Every time hazardous waste leaves your factory, it must go with a manifest: a multi-copy document that you as the sender start, the authorised transporter signs on collection, and the authorised facility signs on receipt. The copies, or the online record in states that have moved the manifest onto the board's system, prove the waste reached a TSDF, incinerator, co-processor or recycler. The Hazardous Waste Rules 2016 add storage limits, labelling, vehicle rules, interstate permissions, records and an annual return. If the chain breaks anywhere, the board treats the waste as yours.
This guide is for factory owners, plant heads and EHS managers who generate hazardous waste and want the paperwork and logistics to stand up when the board inspects. It covers what the manifest is and who signs which part, storage and packaging, the vehicle and the transporter, interstate movement, records and returns, and the mistakes that most often turn into show-cause notices. If you have not yet got your authorisation, start with our page on authorisation to handle hazardous waste.
If a load you sent has turned up dumped somewhere, read our guide on hazardous waste dumping and what happens next alongside this one.
हिंदी में सारांश
खतरनाक अपशिषà¥à¤Ÿ नियम 2016 के अनà¥à¤¸à¤¾à¤° फैकà¥à¤Ÿà¥à¤°à¥€ से निकलने वाले हर खतरनाक कचरे के साथ मैनिफेसà¥à¤Ÿ होना ज़रूरी है। मैनिफेसà¥à¤Ÿ à¤à¥‡à¤œà¤¨à¥‡ वाली फैकà¥à¤Ÿà¥à¤°à¥€ तैयार करती है, अधिकृत टà¥à¤°à¤¾à¤‚सपोरà¥à¤Ÿà¤° माल उठाते समय हसà¥à¤¤à¤¾à¤•à¥à¤·à¤° करता है और अधिकृत TSDF, इंसीनरेटर या रीसाइकà¥à¤²à¤° माल मिलने पर हसà¥à¤¤à¤¾à¤•à¥à¤·à¤° करता है। कई राजà¥à¤¯à¥‹à¤‚ में यह पà¥à¤°à¤•à¥à¤°à¤¿à¤¯à¤¾ अब बोरà¥à¤¡ के ऑनलाइन सिसà¥à¤Ÿà¤® पर होती है। कचरा सामानà¥à¤¯à¤¤à¤ƒ 90 दिन तक ही रखा जा सकता है, उस पर लेबल होना चाहिठऔर रिकॉरà¥à¤¡ रखना ज़रूरी है। दूसरे राजà¥à¤¯ में निपटान के लिठदोनों राजà¥à¤¯à¥‹à¤‚ के बोरà¥à¤¡ की अनà¥à¤®à¤¤à¤¿ चाहिà¤à¥¤ हर साल 30 जून तक वारà¥à¤·à¤¿à¤• रिटरà¥à¤¨ देना होता है। शà¥à¤°à¥ƒà¤‚खला कहीं à¤à¥€ टूटी तो ज़िमà¥à¤®à¥‡à¤¦à¤¾à¤°à¥€ फैकà¥à¤Ÿà¥à¤°à¥€ की मानी जाती है।
The essentials
One manifest per consignment
Every load of hazardous waste that leaves the site needs its own manifest, signed by sender, transporter and receiver.
Authorised hands only
Use only transporters and facilities authorised by the State Board for that category of waste.
Watch the 90 days
Waste can generally be stored on site for up to 90 days unless the board has allowed a longer period.
Crossing a state border
Sending waste to a facility in another state needs permission from the boards of both states.
Numbers must reconcile
Generated, stored and dispatched quantities must match your authorisation, stock register and closed manifests.
You stay responsible
Until the facility confirms receipt, the generator answers for the waste, including if the transporter dumps it.
What is a hazardous waste manifest and who has to fill it?
The manifest is the travelling record of a consignment of hazardous waste, in the form prescribed by the Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016 (Form 10). The sender, which is your factory as the occupier, fills in the waste details and signs it. The transporter signs when the waste is loaded, adding the vehicle details. The receiving facility signs when the waste arrives, recording what it actually received. Each party keeps its copy, and copies go back to the sender and to the State Board.
In many states the paper form has been replaced, or shadowed, by the board's online system: you generate the manifest, the transporter accepts it, and the TSDF or recycler closes it on receipt. The law is the same either way. A manifest that is generated but never closed means the board has no proof the waste arrived anywhere, and it will ask you, not the transporter, to explain.
Treat the manifest as evidence, not a formality. It is what you will show when the board compares your generation figures with what reached the facility, and it is the first thing asked for if a load turns up in a field. Blank manifests signed in advance, or quantities filled in later, are exactly what an inspection team looks for.
Is the waste we generate hazardous at all?
Start here, because the whole manifest system depends on getting the category right. The Rules list industrial processes and the wastes they produce that are hazardous by definition, such as sludge from electroplating, residues from distillation, spent solvents, used oil and spent catalysts. Other wastes become hazardous if they contain listed substances above set concentration limits. Your authorisation should name each waste category and the annual quantity, and those names should be the ones used on every manifest.
Disputes arise at the edges. A unit may say its ETP sludge is non-hazardous because the process is mild, or treat floor sweepings as ordinary garbage. If you want to treat a waste as non-hazardous, have it tested by a recognised laboratory against the limits in the Rules and keep the reports; do not decide by appearance. And never mix or dilute a hazardous waste to bring it under a limit, which the Rules treat as a breach in itself.
The manifest chain, party by party
| Party | What they do | What can go wrong |
|---|---|---|
| Sender (your factory) | Fills waste name and category, quantity, physical form, packaging, hazard information and receiving facility; signs; gives copies to the transporter; sends its copy to the board | Wrong category, estimated quantities, receiver not authorised for that waste |
| Transporter | Checks the load matches the manifest, signs on collection with vehicle details, carries the manifest and emergency information, delivers only to the named facility | Vehicle not authorised, driver not trained, load diverted or partly sold on the way |
| Receiver (TSDF, incinerator, co-processor, recycler) | Weighs and checks the waste, signs, records the quantity received, returns the copy to the sender, reports discrepancies to the board | Quantity mismatch, receipt never confirmed, manifest left open online |
| State Board | Receives copies, tracks open manifests, compares with authorisation and annual returns, inspects | Notices for unclosed manifests, unexplained gaps, storage beyond limits |
How to send a hazardous waste consignment correctly
Run this sequence for every dispatch. Most board notices come from skipping one of these steps on a busy day.
Check your authorisation first
Confirm the waste category and annual quantity are covered by your current authorisation, and that it has not expired. A new process or a new waste stream needs an amendment before it is sent out.
Choose the destination by waste type
Landfillable waste goes to a TSDF, incinerable waste to an incinerator or co-processor, recyclable waste only to a recycler authorised for that category. Keep the facility's current authorisation on file.
Pack and label
Use sound, compatible containers, closed and labelled with the waste name, category, hazard and your details. Do not mix incompatible wastes or dilute waste with non-hazardous material.
Weigh and record
Weigh the load on a calibrated scale, enter it in your stock register and keep the weighbridge slip. Estimated figures are hard to defend later.
Check the vehicle and driver
The transporter must be authorised, the vehicle must carry hazard labels and emergency information under the motor vehicle rules, and the driver should be trained for dangerous goods. Note the vehicle number on the manifest.
Complete the manifest
Fill your part, sign, and hand over the copies or generate it online. Never sign blank manifests or leave quantities to be filled in by someone else.
Close the loop
Follow up until the facility confirms receipt and the quantity matches. Report any discrepancy or non-arrival to the board in writing at once.
How long can hazardous waste be stored at the factory?
Generally for up to 90 days. The Rules let the board allow a longer period in particular cases, for example where the quantity is too small to send economically or the facility is not taking a particular waste, but that permission should be in writing. Waste lying in your yard for six months without it is a straightforward violation, and it is the easiest one for an inspector to prove.
The storage area itself is checked too. Boards expect a covered area with an impervious floor, containment so that spills do not reach drains or soil, segregation of incompatible wastes, labelled containers, fire safety and a register of what came in and what went out. Overflowing sludge bags at the back of the ETP, or drums stacked in the open through the monsoon, are what turn a routine inspection into a show-cause notice.
Plan dispatches around the 90 days, not around when the yard looks full. If your TSDF lifts only on fixed dates, keep a simple tracker of the oldest waste on site and its age. When Advocate B.K. Singh reviews a unit's file before a board hearing, the storage register is one of the first documents he asks for, because dates in it either support or contradict everything else the unit says.
What the transporter and the vehicle must have
The transporter needs authorisation from the State Board for collecting and transporting hazardous waste, and the vehicles must meet the dangerous goods provisions of the Central Motor Vehicles Rules 1989. In practice that means hazard class labels on the vehicle, an emergency information card carried in the cab, a driver who has been trained to handle dangerous goods, and basic safety equipment. Many boards and common facilities also require GPS tracking on vehicles carrying hazardous waste.
Do not assume a transporter is fine because a big TSDF uses him. Ask for his current authorisation, the list of vehicles covered and the waste categories he may carry, and keep copies. A transporter whose authorisation has lapsed is an unauthorised transporter, and handing waste to him puts you in breach whatever the manifest says.
Spills on the road are your problem too. The Rules require accidents during handling or transport to be reported immediately to the State Board, and the manifest and emergency card tell the police and fire service what they are dealing with. A transporter with no spill kit and a driver who cannot read the card are risks you have chosen.
Matching the waste to an authorised destination
| Kind of waste | Usual destination | Not acceptable |
|---|---|---|
| Landfillable waste such as ETP sludge after stabilisation, contaminated soil, residues | Secured landfill at a TSDF, after any pre-treatment the facility requires | Municipal landfill, open pits, brick kilns, filling low land |
| Incinerable waste such as distillation residues, organic sludges, contaminated packaging | Common or captive incinerator, or co-processing in a cement kiln with board approval | Burning in your own boiler without permission, open burning |
| Recyclable waste such as used oil, spent solvents, certain metal-bearing wastes | Recycler or re-refiner authorised for that category | Scrap dealers, unregistered recyclers, informal traders |
| Waste with an approved use as a resource | Utilisation under the board's permission and CPCB procedures | Informal reuse without permission |
| Empty containers and drums that held hazardous material | Decontamination by an authorised facility, then recycling | Sale to kabadis or for water storage |
TSDF membership and contracts with recyclers
Most generators of landfillable or incinerable waste become members of the common TSDF that serves their area, and the membership letter is usually one of the documents the board asks for when granting or renewing authorisation. Keep it current. A lapsed membership means you have nowhere lawful to send the waste, even if the facility kept lifting it informally.
For recyclables, put the arrangement in writing: the waste categories, the recycler's authorisation number and validity, who arranges transport, how quantities are weighed and how receipts are confirmed. A recycler offering to pay noticeably more than the market for used oil or spent solvent deserves a closer look, because the money often comes from selling the waste on informally.
Sending hazardous waste to a facility in another state
It is allowed, but not on your say-so. Where waste goes for disposal to a facility in another state, the Rules require the sender to obtain permission (a no objection) from the State Boards of both the sending and the receiving state, and boards of states the vehicle passes through are to be informed. Units near state borders, for example in the NCR where Delhi, Haryana and Uttar Pradesh meet, run into this often.
Apply well before you need to send the waste, because the receiving state's board may want to know why it should accept your waste and whether the facility has capacity. Keep the permissions on file with the manifests. Sending across a border without them is one of the faster ways to get a consignment held and a notice issued in two states at once.
Recyclables can raise their own questions, since a recycler's authorisation sets the categories and quantities it may accept from anywhere. Check that your consignment fits within those limits before dispatch. If the recycler is over its authorised capacity, your waste is going somewhere it should not.
Records, annual returns and what the board compares
Keep a running record of the hazardous waste you generate, store and send out, in the format the Rules prescribe, and file an annual return with the State Board by 30 June for the previous financial year. Keep the manifests, weighbridge slips, facility receipts and invoices for the same period together. They will be read together.
Boards increasingly do a simple mass balance. Your consent and authorisation say roughly how much of each waste your process should generate; your production figures and ETP running records say how much it probably did; your manifests and the facility's receipts say how much left. If the dispatched figure is far below what the process should produce, the board will ask where the rest went. A plausible answer, backed by production data, beats an angry one.
Tie your records to your consent conditions as well. A unit that expands production without updating its authorisation will generate more waste than it is allowed to, and the gap shows up in exactly this comparison. See our page on getting fresh consent before expanding.
The mistakes that most often lead to board notices
- Open manifests. Waste dispatched but receipt never confirmed by the facility, often because nobody followed up on the online system.
- Waste with a kabadi. Used oil, drums or spent solvent sold to a scrap dealer as if it were ordinary scrap.
- Storage beyond 90 days. Sludge bags or drums lying for months, often with no written extension from the board.
- Authorisation out of date. A new product, new process or higher production creating a waste stream the authorisation does not cover.
- Mismatched figures. Annual return, stock register and manifests telling three different stories.
- Unchecked transporter. A vehicle or transporter whose authorisation lapsed months ago.
- Mixing and dilution. Hazardous sludge mixed with ash, soil or garbage to make it look non-hazardous.
The sludge that was never generated
Here's a made-up example. A mid-sized chemical unit in an industrial area in Haryana is authorised to generate a fixed annual quantity of ETP sludge. On an inspection, the board's team finds that closed manifests for the previous year account for barely a third of that figure, while the storage area holds sludge bags dated more than five months back. It issues a show-cause notice asking where the remaining sludge went and why waste has been stored beyond 90 days.
The unit's first instinct is to say the transporter must have lost some manifests. Its lawyer asks for something better: production records and ETP running hours for the year. They show that one product line had been shut for seven months, so far less sludge was actually generated than authorised. Two further consignments had reached the TSDF, but the facility had never closed them online; its weighbridge slips prove receipt.
The reply sets out the production figures, attaches the TSDF's confirmation for the open manifests and admits the storage breach, with a dispatch plan and a request to regularise. The board accepts the explanation on quantities and closes that part. It still assesses environmental compensation for the storage breach, at a far lower figure than the 'missing sludge' allegation would have carried.
Your consignment was dumped or a notice has arrived
If a load you sent has been found dumped, the board will come to you first. Produce the manifest, the transporter's authorisation, the weighbridge slip and your communications with the facility, and report in writing that the consignment did not arrive. If you raised the alarm before the board found the dump, say so; it matters. Liability under the Rules extends to the transporter and facility as well as to you, but you will be asked to fund the lifting while responsibility is sorted out.
If the notice is about records, storage or open manifests, reply on the documents, not on general assurances. Where the board proposes closure or disconnection, the reply should go in before the date fixed, and our pages on replying to a closure notice and environmental compensation demands explain the options. Directions under Water Act section 33A, Air Act section 31A or EP Act section 5 can be appealed to the NGT under section 16 within 30 days of communication.
A ten-minute monthly compliance check
- Is the authorisation valid, and does it cover every waste stream we now generate?
- Is any waste on site older than 90 days, and if so, do we have the board's written permission?
- Are all manifests from last month closed by the receiving facility?
- Do the quantities in the manifests match our weighbridge slips and stock register?
- Are the transporter's and facility's authorisations current and on file?
- Are containers labelled and the storage area covered, contained and segregated?
- Has any empty drum, used oil or solvent left the site other than through an authorised route?
- Are interstate permissions in place for any waste going outside the state?
Related guides for waste-generating units
For the two wastes that most often slip out of the system, see used oil and chemical sludge disposal rules. If you are buying or leasing a site that once handled hazardous waste, read who pays for cleaning up contaminated industrial land. Battery and electronics makers have parallel duties, covered in lithium-ion battery waste rules for EV companies. Our page on a legal check of your environmental compliance explains how we review a unit's waste file before the board does.
Frequently Asked Questions
Is a manifest needed for every hazardous waste consignment?
Yes. Every movement of hazardous waste from the generator to a transporter and facility needs its own manifest, whether on paper or through the board's online system.
Who keeps the copies of the manifest?
The sender, transporter and receiving facility each keep a copy, and copies go to the State Board. The sender should keep its copies with weighbridge slips and receipts for inspection.
Do I need TSDF membership?
Most generators of landfillable or incinerable waste need an arrangement with an authorised facility, and boards usually ask for TSDF membership when granting or renewing authorisation.
Can I store hazardous waste for more than 90 days?
Only if the State Board has allowed a longer period. Without written permission, storage beyond 90 days is a violation.
Can I give used oil or empty drums to a scrap dealer?
No. Used oil goes only to an authorised recycler or re-refiner, and contaminated drums only to an authorised facility for decontamination.
Does the transporter need its own authorisation?
Yes. The transporter needs authorisation from the State Board, and its vehicles must meet the dangerous goods rules under the Central Motor Vehicles Rules 1989.
What if the facility never confirms receipt?
Follow up in writing, collect the weighbridge slip or receipt, and inform the board. An open manifest is treated as waste that has not been accounted for.
Can hazardous waste be sent to a TSDF in another state?
Yes, with permission from the State Boards of both the sending and receiving states, and with states in transit informed.
When is the annual return due?
The annual return for the previous financial year is filed with the State Board by 30 June.
If my transporter dumps the waste, am I liable?
Usually yes, at least in the first instance. The Rules make the generator responsible for using authorised operators and completing the manifest chain, though the transporter is also liable.
Can a board order closure for manifest violations?
Yes. Serious or repeated violations can lead to directions for closure and disconnection, as well as environmental compensation. Such directions can be appealed to the NGT within 30 days.
About the author
Advocate B.K. Singh, Founder & Principal Advocate, MCA, LL.B., LL.M.
Advocate B.K. Singh has practised for more than twenty years before the Supreme Court, the High Courts and the National Green Tribunal, and leads the environmental practice from offices in Dwarka (New Delhi) and Vaishali (Ghaziabad) with Advocate Sadhna Singh. Read his profile.
Board notice about manifests or storage? Send it to us
Send the notice, your authorisation and a short note of what happened on WhatsApp, or call us. We will tell you what the board is likely to focus on and how to reply on the documents.
This page gives general information about environmental law as it stood when it was last reviewed. It is not legal advice on your case and does not promise any result. Laws, rules, fees and time limits change, so check the current position for your matter before acting.
Have a question about your own case?
A guide can only go so far. Send us the notice, the order or a few photos, and we'll tell you where you stand, which authority or NGT bench deals with it and when the next step is due, in plain words.
