Form V - Environmental Statement for E-Waste Recyclers

Every e-waste recycling facility in India operates within a highly regulated environment, given the hazardous nature of the materials they handle such as lead, mercury, cadmium, lithium-ion batteries, PCBs, CRT glass, and other toxic components. To ensure these operations remain transparent, responsible, and environmentally safe, the Ministry of Environment, Forest and Climate Change mandates the annual submission of Form V, the Environmental Statement, under Rule 14 of the Environment (Protection) Rules, 1986. This document is an annual environmental audit for the financial year ending on 31st March and serves as a comprehensive reflection of a recycler’s environmental performance.

Form V begins with general information about the unit, capturing the name and address of the owner or occupier, industry category including primary and secondary STC codes, production capacity as approved under the Consent to Operate, year of establishment, and the date on which the last Environmental Statement was submitted. These details ensure clear identification of the facility and build a foundation for reviewing the unit’s environmental accountability.

The statement then moves into a detailed review of resource consumption, starting with water usage. E-waste recyclers must report water consumed for industrial processes, cooling systems, and domestic purposes, expressed in cubic meters per day. They also need to present product-wise water consumption for both the previous and current financial years, offering insight into efficiency improvements and conservation measures undertaken by the facility. Following water usage, Form V requires a thorough disclosure of raw material consumption. For recyclers, this includes the total quantity of e-waste received as input material along with any chemicals or consumables used during processing. These values must be presented per unit of output for different product streams like metals, plastics, PCBs, or mixed fractions, again comparing the current year with the previous one.

A critical part of Form V focuses on pollution generated by the unit. Recyclers must report the nature and quantity of water and air pollutants, strictly based on parameters specified in their Consent to Operate. Wastewater, if generated, must be analysed for pH, suspended solids, organic load, and heavy metals, although many facilities operate on a zero-liquid-discharge model and only domestic wastewater needs to be accounted for. Air emissions generated from shredding lines, dust extraction systems, manual dismantling zones, and DG sets must also be recorded, covering particulate matter and gaseous emissions. Any variations from prescribed standards must be explained with reasons, ensuring transparency and corrective action where needed.

Form V then addresses hazardous waste, which is a significant by product of e-waste recycling activities. Facilities must disclose the total quantity of hazardous waste generated during both the previous and current financial years, distinguishing waste arising directly from processing such as lead-bearing dust, PCB residues, mercury components, contaminated PPE, or battery waste from waste produced by pollution control systems like dust collected in bag filters or sludge from scrubbers. Similarly, the facility must report all non-hazardous solid waste generated, including plastics, paper, glass, non-contaminated metals, rubber, and packing material, while also indicating how much of this waste was recycled or reused.

A detailed explanation of the characteristics of hazardous and solid wastes is also required. This includes information about contamination levels, physical and chemical properties, toxicity, and how these wastes are stored, transported, and disposed of. Disposal practices may involve sending waste to authorized recyclers, transporting hazardous fractions to TSDFs, or opting for co-processing in cement kilns, depending on the nature of the waste. Accurate reporting ensures responsible waste management and prevents environmental leakage.

The statement also requires a narrative on the impact of pollution control measures implemented by the recycler. Dust extraction systems, upgraded bag filters, secure hazardous waste storage, water conservation steps, energy-efficient machinery, and structured workplace safety programs all play a role in reducing pollution, saving resources, improving worker health, and lowering operational costs. These measures also demonstrate how the facility’s environmental practices directly influence the efficiency and sustainability of production.

Additionally, the recycler must disclose any new investments made towards enhancing environmental protection. This could include upgrades to pollution control equipment, fire safety systems, CCTV surveillance for waste tracking, solar power installations, waste treatment systems, improved storage facilities, or employee training programs. These investments highlight the facility’s ongoing commitment to better environmental performance.

Finally, Form V allows the recycler to include any miscellaneous information related to environmental protection and pollution abatement. This could involve details about internal environmental audits, emergency mock drills, plantation initiatives, CSR activities, ISO 14001 implementation, new SOPs, or the introduction of digital tracking systems. Such additions help paint a complete picture of the facility’s environmental culture and long-term sustainability vision.

In summary, Form V is not just a compliance document it's a transparent environmental audit that captures the essence of how responsibly an e-waste recycling facility operates. For recyclers, filing an accurate and comprehensive Form V strengthens credibility, aligns operations with regulatory expectations, and demonstrates leadership in sustainable waste management. As regulatory expectations and EPR obligations continue to grow, the importance of Form V as an environmental accountability tool becomes even more critical. With structured reporting, accurate data collection, and expert compliance guidance, recyclers can ensure their annual Environmental Statement reflects not just operational activity, but a deep-rooted commitment to environmental protection and sustainable recycling practices.

Whether you are a recycler, refurbisher, producer, importer, or bulk consumer Aseries Envirotek India Private Limited provides complete compliance consulting tailored to your operations. From documentation to approvals, audits to reporting, we ensure your organization stays fully compliant, efficient, and future-ready. Connect with our experts today and make compliance seamless.