GSR 84(E) (GSR-84(E))

GSR 84(E) is a Gazette notification (General Statutory Rules, Extraordinary) issued by the Ministry of Environment, Forest and Climate Change in early 2025 that amended the operational framework for industrial consents (CTE and CTO) issued under the Air (Prevention and Control of Pollution) Act 1981 and the Water (Prevention and Control of Pollution) Act 1974. The notification updates timelines, fee structures, online application procedures, and the categorisation of industries into Red, Orange, Green and White consent categories that determines consent validity periods and renewal requirements.

The notification follows the CPCB's broader reform of the Indian consent regime in response to "ease of doing business" initiatives and NGT directions that earlier consent processes were causing 6-18 month delays for industrial setup. Key operational changes include: online-only application through the PARIVESH 2.0 portal (no physical filing accepted), compressed timeline for SPCB decision (30 days for White, 45 days for Green, 60 days for Orange, 90 days for Red — versus earlier indefinite timelines), self-certification for low-pollution White category, integrated CTE-CTO for certain small-scale categories (one combined consent instead of two sequential consents), and extended CTO validity for Green and White (15 years from earlier 5 years; Red and Orange remain 5 years).

For recycling plants, the practical implications hinge on category. Most recycling units — plastic granulation, e-waste dismantling, tyre shredding — fall in Red category (Pollution Index 60+) where 5-year CTO renewal and full application remain. CBG plants fall in Orange (PI 41-59) with the new 90-day timeline. Refurbishment-only e-waste units (no chemical processing) may qualify for Green (PI 21-40), benefiting from the 15-year extended validity — a substantial easing if achievable. The categorisation revision under GSR 84(E) reassessed Pollution Index scores for several industries, in some cases moving plants down a category and in others up.

The fee schedule under GSR 84(E) ties consent fees to capital investment and pollution category. Recycling plants of Rs 10-50 crore project cost typically pay Rs 1-3 lakh CTE fee and Rs 50,000-2.5 lakh annual CTO fee, plus state-specific surcharges. The notification standardised the formula across states; previously each SPCB had its own fee table, with Maharashtra and Gujarat at the high end and smaller states at the low end. The trade-off industry highlights is that the new format compresses application timelines but raises documentary requirements — the SPCB can now reject incomplete applications without further engagement, putting the onus on the applicant to submit a defensible techno-environmental feasibility report on the first attempt.