Rules 20 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Rules 20 to 24 are the Rules' miscellaneous chapter, and they carry real consequences. They require records in Form 3 and annual returns in Form 4, hand each authority its duties through Schedule VII, require immediate accident reporting with a Form 11 report, make occupiers and operators liable for damage, and give an appeal within thirty days to the State's Environment Secretary.
These Rules are current as amended up to G.S.R. 636(E) dated 16 July 2026 (Chapter VIII on non-ferrous metal scrap in force from 1 April 2026). Later amendments, CPCB guidelines and State Board orders should be checked. If you face a Board notice, an accident inquiry or an adverse order on authorisation, see our legal dispute resolution service.
Occupiers and operators keep records in Form 3 and send annual returns in Form 4 to the State Board (rule 20). An accident must be intimated immediately by telephone or e-mail, followed by a Form 11 report (rule 22). They are liable for all damages to the environment or third parties from improper handling (rule 23). An order suspending, cancelling or refusing authorisation can be appealed in Form 12 within thirty days to the State's Environment Secretary (rule 24).
Rule 20: records, returns, inventories and the review report
| Sub-rule | Provision |
|---|---|
| 20(1) | The occupier handling hazardous or other wastes and the operator of a disposal facility maintain records in Form 3 |
| 20(2) | They send annual returns to the State Board in Form 4 |
| 20(3) | The State Board, on the basis of the returns, prepares an annual inventory of waste generated, recycled, recovered, utilised including co-processed, re-exported and disposed, and submits it to the CPCB by 30 September every year; it also prepares an inventory of hazardous waste generators, actual users and common and captive disposal facilities and submits it to the CPCB every two years |
| 20(4) | The CPCB prepares a consolidated review report on management of hazardous and other wastes and forwards it, with recommendations, to the Ministry before 30 December once every year |
The due date for the occupier's return (30 June) is in rule 6(5), explained in rules 6 and 7. The inventory and review report follow from the returns, which is why late or inconsistent returns show up in national figures.
Rule 21: the authorities and their duties
The authority in column (2) of Schedule VII performs the duties in column (3). Schedule VII lists six authorities.
| Authority | A selection of duties |
|---|---|
| Ministry of Environment, Forest and Climate Change | Identification of wastes; permissions to exporters, importers and for transit; promoting environmentally sound management; sponsoring training |
| Central Pollution Control Board | Coordinating State Boards; training; recommending standards for treatment and disposal; inspection of facilities; preparing guidelines and SOPs for recycling, utilisation, pre-processing and co-processing; annual review report |
| State Government or Union territory | Identifying sites for common facilities; assessing EIA reports and conveying site decisions; notifying sites; publishing an inventory of disposal sites |
| State Pollution Control Boards or Committees | Inventorisation; grant and renewal of authorisation; monitoring compliance, including conditions of import and export permissions; examining and forwarding import applications; programmes to prevent waste; action against violations |
| Directorate General of Foreign Trade | Grant of licence for import and refusal of licence for wastes prohibited for import and export |
| Port authority and Customs authority | Verifying documents; informing the Ministry of illegal traffic; analysing wastes; training officials; action under the Indian Ports Act or the Customs Act |
Knowing who does what helps an applicant to address the right office. The State Board is the one most occupiers deal with.
Rule 22: accident reporting
"Where an accident occurs at the facility of the occupier handling hazardous or other wastes and operator of the disposal facility or during transportation, the occupier or the operator or the transporter shall immediately intimate the State Pollution Control Board through telephone, e-mail about the accident and subsequently send a report in Form 11."
The duty falls on the occupier, the operator and the transporter. It covers accidents at the facility and during transport. The word is "immediately", so the intimation by telephone or e-mail comes first, and the Form 11 report follows. The general accident duty under the Act is explained in section 9 of the EP Act, and the EP Rules' list of authorities in rules 12 and 13.
Rule 23: liability
- 23(1): "The occupier, importer or exporter and operator of the disposal facility shall be liable for all damages caused to the environment or third party due to improper handling and management of the hazardous and other waste."
- 23(2): the occupier and the operator of the disposal facility "shall be liable to pay financial penalties as levied for any violation of the provisions under these rules by the State Pollution Control Board with the prior approval of the Central Pollution Control Board."
The first sub-rule is a rule of liability for damage; it does not set an amount. The second is about financial penalties levied by the State Board with the CPCB's prior approval. This article does not restate any amounts. Penalty provisions of the Act are explained in sections 15 to 15B.
Rule 24: appeal
| Sub-rule | Provision |
|---|---|
| 24(1) | A person aggrieved by an order of suspension, cancellation or refusal of authorisation or its renewal passed by the State Board may, within thirty days from the date the order is communicated, appeal in Form 12 to the Appellate Authority, the Environment Secretary of the State |
| 24(2) | The Appellate Authority may entertain the appeal after thirty days if satisfied that the appellant was prevented by sufficient cause |
| 24(3) | Every appeal is disposed of within sixty days from the date of filing |
The thirty days run from the date the order is communicated, so keep proof of the date of receipt. An appeal needs a clear statement of grounds and the Board's order and reasons; see rule 7 on the hearing and reasons the Board must give.
Practical steps
- Keep Form 3 up to date every time waste moves, is stored or is recycled.
- File Form 4 on time and make sure its numbers match your manifests.
- Keep an accident protocol: who calls the Board, by which means, and who prepares Form 11.
- Brief transporters that they share the reporting duty.
- Diarise appeal dates on any adverse order, from the date of communication.
- Know your Schedule VII contact for each kind of permission.
Example
A tanker carrying spent acid for Raipur Chemical Recoveries Limited overturns on a highway. The driver informs the company, and the company's EHS head telephones the State Board immediately and follows up by e-mail. A Form 11 report goes to the Board within the days that follow. The Board later suspends the company's authorisation for a period. The company files an appeal in Form 12 with the Environment Secretary within thirty days of receiving the order, annexing the Board's reasons and its corrective measures.
Need help with a notice or an appeal?
Accidents and adverse orders have short clocks. Our legal dispute resolution team can help you prepare Form 11, build the record of liability and file an appeal within time.
Key takeaways
- Records are in Form 3; annual returns in Form 4; the Board's inventory goes to the CPCB by 30 September.
- Schedule VII allocates duties among the Ministry, CPCB, State Governments, State Boards, DGFT and Port and Customs authorities.
- Accidents are intimated immediately by telephone or e-mail and followed by Form 11.
- Occupiers, importers, exporters and operators are liable for damage from improper handling.
- Appeals against suspension, cancellation or refusal of authorisation lie to the State Environment Secretary within thirty days.
Read next
- Rules 16-19: TSDF, packaging, transport and manifest
- Rules 25-30: EPR for used oil
- Section 9 of the EP Act: accidental discharge intimation
- Sections 15 to 15B of the EP Act: residuary penalty
Disclaimer: Based on the environment rules, guidelines and notifications named above as published in the Gazette of India, read with every amendment notified up to 3 October 2026 that the article names (consolidated reading texts from the CPCB 2021 compilation and the Goa State Pollution Control Board 2025 compilation were checked against the amending notifications), as consulted on 3 October 2026. Later amendments, CPCB guidelines, State Board orders and fees should be checked. This article is general information, not legal advice; check the official text before acting.