeding INR 30,00,000 (Indian Rupees thirty lakh) will not be entitled to such exemptions. The policy also grants a 10 (ten)-year exemption from no-entry restrictions to the first 1,000 (one thousand) eligible privately owned electric N2 category trucks registered in Delhi within the prescribed timeline;
• the policy designates Delhi Transco Limited as the nodal agency for planning and implementation of public EV charging and battery swapping infrastructure and provides for the establishment of a single-window clearance mechanism, development of a dedicated digital portal and constitution of a High-Powered Committee to oversee deployment of charging infrastructure across the National Capital Territory of Delhi; and
• the policy also encourages the establishment of public, community and private charging infrastructure by DISCOMs, private entities, real estate developers, Resident Welfare Associations and other stakeholders, while promoting grid readiness, battery swapping infrastructure and energy storage systems to support large-scale EV adoption.
• the policy prescribes phased electrification mandates for new vehicle registrations in Delhi, permitting only electric three-wheelers (L5 category) and electric N1 goods carriers for new registration with effect from January 1, 2027, and only electric two-wheelers for new registration with effect from April 1, 2028, while the Government of NCT of Delhi has expressed its intention to introduce similar electrification mandates for four-wheelers in the future.
• fleet aggregators and delivery service providers operating in Delhi are prohibited from inducting new conventional internal combustion engine vehicles running purely on diesel or petrol into their existing four-wheeler light commercial/goods vehicle and two-wheeler fleets with effect from January 1, 2026, subject to a transitional allowance permitting induction of BS-VI compliant two-wheelers into the existing fleet until December 31, 2026
• the policy establishes a dedicated Electric Vehicle Fund under the Transport Department, to be sourced from state budgetary allocations, Central and State Government schemes and grants, the Air Ambience Fund, Environment Compensation Charge, the PM E-DRIVE Scheme, cess and taxes, and constitutes a Delhi EV Apex Committee under the chairpersonship of the Minister (Transport) to oversee implementation of the policy, approve operational guidelines and manage the EV Fund.

Key takeaway: Delhi’s EV Policy bars fleet aggregators and delivery service providers from inducting new conventional vehicles running solely on petrol or diesel into their existing fleets of four-wheeler light commercial vehicles, four-wheeler light goods vehicles and two-wheelers. BS-VI two-wheelers may be inducted into those fleets only through December 31, 2026. New L5 and N1 registrations will be electric-only from January 1, 2027, and new two-wheeler registrations will be electric-only from April 1, 2028. Operators must align their fleet and charging plans accordingly.

 

 

Extension of self-certification framework for high-capacity solar photovoltaic inverters

MNRE, vide notification dated July 3, 2026, has extended the implementation timeline for the Solar Systems, Devices and Components Goods Order, 2025 in respect of Solar Photovoltaic (“SPV”) inverters having a capacity exceeding 200 (two hundred) kilowatts (“kW”). The extension has been granted in view of the limited availability of testing facilities and to provide manufacturers additional time to comply with the mandatory registration requirements under the BIS framework.

The notification provides that manufacturers of SPV inverters with a capacity exceeding 200 (two hundred) kW may continue to supply such products on the basis of self-certification until December 31, 2026, or until further orders, whichever is earlier. The extension is subject to the condition that manufacturers possess valid International Electrotechnical Commission certificates corresponding to the applicable Indian Standards prescribed under the Solar Systems, Devices and Components Goods Order, 2025, along with test reports issued by accredited testing laboratories. The notification seeks to facilitate a smooth transition to the mandatory compliance framework while addressing constraints arising from limited testing infrastructure.

Key takeaway: Supply of SPV inverters above 200 (two hundred) kW may continue on self-certification until December 31, 2026 or until the Government issues an earlier further order, whichever occurs first. This preserves near-term deliveries but does not remove the applicable BIS requirements. Manufacturers must hold the specified International Electrotechnical Commission certificates and accredited-laboratory reports and use the extension to complete the compulsory registration process.

 

 

Amendments to the Minerals (Evidence of Mineral Contents) Rules, 2015

The Ministry of Mines, vide notification dated July 3, 2026, has notified the Minerals (Evidence of Mineral Contents) Amendment Rules, 2026, amending the Minerals (Evidence of Mineral Contents) Rules, 2015. The amendments seek to introduce a definition for high purity quartz and revise the mineral classification framework applicable to the exploration and assessment of quartz, felspar and mica deposits.

Some of the key amendments are as follows:

• “High purity Quartz” has been defined as quartz having silicon dioxide (SiO₂) content exceeding 99.99% and total impurities below 50 parts per million;
• Schedule I has been amended to distinguish quartz, felspar and mica deposits occurring in veins and pegmatites based on whether such deposits are associated with minerals specified in Part D of the First Schedule or the Seventh Schedule to the Mines and Minerals (Development and Regulation) Act, 1957, or with high purity quartz; and
• Schedule II has been amended to include a separate exploration category for quartz, felspar and mica deposits occurring in pockets, lenses, veins and pegmatites that are not associated with minerals specified in Part D of the First Schedule or the Seventh Schedule to the Mines and Minerals (Development and Regulation) Act, 1957, or with high purity quartz.

Key takeaway: Evidence of mineral content will now determine whether quartz, felspar and mica deposits fall into different exploration categories. High-purity quartz is defined as quartz with SiO₂ content above 99.99% and total impurities below 50 (fifty) ppm, and associated deposits are classified separately. Exploration applicants should update their sampling, assay and geological records immediately.

 

Amendment to the Natural Gas (Supply Regulation) Order, 2026

The Ministry of Petroleum and Natural Gas, vide order dated July 4, 2026, has notified amendments to the Natural Gas (Supply Regulation) Order, 2026 issued under the Essential Commodities Act, 1955. The amendments have been introduced in view of the easing of disruptions in Liquefied Natural Gas (“LNG”) shipments through the Strait of Hormuz following the commencement of ceasefire and resumption of sea traffic, thereby reducing the need for regulatory measures relating to allocation and diversion of natural gas supplies. Paragraphs 2 to 6 of the Natural Gas (Supply Regulation) Order, 2026, which provided for regulation of production, sector-wise allocation, diversion, distribution, disposal, acquisition, use and consumption of natural gas, including LNG and re-gasified LNG, have been omitted. Consequently, the existing paragraph 7 has been renumbered as paragraph 2.

Key takeaway: Removing paragraphs 2–6 of the Natural Gas (Supply Regulation) Order withdraws temporary controls on the production, sector allocation and diversion of natural gas, LNG and re-gasified LNG. Suppliers and large consumers should revisit their nominations, contracts and contingency plans and re-check the requirements under the renumbered paragraph 2.

 

Amendment to the list of white category sectors under the Air (Prevention and Control of Pollution) Act, 1981 and the Water (Prevention and Control of Pollution) Act, 1974

The Central Government vide notification dated July 8, 2026, has substituted the Schedules to the notifications dated November 12, 2024, issued under the Air (Prevention and Control of Pollution) Act, 1981 and the Water (Prevention and Control of Pollution) Act, 1974, revising the list of sectors classified under the white category. The amended Schedules include 87 (eighty-seven) sectors comprising low-pollution activities such as assembly-based manufacturing, dry process industries, renewable energy projects, small-scale processing units, repair and servicing activities, and other sectors with minimal environmental impact. The amendments further identify certain sub-sectors transitioned from the existing green category to the white category, thereby updating the industrial classification framework based on pollution potential under both legislations.

Key takeaway: Operators carrying out any of the 87 (eighty seven) listed low-pollution activities may qualify for white-category treatment under both the Air (Prevention and Control of Pollution) Act, 1981 and the Water (Prevention and Control of Pollution) Act, 1974, potentially avoiding prior consent and reducing approval lead times. Operators must verify that their actual processes, capacity, fuel use and effluent profile are consistent with the applicable schedule. They must also make any required intimation to the SPCB or PCC and continue to comply with waste and discharge controls.

 

Amendments to the EIA Notification, 2006 for continuity of EC process

MoEFCC, vide notification dated July 13, 2026, has notified amendments to the EIA Notification, 2006 to ensure continuity in the EC process in cases where the State Level Environment Impact Assessment Authority (“SEIAA”) and State Level Expert Appraisal Committee (“SEAC”) become non-functional due to expiry of their tenure or other circumstances. The amendments seek to prevent delays in appraisal of projects by establishing interim mechanisms for undertaking the functions of SEIAA and SEAC until their reconstitution.

Some of the key amendments are as follows:

• the tenure of SEIAA and SEAC has been extended from three years to four years, with the process for their reconstitution required to be initiated by the concerned State Government 6 (six) months prior to the expiry of their tenure;
• a SAEIA shall be constituted by the Central Government for each State or Union Territory, comprising ex-officio members as considered appropriate, to discharge the functions of SEIAA where the SEIAA is non-functional due to expiry of its tenure or other circumstances. The SAEIA may function for a maximum period of 6 (six) months, with a further extension of up to 6 (six) months;
• a Standing Committee on Environment Impact Appraisal (“SCEIA”) shall be constituted by the Central Government for each State or Union Territory to discharge the functions of SEAC where the SEAC is non-functional due to expiry of its tenure or other circumstances. The SCEIA may function for a maximum period of 6 (six) months, with a further extension of up to 6 (six) months;
• the requirement for consideration of Category ‘B’ projects at the Central level in the absence of a duly constituted SEIAA or SEAC has been removed, in view of the establishment of SAEIA and SCEIA as interim mechanisms;
• the composition and eligibility criteria for Expert Appraisal Committees (“EACs”) and SEACs have been revised, including requirements relating to qualifications, experience, maximum membership, tenure of members and appointment of Chairpersons and Member Secretaries; and
• the maximum tenure of a member, including the Chairperson, of EACs, SEACs and SEIAAs has been prescribed as 2 (two) terms of 4 (four) years each, subject to the condition that the member is not more than 70 (seventy) years of age at the time of appointment. In exceptional cases, where there is a paucity of experts in a particular field, the maximum age limit may be extended up to 75 (seventy-five) years.

Key takeaway: EC processing for Category B projects should no longer stop or shift automatically to the Centre when a State SEIAA or SEAC becomes non-functional. The SAEIA or SCEIA can act for up to six months, with one possible 6 (six) month extension. Project proponents and State authorities should build the 4 (four) year tenure and the requirement to initiate reconstitution 6 (six) months before expiry into their EC schedules. They should use the interim bodies where needed.

 

Amendment to the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016

MoEFCC, vide notification dated July 16, 2026, has notified the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2026, amending Schedule I of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The notification has been issued without prior public consultation in exercise of the powers under Rule 5(4) of the Environment (Protection) Rules, 1986, as the Central Government considered it to be in the public interest to dispense with the notice requirement.

The amendment omits “Brine sludge” from the list of hazardous wastes generated under the process of “Production of caustic soda and chlorine” specified against Serial No. 16 of Schedule I to the 2016 Rules. The amendment came into force on the date of its publication in the Official Gazette.

Key takeaway: Upon publication in the Official Gazette, caustic-soda and chlorine producers no longer have “brine sludge” listed in Schedule I as a hazardous waste. This change may reduce hazardous-waste authorisation and manifest burdens for that waste stream. Compliance teams must recheck classification and disposal arrangements without relaxing safe handling or other applicable environmental controls.

 

Model Service Agreement issued for “Electrolyser as a Service” under the National Green Hydrogen Mission

MNRE, vide Office Memorandum dated July 23, 2026, has published a Model Service Agreement for the “Electrolyser as a Service” (“EAAS“) business model under the National Green Hydrogen Mission (“NGHM“). The Model Service Agreement seeks to facilitate the adoption of green hydrogen by standardising contractual arrangements between project developers and consumers, reducing transaction costs and expediting contract negotiations.

Some of the key provisions are as follows:

• the Model Service Agreement has been developed for the EAAS model, under which technology providers establish, own and operate electrolytic hydrogen generation facilities at the consumer’s premises, thereby reducing the consumer’s upfront capital expenditure;
• the Model Service Agreement sets out standard industry practices relating to allocation of responsibilities between the parties, performance guarantees, threshold energy consumption parameters and risk allocation mechanisms for EAAS projects;
• the Model Service Agreement has been issued as a facilitative and reference document to promote consistency in contractual arrangements and improve ease of doing business under the NGHM; and
• the Office Memorandum clarifies that the Model Service Agreement is non-binding and that market participants, project developers and off takers remain free to negotiate, modify, add to or delete contractual provisions based on their commercial requirements, risk allocation preferences and project-specific technical considerations. The MNRE has further clarified that it shall not be liable for any legal or commercial disputes arising from agreements executed on the basis of the Model Service Agreement.

Key takeaway: MNRE’s EAAS model can reduce negotiation time and upfront capital requirements for on-site hydrogen projects, but it does not allocate risk by default. Developers and offtakers must tailor the performance, payment, permitting, utilities, safety, ownership and liability terms to their project. MNRE accepts no responsibility for disputes arising from agreements based on the model.

 

CPCB issues guidelines for collection, handling, storage and transportation of waste batteries

CPCB, in July 2026, issued the Guidelines for Collection, Handling, Storage and Transportation of Waste Batteries under the Battery Waste Management Rules, 2022. The guidelines prescribe operational and safety requirements for the environmentally sound collection, storage and transportation of waste batteries and are applicable to producers, recyclers, refurbishers, collection centres and entities engaged in the transportation of waste batteries.

Some of the key provisions are as follows:

• producers have been advised to establish effective collection mechanisms for waste batteries through take-back systems, collection centres, dealers, retailers, deposit refund schemes or buy-back arrangements, and to provide consumers with information regarding collection points, authorised recyclers or refurbishers and available incentive schemes;
• producers, recyclers and refurbishers may establish collection centres, which are required to obtain the applicable registrations, consents and authorisations from the concerned SPCBs or Pollution Control Committees (“PCCs”), maintain prescribed records and channelise waste batteries only to authorised recyclers or refurbishers;
• the guidelines prescribe detailed requirements for collection centres and drop points, including separate storage for different battery chemistries and categories, fire protection systems, personal protective equipment, emergency response measures, weighing and record-keeping facilities, restrictions on dismantling or processing activities, and periodic collection arrangements for waste batteries;
• producers, collection centres, recyclers and refurbishers may store waste batteries for a period not exceeding 90 (ninety) days, unless an extension is granted by the concerned SPCB or PCC, and are required to store batteries in accordance with prescribed safety measures, including segregation by battery type and chemistry, protection from heat and moisture, management of damaged or leaking batteries, spill containment systems and standard operating procedures for handling and movement of waste batteries; and
• the guidelines further prescribe operational requirements for the transportation of waste batteries, including appropriate packaging, labelling, documentation, handling and emergency preparedness measures, to ensure safe transportation and prevent environmental contamination during transit.

Key takeaway:

• Producers, recyclers and refurbishers setting up collection centres should obtain the applicable CTE, CTO and Hazardous Waste authorisation from the SPCB/PCC, submit the site plan for storage-capacity approval and file the previous financial year’s Form 4 annual return by June 30.
• Store batteries by type and chemistry in cool, dry, segregated, fire-protected areas with spill containment, trained personal protective equipment and inspection records, do not exceed 90 (ninety) days unless the SPCB/PCC grants an extension.
• Channelise waste only to authorised or registered recyclers/refurbishers; complete the Rule 19 manifest and transport authorisation, give required SPCB/PCC intimation and obtain transit-State notices and NOCs for interstate routes, with fire, spill, evacuation and accident-reporting controls in place.

 

CPCB issues guidelines for recycling of waste batteries

CPCB, in July 2026, has issued the Guidelines for Recycling of Waste Batteries (Lead Acid and Lithium-ion) under the Battery Waste Management Rules, 2022. The guidelines prescribe environmentally sound procedures for the recycling of lead-acid and lithium-ion batteries and lay down operational, environmental and safety requirements applicable to battery recycling facilities. Some of the key provisions are as follows:

• the guidelines prescribe the battery recycling value chain, including collection, transportation, storage, sorting, inspection, dismantling and recovery of valuable metals from waste batteries;
• detailed operational requirements have been specified for lead-acid battery recycling facilities, including infrastructure requirements, pollution control equipment, effluent treatment systems, emission standards, worker safety measures and procedures for minimising fugitive lead emissions;
• separate operational requirements have been prescribed for lithium-ion battery recycling facilities, including infrastructure for battery discharge, shredding, material separation, hydrometallurgical processing, pollution control and safe handling of black mass and recovered materials;
• recyclers are required to comply with prescribed emission and environmental standards, maintain records and submit returns in accordance with the Battery Waste Management Rules, 2022; and
• the guidelines also prescribe safety measures relating to storage, fire prevention, occupational health, emergency response and environmentally sound management of battery recycling operations.

Key takeaway:

• Recyclers should map facility upgrades by stream: lead-acid units above 5,000 (five thousand) MTA must install mechanical or automated battery breaking within 1 (one) year of the July 2026 guidelines and smaller units within 3 (three) years; lithium-ion units should provide dedicated discharge, shredding, separation and black-mass handling systems.
• Maintain covered, impervious storage; air pollution control system/effluent treatment plant, hoods, scrubbers and bag filters; fire protection, ventilation, personal protective equipment, training and occupational-health controls, and follow safe discharge and dismantling procedures. Monitor stack and work-zone emissions quarterly in the first year and at least annually thereafter through accredited laboratories, including online particulate matter, hydrogen fluoride and total organic carbon analysers for continuous lithium-ion processes.
• Register and maintain financial-year-wise procurement, recycling and recovered-material sales records on the Battery Waste EPR Portal, generate and transfer EPR certificates and submit quarterly returns; improper handling can trigger environmental compensation and immediate response, site assessment and remediation of contaminated soil, groundwater or sediment.

 

This Newsletter has been prepared by:

Vishnu Sudarsan Partner

Sugandha Somani Gopal Partner

Vihaan Pathak Associate

 

For more details, please contact km@jsalaw.com

 

[1] 2026 INSC 455

[2] Suo Motu Writ Petition (Civil) No. 10 of 2025

[3] Suo Motu Writ Petition (Civil) No. 2 of 2026

[4] Civil Appeal Nos. 6395-6397 of 2025

[5] 2026 INSC 761

[6] Suo Motu Writ Petition (Civil) No. 9 of 2026

[7] Appeal No. 44 of 2016 (WZ)

[8] Original Application No. 1237/2024

[9] Original Application No. 235 Of 2026