Required Licenses for Plastic Recycling Plant: SPCB NOC, EPR Registration & Compliance Checklist

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When EcoNova Polymers Pvt. Ltd., a mid-sized packaging company from Pune, decided to set up its own plastic recycling plant, the founders were confident. They had land, machinery quotations, and investors ready. But within weeks, everything stalled.

Their bank asked for CTE and CTO from the State Pollution Control Board. A local inspector demanded a Factory Licence. Their EPR consultant insisted on PWP registration on the CPCB portal.

Three different lists of requirements. Zero clarity.
Their project didn’t fail because of money or technology — it struggled because no one explained the actual licenses required for a plastic recycling plant in one place.

This guide does exactly that.

Why Licensing Matters for Plastic Recycling in India

India generates millions of tonnes of plastic waste every year, and recycling is a priority sector. But it’s also regulated more strictly than ever. Licences matter because:

  • Banks and investors check them before releasing funds.
  • Brands buying recycled plastic or EPR certificates will only work with compliant recyclers.
  • SPCBs and CPCB are conducting more inspections than before.
  • Operating without proper approvals can lead to stoppage or penalties.

In short: your licences decide whether your recycling business is legiimate, fundable, and scalable.

India’s Plastic Waste Trend

A quick look at the rising waste volumes explains why compliance is taken so seriously:

Year Plastic Waste Generated (TPA) Trend
2016–17 ~1.57 million Baseline reporting years
2017–18 ~0.66 million Under-reporting issues
2018–19 ~3.36 million Reporting improved
2019–20 ~3.47 million India crosses 3.4M TPA
2020–21 ~4.12 million Continues to rise

Business insight: Regulators want only capable, compliant facilities running. This is why licensing is strict.

The 3 Core Licences Required for a Plastic Recycling Plant

To keep things simple, think of compliance in three buckets:

  1. SPCB NOC (CTE + CTO)
  2. Plastic Waste Processor Registration (PWP on CPCB EPR Portal)
  3. Business & Safety Licences (Factory, Fire, Trade, GST)

Let’s break them down.

1. SPCB NOCs: CTE & CTO

Every recycling plant must obtain:

  • CTE (Consent to Establish) – before construction or installation
  • CTO (Consent to Operate) – before starting operations

These are mandatory under the Water Act 1974 and Air Act 1981.

Why this matters

CTE and CTO determine whether you can even legally build and run your unit. Without them:

  • Bank loans won’t be released
  • Local authorities can stop construction
  • Operation becomes illegal
  • Complaints or inspections can lead to immediate shutdown

What SPCB checks

  • Land zoning and suitability
  • Machinery capacity (TPA)
  • Pollution control equipment
  • Wastewater treatment plan
  • Storage safety
  • Hazardous waste handling

Documents required

  • Land/lease documents
  • Machinery list
  • Site layout plan
  • Process flow diagram
  • Waste management plan
  • Pollution control system details
  • Fee payment receipts

Business tip: Your declared capacity here must match what you later declare on the CPCB EPR portal.

2. PWP Registration on CPCB EPR Portal

After obtaining SPCB NOCs, a recycling plant must register as a Plastic Waste Processor (PWP) to legally issue EPR certificates.

This registration is done online on the CPCB Plastic EPR Portal and processed by your State Pollution Control Board.

Why this licence is crucial

Without PWP registration:

  • You cannot issue EPR certificates
  • Big FMCG and packaging brands cannot work with you
  • You lose access to the most profitable side of recycling: EPR credit trading
  • Your operations are seen as informal

What CPCB Requires

  • Company KYC (PAN, GST, CIN)
  • CTE & CTO copies
  • Process flow diagram
  • Geo-tagged photos of raw material area, production zone, dispatch area
  • Geo-tagged photos of machinery
  • Pollution control and safety system details
  • Electricity bill
  • Onsite/offsite disaster management plan

Validity

  • Fresh registration: 1 year
  • Renewal: 3 years

A quick real-world example

A recycler in Haryana installed a 6,000 TPA washing and granulation line but ignored PWP registration. He could still sell granules, but major brands refused to buy from him because his processed waste couldn’t be counted towards their EPR targets.

He lost high-margin clients simply due to missing one licence.

3. Business & Safety Licences (Often Ignored — Most Delays Happen Here)

Apart from environmental and EPR approvals, your plant also needs standard industrial licences.

A. Factory Licence

Under the Factories Act, 1948, if your plant uses power and employs a threshold number of workers, you must obtain a Factory Licence from the State Factory Department.

This covers:

  • Worker safety
  • Occupational health
  • Building layout approval
  • Equipment safety standards

B. Fire NOC

Your fire department will check:

  • Hydrant system
  • Extinguishers
  • Exit routes
  • Electrical safety
  • Storage of flammable plastics

This is often mandatory before occupancy.

C. Trade Licence / Shop & Establishment

Issued by your municipal authority, required for commercial operations.

D. GST & Company Registration

Usually:

  • Private Limited / LLP
  • GST registration
  • IEC (if importing machinery or exporting recyclate)

Why this bucket matters

Compliance affects:

  • Bank loan approvals
  • Insurance claims
  • Worker safety audits
  • CSR and brand partnerships

Licence Snapshot

A simple summary of all licences required for a plastic recycling plant:

Licence Authority When Required Notes
CTE SPCB/PCC Before construction Mandatory NOC
CTO SPCB/PCC Before operations Must match plant capacity
PWP Registration SPCB/PCC via CPCB Portal Before selling to PIBOs Needed to issue EPR certificates
Factory Licence State Factories Dept. After setup Covers safety & manpower
Fire NOC Local fire dept. Before occupancy Essential for insurance
Trade Licence Municipality Before business Routine compliance
GST, PAN, IEC GST & MCA Before billing/import-export Standard business norms

Compliance Risks & Consequences

If any licence is missing or outdated, the risks include:

  • Suspension of operations
  • Power/water disconnection
  • Environmental compensation
  • Loss of EPR-linked clients
  • Contract cancellations
  • Difficulty getting bank funding
  • Delays in renewing PWP registration
  • In extreme cases, cancellation of registration

A real incident

A recycler in Madhya Pradesh missed renewing his CTO. An unplanned SPCB inspection stopped all operations for 20 days. During that period, three major clients moved their waste to another recycler.

The financial loss far exceeded what a timely renewal would have cost.

Practical Compliance Checklist

Before construction

  • Finalize land
  • Prepare layout & project report
  • Ensure zoning approval
  • Apply for CTE

After machinery installation

  • Install pollution control systems
  • Update process flow diagram
  • Apply for CTO

Before commercial operation

  • Apply for PWP registration
  • Complete Factory Licence process
  • Install fire systems and obtain Fire NOC
  • Take trade licence and GST registration

Ongoing

  • File annual returns (PWM/EPR)
  • Maintain records of waste processing & certificates
  • Renew CTO and PWP before expiry

Conclusion

If you’re planning to set up a plastic recycling plant, the right licences will save you months of delay, prevent legal complications and help you build trust with high-value clients.

The three most important licences required for a plastic recycling plant are:

  • SPCB’s CTE & CTO
  • PWP Registration on CPCB’s EPR portal
  • Factory, Fire and business licences

When done early and correctly, these approvals turn your plant into a legitimate, bankable and EPR-ready business.

If you want guidance on mapping this for your own project, we can help.

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FAQs: Required Licenses for Plastic Recycling Plant

The core licenses include CTE and CTO from the State Pollution Control Board, Plastic Waste Processor (PWP) registration for EPR compliance, and Factory Licence, Fire NOC, Trade Licence, GST registration, and basic company incorporation documents.

The SPCB NOC, which includes Consent to Establish (CTE) and Consent to Operate (CTO), ensures your facility meets environmental and pollution-control standards. Without these approvals, construction and operations are not legally permitted.

PWP (Plastic Waste Processor) registration is done on the CPCB Plastic EPR Portal, allowing recyclers to legally process plastic waste and issue EPR certificates to brands (PIBOs). Without PWP registration, companies cannot participate in the EPR system.

You may operate with only SPCB permissions, but you cannot issue EPR certificates, meaning big brands and PIBOs will not work with you. This significantly limits revenue and business growth.

If your plant meets manpower and power-load thresholds, you must obtain a Factory Licence under the Factories Act, 1948. Most medium and large recycling units fall under this requirement.