Skip to main content
Knowledge Hub
Compliance9 min read

Which Licence Is Needed to Run an RO Plant?

No single "RO plant licence" exists — the permissions attach to where the water comes from, where the reject goes, and what you sell. Here is the full picture.

Technically reviewed by Prashant Dwivedi, Co-Founder & Director ·

There is no single "RO plant licence" in India. The permissions attach to three things: where the plant draws its water (a groundwater NOC from the Central Ground Water Authority or the State groundwater authority), where the reject or brine goes (consent under the Water (Prevention and Control of Pollution) Act, 1974 from the State Pollution Control Board), and what you sell (an FSSAI licence if you bottle the water). Get these three right and the plant runs legally; miss one and the notices start.

Does an RO plant itself need a licence?

No. An RO plant is a treatment system, not a licensed activity. What the law licenses is the water intake and the discharge around it. An RO plant that polishes municipal water for a hotel's kitchens and sends its small reject stream to the building's sewer sits in a very different legal position from a 500 KLD industrial RO that draws borewell water and discharges concentrated brine. So before ordering, map the plant's position on all three axes: source water, reject disposal, and end use. Each axis decides which permission applies.

Do you need permission to draw groundwater for an RO plant?

Yes, in almost every commercial case. The Central Ground Water Authority (CGWA) regulates groundwater extraction by industries, infrastructure and mining projects across the country, and issues No Objection Certificates (NOCs) for it — CGWB. In 14 States/UTs that have their own groundwater Acts, the State Ground Water Authority grants the NOC instead; CGWA regulates the remaining States and Union Territories directly.

Under the CGWA guidelines notified on 24 September 2020 (S.O. 3289(E)), all new and existing industries abstracting groundwater must seek an NOC unless specifically exempted. Exemptions are narrow: individual domestic consumers, rural drinking water schemes, agricultural use, and micro and small enterprises drawing less than 10 cum/day. A factory, hotel or water-bottling plant almost never falls in these categories.

The conditions that come with an NOC matter for an RO plant:

  • Industries drawing more than 10 m³/day must construct a piezometer (observation well) at least 15 m from the production well and submit monthly water level data.
  • Industries abstracting more than 100 m³/day must undertake an annual water audit through CII/FICCI/NPC-certified auditors and reduce groundwater use by at least 20% over the next three years — one more reason to design reuse into the RO system from day one.
  • An impact assessment report and groundwater modelling study covering a 5 km radius is mandatory for projects extracting more than 100 m³/day in over-exploited, critical and semi-critical areas, and more than 500 m³/day (non-alluvium) or 2,000 m³/day (alluvium) in safe areas — CGWB.
  • In over-exploited assessment units, no NOC is granted to any new industry except MSMEs — and no NOC at all to new packaged water industries, even MSMEs, in those areas.

The application process is online through a web-based system — CGWB — and abstraction charges apply based on the quantity drawn, with separate restoration charges in stressed areas.

If your RO plant recycles treated wastewater instead of drawing groundwater, the NOC question disappears — but the consent question below does not.

When does the State Pollution Control Board need to consent?

Whenever the RO plant discharges sewage or trade effluent. Section 25 of the Water (Prevention and Control of Pollution) Act, 1974 prohibits any person from establishing any industry, operation or process, or any treatment and disposal system, that is likely to discharge sewage or trade effluent into a stream, well, sewer or land — without the previous consent of the State Board. That consent is granted in two stages: consent to establish (CTE) before construction, and consent to operate (CTO) once the plant runs.

For an industrial RO plant this applies squarely. The reject stream — the 20-40% of feed water that leaves as concentrated brine — is trade effluent, and the board's consent will fix its point, nature, composition and rate of discharge. A brine stream with 15,000 mg/L of dissolved salts cannot go to a storm drain or onto land; it must go where the consent says, or into a ZLD loop.

For a building or hotel RO that polishes municipal water, the position is milder: the intake is already metered municipal supply and the small reject stream goes to the sewer as domestic-classified discharge. Even so, confirm the discharge point with your local authority — and if the building draws groundwater at all, the NOC rules above apply regardless of what the RO does afterwards. Under the same CGWA guidelines, installation of an STP is mandatory for residential apartments and group housing societies whose groundwater requirement exceeds 20 m³/day, with the treated water used for flushing, car washing and gardening.

What paperwork does a packaged drinking water RO plant need?

If the RO plant's product is sold in bottles or jars, two regimes apply.

First, an FSSAI licence is mandatory — packaged drinking water is a regulated food product under standard 2.10.8 of the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011. Under FSSAI's scheme of testing notification dated 17 December 2025, the source water must be tested for all parameters at an FSSAI-notified NABL-accredited laboratory before use, and the plant must maintain batch-wise test records, monthly microbiological testing, and corrective-action records for any non-conforming batch, with the scheme in force from 1 January 2026.

Second, the BIS certification mark is no longer mandatory. FSSAI gazette-notified the omission of the mandatory BIS certification provision on 17 October 2024, and the advisory confirms the mandatory BIS mark no longer applies to packaged drinking water and mineral water. The underlying standard — IS 14543:2024, the specification for packaged drinking water — is now listed by BIS as a voluntary certification standard. Many buyers still expect the mark, so treat it as a market decision rather than a legal one.

What checklist should you complete before ordering the plant?

Work through this before signing the purchase order:

  • Confirm the water source. Municipal supply, borewell or surface water each changes the permission set.
  • If groundwater: check which authority covers your district (CGWA or the State groundwater authority) and whether your assessment unit is safe, semi-critical, critical or over-exploited — over-exploited units can block new NOCs outright.
  • Budget for NOC conditions: a piezometer if you draw more than 10 m³/day, an annual water audit above 100 m³/day, and impact assessment for large or stressed-area withdrawals.
  • Classify the reject stream. Decide where the brine goes — sewer per consent, evaporation, or a ZLD loop — and get the State PCB's position in writing.
  • If the product is bottled: apply for the FSSAI licence, arrange source-water testing at a notified NABL lab, and decide whether to pursue voluntary BIS certification for market acceptance.
  • Keep one person accountable for renewals — consents and NOCs expire, and an expired CTO stops the whole plant, not just the paperwork.

Frequently asked questions

I run a small factory and want an RO only for drinking water for staff. Do I need all of this?

The permissions follow the source and the discharge, not the use. Drawing groundwater for the plant still needs an NOC (unless you qualify for an exemption, such as a micro or small enterprise drawing under 10 cum/day). If the RO feed is municipal water and the reject goes to the sewer, the consent question is simpler — but confirm the arrangement with your State PCB rather than assuming.

Is the BIS ISI mark still required for packaged drinking water?

No. FSSAI gazette-notified the omission of the mandatory BIS certification provision on 17 October 2024, so the ISI mark is no longer legally required for packaged drinking water or mineral water. The FSSAI licence and the FSSAI scheme of testing — in force from 1 January 2026 — remain mandatory. BIS certification to IS 14543:2024 continues as a voluntary option.

My society's RO draws groundwater. Does the society need a NOC too?

Yes — apartment complexes and group housing societies drawing groundwater need an NOC, granted only where the local water supply agency cannot meet the requirement. Under the CGWA guidelines, such an NOC is valid for five years, and where the groundwater requirement exceeds 20 m³/day an STP is mandatory, with treated water reused for flushing and gardening.

What happens if I run the RO plant without the required consent?

Operating without consent puts you outside the law on both fronts: unauthorised groundwater extraction attracts environmental compensation and the CGWA or State authority can direct the well's closure, and an unconsented discharge under Section 25 of the Water Act is an offence the State PCB can act on. Both authorities operate complaint and inspection mechanisms, and the boards' consent conditions are enforceable against the plant operator.

Who enforces all of this?

Groundwater extraction is enforced by the CGWA or the State Ground Water Authority, as applicable in your State. Discharges and consents are enforced through CPCB directions and State Pollution Control Board orders/consents. Food safety for bottled water is enforced by FSSAI and the State food safety commissioners.

Navbharat Water designs, builds and operates RO/UF and water treatment plants for industry and buildings in India and abroad, sized from 10 KLD to 10 MLD — and we plan the permissions around the plant, not after it. If you are sizing a new RO system or regularising an existing one, explore our water treatment and membrane solutions or get a quote. For a related read on choosing membranes before you commit, see our RO membrane selection guide.

Sources

Have a water treatment requirement?

Navbharat Water engineers have commissioned 150+ ETP, STP, and ZLD plants across India. Share your requirement for a technical consultation.

Request a Technical Consultation