Factory licence and GPCB consents in Gujarat

Why this is confusing

• Many guides are out of date. They still describe factory licensing under the Factories Act, 1948. Factory licensing now falls under the OSH Code.
• People use different words. Plant teams say "GPCB NOC" and "CTO", and "factory licence" is often spelled "factory license". GPCB's procedure uses CTE and CCA.
• Consent renewal has changed at the central level. How that applies to a given unit in Gujarat is a separate question.
• The order matters. Finding out late that environmental clearance is needed is costly.

Factory licensing after the OSH Code

The Occupational Safety, Health and Working Conditions Code, 2020 has been in force since 21 November 2025. Factory registration and licensing now fall under the Code (approval and licensing of factories: section 79) and the Gujarat rules made under it. For factories, the State Government is the regulator. Guidance written under the Factories Act, 1948 may be out of date.

The Code defines a factory mainly by the number of workers: 20 or more where power is used, or 40 or more without power. Where State law sets a different number, that number applies.

In practice: check whether the premises is a factory under the Code; apply for approval and a licence under the Gujarat rules; and keep the licence in line with changes at site. We work from the current Code and rules, not older checklists.

GPCB consents

Pollution control consent comes from the Water Act and the Air Act. The State Board's prior consent is needed to establish an industry under the Water Act. Under GPCB's procedure, a unit obtains Consent to Establish (CTE) before it is set up, and a Consolidated Consent and Authorisation (CCA) before it starts operating. GPCB handles these applications through its online system, XGN.

Not every unit needs every consent. Some low-pollution (white category) units are exempt from consent. Projects with environmental clearance may not need a separate consent to establish, but still need consent to operate. CPCB classifies industrial sectors by pollution potential (red, orange, green and white; a blue category was added in 2025). We check your unit's category and GPCB's treatment for your case.

Central consent guidelines bind State Boards. Guidelines on water consents were amended in January 2026, and they treat consent to operate as valid until cancelled. How GPCB applies this to a given unit is set by its own orders. We check GPCB's current procedure for each case and do not assume the outcome.

NOC, CTO, CTE, CCA: the terms people use

• "GPCB NOC" is how many people describe the Consent to Establish. GIDC's own plan-approval checklist, for example, asks for the "CTE/NOC" from the pollution board.
• "CTO" (consent to operate) is the general term. In Gujarat, the operating permission is GPCB's Consolidated Consent and Authorisation (CCA).

Environmental clearance

Some projects need prior environmental clearance under the EIA Notification, 2006, in addition to GPCB consents. The Notification lists the project types it covers. Category A projects are appraised centrally and Category B projects by the State-level authority. Stages can include screening, scoping, public consultation and appraisal.

Whether clearance is needed, and in which category, depends on the activity and its scale. We check this at the start. Technical studies, such as an EIA report, come from qualified specialists. Our role is the regulatory route, the application plan and the follow-through.

Licences a factory in Gujarat usually holds

The list depends on the activity, but an operating factory usually holds:

• factory registration and licence under the OSH Code and the Gujarat rules;
• GPCB consents (CTE, then CCA), unless an exemption applies;
• hazardous waste authorisation under the Hazardous Waste Rules, 2016, where the unit generates such waste, with an annual return to the State Board;
• a fire safety certificate under the Gujarat Fire Prevention and Life Safety Measures Act, 2013, where the Act applies to the building;
• environmental clearance, where the project is listed in the EIA Notification;
• other registrations as the activity requires, such as extended producer responsibility registrations for some producers.

This list is usual, not complete. To keep these current across departments, see statutory approvals and government liaison.

What we handle

For a new plant, these approvals sit within the full set of approvals to set up an industry in Gujarat. We handle:

• an applicability check: whether the premises is a factory under the OSH Code, which GPCB consents apply and whether environmental clearance is needed;
• factory approval and licence applications under the Gujarat rules, and later amendments;
• CTE and CCA applications with GPCB, and amendments when operations change;
• environmental clearance: route planning and coordination through the appraisal process;
• fire safety certificates under the Gujarat Fire Act, applied for and renewed online, where the Act applies;
• status tracking and replies to queries for every application.

What you receive: a written applicability note; a licence and consent map for your unit; application drafts and document checklists for your review; draft replies to queries; and a status report until each application is decided.

After approval: keeping licences and consents current

Conditions apply throughout operation, and a change in production, raw materials, effluent or emissions can call for an amendment. Some laws also create recurring duties, such as registers and returns under the OSH Code and an annual environmental statement to the State Board. To track each with a named owner, see Adynta Compliance Monitoring.

How we work

We check applicability against the current law, plan the applications in order, prepare each file for your review, and follow it until it is decided. We do not promise approvals, timelines or fees. Read more about how we work.