Classify the activity and material
Distinguish chemical synthesis, blending, repacking, storage, trading, plastic conversion and waste recovery. Record substance identity, concentration, maximum storage quantity and process conditions. A product name or broad industry description is not enough to determine the applicable permissions.
Keep raw materials, saleable products, by-products and wastes separately identified. Commercial value alone should not be used to assume a residue is outside the waste framework.
Build a site-specific permission map
Assess pollution consents, environmental clearance, hazardous-chemical duties and waste authorisations separately against the project and process. Use the actual instruments, schedules and current state-board procedures. The hazardous-chemical framework and hazardous-waste framework address different questions; one permission does not establish compliance with both.
Before increasing capacity, adding a substance or changing storage arrangements, check whether permissions and emergency arrangements need revision. Assign technical assessment to competent environmental and safety specialists.
Maintain evidence that operations can use
- Process flow, material balance, storage layout and substance inventory.
- Current safety data sheets, labels, worker training and emergency contacts.
- Consent conditions, monitoring reports, inspections and corrective-action records.
- Waste classifications, quantities, storage records and documented transfers to authorised recipients.
- Supplier specifications, customer restrictions and import or export documentation.
Connect plastics and packaging roles
A plastic-product manufacturer, packaging producer, importer and brand owner may have different responsibilities. Assess the actual packaging category and commercial role under the applicable plastic-waste and EPR framework. Keep packaging quantities and counterparty records connected to purchases, production and sales rather than estimating them only when a return is due.
Use finance records to support traceability
Reconcile input purchases, production yields, recoveries, finished stock and waste-disposal costs. Document job-work ownership and movements. Restrict access to proprietary formulations while making the required safety information available to the people who need it.
For example, introducing a solvent-based coating line can change emissions, chemical storage and waste streams even when the company sells the same finished product. The operational change should trigger a permission and control review before commissioning.
Scope of support
Kosha can help coordinate records, accounting, tax and compliance schedules. Process design, hazardous-material classification, emergency planning and statutory technical certification require the appropriate specialists; this page does not provide handling instructions.
Start with the site and the proposed change
Prepare a brief that compares the existing operation with the proposed one: processes, capacity, materials, storage areas and expected output streams. Attach an index of current permissions and their conditions, with unresolved observations clearly identified. A dated comparison helps the specialist see what has changed even when the business continues to sell the same product.
- Use pollution consent assessment for the scope of the existing consent and questions raised by a process or capacity change.
- Use hazardous-waste support for the relevant waste record and authorisation worklist. Identify each stream and its existing assessment; keep uncertain classifications open for the technical specialist.
- Use plastic packaging EPR support for the separately assessed packaging role and quantity records. Include packaging bought, supplied and returned, with the counterparties and reporting period identified.
Keep a submission register alongside the brief: document version, owner, date supplied, question raised and response received. A submitted application, an unanswered query and an issued permission should remain distinguishable in the project record.
References and official procedures
- MoEFCC hazardous substances management
- CPCB environmental rules and waste frameworks
- MoEFCC rules and regulations
Source material consulted 1 October 2026. Check the applicable instrument, period and portal instructions for the actual assignment.
Kosha.Services · Updated 2 October 2026

