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

GSR-84(E) refers to the Gazette of India Notification dated 29 January 2025 issued by MoEFCC under the Air (Prevention and Control of Pollution) Act, 1981 and the Water (Prevention and Control of Pollution) Act, 1974, which consolidated and standardised India's Consent to Establish (CTE) and Consent to Operate (CTO) framework across all SPCBs. The notification, formally titled "Consolidated Consent Guidelines, 2025", is the most significant overhaul of the state-level pollution consent regime since the original Acts in the 1970s and 1980s.

Key provisions of GSR 84(E):

• Statutory timelines — SPCBs must dispose of CTE applications within 90 days and CTO applications within 60 days of receipt of complete application
• Auto-renewal pathway — Green and Orange category units with satisfactory compliance can apply for streamlined renewal without re-submission of full documents
• Consent validity — 5 years (Green), 10 years (Orange), 15 years (Red), uniform across all states
• State Level Monitoring Committee (SLMC) — Constituted under paragraph 15, decides applications where SPCB exceeds prescribed timelines, providing escalation
• First Schedule — Standardised Form I (CTE) and Form II (CTO) with prescribed information and documents
• Second Schedule — Maximum consent fee limits based on capital investment, capping the wide fee disparities across states
• OCMMS mandate — All consent applications must be filed through the State's online portal

The notification responds to two long-standing complaints from industry. First, that consent timelines varied wildly across states (some States routinely took 12–18 months, others 60 days), making national project planning difficult. Second, that consent fees and procedural requirements differed without rational basis, creating regulatory arbitrage between states.

For Indian recycling and CBG entrepreneurs, the practical impact is positive but transitional. Maharashtra, Gujarat, Tamil Nadu, and Karnataka — which already had mature OCMMS and reasonable timelines — saw modest changes. Smaller-state SPCBs are still operationalising the new framework; some have struggled to meet the 60/90-day timelines, leading to SLMC referrals. The fee caps in the Second Schedule have lowered consent costs in states that previously charged higher fees (Haryana, UP), but raised them in states that previously charged below the cap. Industry associations including CII and FICCI continue to engage with MoEFCC on implementation gaps, particularly around the definition of "complete application" and the SPCBs' practice of returning applications for additional documents that effectively restarts the clock.