Hazardous Waste Management Annual Filing

Introduction

Uncontrolled hazardous waste is very dangerous to the people and it is dangerous to the environment. According to the Hazardous and Other Wastes (Management and Trans boundary Movement) Rules, 2016, industries and facilities producing, storing, transporting, or disposing of hazardous waste shall bear an obligation to submit annual returns to the State Pollution control Board (SPCBs), respectively.

Hazardous Waste Management Annual Filing is not merely a routine and a compliance job, it also indicates your environmental responsibility. We have along with us a team of compliance professionals, who can assist you with easy and error free annual filing so that you can abide by every clause of the law.

What is Hazardous Waste Management Annual Filing?

Hazardous Waste Management Annual Filing is a form filled with data pertaining to hazardous waste generation, handling, storage, treatment and disposal by those occupiers and operators of hazardous waste facilities once a year and it shall be submitted in the Form 4 in the Hazardous Waste Rules, 2016.

This filing contains some important details in form of:

• The type and amount of produced hazardous waste
• Rotations of storage, transport and disposal
• Contact information of the licensed recyclers or disposal areas safeguarding the environment takes precedence over other kinds of hazards or disasters.
• Measures of compliance made in one year
• The report assists the SPCBs to keep watch of waste-generating units and to implement safe practices.

What is the Need of Hazardous Waste Annual Filing?

• Legal Requirement:
  Under Rule 20 (2) of 2016 Rules, it has been made mandatory that all the various units of generating hazardous wastes are required to submit annual returns through Form 4 by 30th June of every financial year of the previous year.
• Avoid Penalties:
  Not filing the returns correctly and on time may result in fines, prosecution and even authorization.
• Audit Trail:
  Creating of a strong environmental audit background, CSR reporting and certification exercise (ISO 14001, ESG compliance) can be achieved through annual submission.
• Transparency & Environmental Stewardship:
  It shows your company in serious commitment to managing of waste and protecting the environment.

Eligibility Criteria

Hazardous Waste Annual Returns should be applied by the following entities:

• Manufacturing Industries (pharmaceutical, paint, chemicals, electronics etc)
• Hazardous Waste Generators (as given in Schedule I of the Rules)
• Hazardous waste Recyclers and Re-processors
• Common Hazardous Waste Treatment, Storage and Disposal Facilities (CHWTSDF)
• Recycling and E-Waste scrapers (in which hazardous subsets are treated)
• Acceptable handlers of hazardous waste
• In case you are working under the authority of Form 2 Authorization issued by SPCB as a hazardous waste handler, you need to pay annual returns.

Documents Required

The following is a list of documents that one is expected to bring with him or her when filing hazardous waste annual returns:

• Hazardous Waste Authorization Copy (Form 2)
• Data of waste production (amount, type)
• Form 10-Manifest records
• Description of means of disposal (co-processing, incineration, landfilling)
• Records of waste storage and waste treatment
• Transportation records
• The information of recyclers/re-processors to whom waste was sent to
• The prior year adjusted basis of stocks (Form 4)
• Udyam/MSME Certificate (in case of availability)
• PAN, GST, CIN information
• Authorized signatories Aadhar and PAN

Caution: The requirements are slightly different across the states.

Step-by-Step Process

• Step 1: Document review
  We look at the state of waste management you are doing, the validity and documentation of your authorization.
• Step 2: Data collection
  We assist you to collect all these necessary data found in your registers, manifest records and treatment logs.
• Step 3: Preparation of form 4
  Our professionals prepare the annual return Form 4 as it is stipulated in the Rules.
• Step 4: Compliance Check and Validation
  We ensure that you are filing as per SPCB norms and authorization conditions.
• Step 5: Submission via the Web
  Your filing is done through the state portal appropriate (OCMMS, XGN or SPCB website) and in hard copy form, should you be required to do so.
• Step 6: Recognition
  The business is filed and you get a filing acknowledgment, and we keep your filing in digital form to be used in auditing and renewals.

Timeline

Hazardous Waste Annual Return (Form 4) is required to be given by 30th June of every year on the previous financial year.

Usual service schedule:

• Data collection: 5–7 working days
• Return Drafting: 3–4 working days
• Submission & Filing: 1 to 2 working days
• Overall Duration: 7–10 business days (time required by the client)

Fees and Costs

Government Charges:

• No government fee is made on annual return filing, although the government may place punishment fee or environmental compensation fees on late or mistaken returns.

Included in our Professional Fees is:

• Assessment of hazardous waste licensing
• Information compiling and arrangement
• Filing and preparation of form 4
• Online submission and portal log in
• Confirming and advisory filing

Pricing: ₹4,000 to ₹20,000
It varies with the nature of the wastes, quantum of waste and SPCB system.

Penalties for Non-Compliance

• Punishments of the Environment Protection Act, 1986
• Withdrawal, or closure of hazardous waste authorization
• Environmental compensations by CPCB/SPCB
• Legal actions and show-cause notices
• Don’t gamble – never be late to comply with our professional assistance.

Why Choose Us?

• Domain Expertise: Our areas of expertise are Hazardous Waste, EPR, E-Waste and Plastic Waste filings.
• PAN India Service: We deal with state specific SPCB filings (OCMMS, XGN, DPCC etc.)
• On-Time Filings: This is assurance of filing ahead of the due date.
• Quality and Accuracy: We avoid rejection and penalty because we have proper document support and entries.
• Compliance Advisory: In addition to filing we assist you through suggested registers, manifests, and records of storage.
• Audit Ready: We prepare your records so they are ready to face inspections, ISO audits, and ESG reporting.