Which CPCB Category Does a Biochar Plant Fall Under? Reading the Charcoal Manufacturing Analogue
CPCB's sector-categorisation directions contain no explicit entry for biochar. Reading the residuary classification route alongside the charcoal manufacturing entry suggests how a pyrolysis-based biochar plant is likely to be categorised, and why the answer turns on kiln type and capacity.
In order to determine the correct classification of a biochar plant working on the pyrolysis process, it is necessary to discuss the directions dated 12.02.2025 issued by the Central Pollution Control Board on "Classification of Sectors into Red, Orange, Green, White and Blue Categories". In those directions, no explicit entry covering biochar is mentioned. We therefore move to the residuary sector classification method provided in sub-chapter 3.3, which reads as under:
"The revised methodology of classification (2025) and list of sectors classified by CPCB is required to be adopted and implemented by all SPCBs/PCCs. In case of any new or left-out sector, the SPCB/PCC may categorize the sector at its own level. For this purpose, a committee headed by the Member Secretary, SPCB/PCC and comprising of at least two senior cadre engineers/scientists of the SPCB/PCC (as nominated by the Member Secretary of the concerned SPCB/PCC) may be constituted to examine the matter and classify the sector in accordance with the methodology prescribed by CPCB. The State Level Committee may also co-opt subject experts, industrial association representatives, etc., as members, as per requirement. CPCB has also developed a tool to assess the Cumulative Pollution Index and category of any sector, which is available on https://cpcb.nic.in/categorization-of-industrialsectors/."
The directions add that all SPCBs/PCCs are required to submit the list of all sectors classified under the white category to CPCB in the prescribed format (Annexure-V), for notification as per the provisions of the Jan Vishwas (Amendment of Provisions) Act, 2023.
The residuary route for left-out sectors
The meaning of sub-chapter 3.3 is that State Pollution Control Boards and Pollution Control Committees are at liberty to examine and classify left-out or new sectors on the basis of the methodology prescribed by the CPCB. Where a sector is not explicitly named, the classification decision moves to the state level, exercised through a committee process rather than left to individual discretion.
Finding the closest comparable entry
In addition, the regulatory treatment or classification of a particular sector, product or service which is not explicitly mentioned in the law generally finds its classification by way of juxtaposing it against the most identical or comparable entry provided. In the instant case, the CPCB Directions dated 12.02.2025 on classification of sectors contain no direct or explicit mention of biochar, so the exercise is to locate an identical or comparable entry.
On the basis of the List of Sectors Classified by the Central Pollution Control Board (as updated on 24th August 2026) read with CPCB's directions dated 16.12.2025, Charcoal Manufacturing at Sl. No. 217 is the most comparable sector to biochar. It is pertinent to mention that biochar is not automatically the same as charcoal for regulatory purposes, but the charcoal manufacturing category may be the closest analogue where no separate biochar category exists.
Sector entry at Sl. No. 217 covers Charcoal Manufacturing, classified in line with the Environmental Guidelines for Charcoal Manufacturing Units prepared by the CPCB, as follows:
| Particulars of the Process | Category |
|---|---|
| Charcoal manufacturing units with earth mound kilns | Green Category |
| Charcoal manufacturing units with elevated/above-ground kilns or rotary kilns having production capacity less than 15 TPD | Green Category |
| Charcoal manufacturing units with elevated/above-ground kilns or rotary kilns having production capacity of 15 TPD and more | Orange Category |
What this means for biochar
Therefore, on reading the CPCB Directions dated 12.02.2025 in congruity with the CPCB Directions dated 16.12.2025, it appears that the Charcoal Manufacturing entry should ideally cover the process of manufacturing biochar. If that is correct, the classification of a biochar manufacturing plant shall be determined on the basis of the table above, which makes the kiln technology and production capacity the operative variables in the classification outcome.
For project developers, the practical consequence is twofold. First, until a dedicated biochar entry is notified, the category assigned to a biochar plant will rest on an analogy that a state-level committee applies, so the classification should be confirmed with the concerned SPCB/PCC before consent applications are filed. Second, the same plant can sit in different categories depending on its configuration, which means capacity and kiln choices made at the design stage carry regulatory consequences that deserve attention alongside the carbon-side structuring of the project.