Who must register as a seller of ozone-depleting substances in India?

The rule, in plain terms

Rule 6 casts a wide net deliberately: sell, stock, exhibit for sale, or distribute. A trader holding R-22 cylinders in a godown is "stocking"; a dealer listing R-22 on a marketplace is "exhibiting for sale"; a wholesaler moving cylinders to sub-dealers is "distributing". All of it requires registration first. The rules sit under the Environment (Protection) Act, 1986, and are administered through the Ozone Cell, MoEFCC, with Form 10 of Schedule XI as the seller-registration instrument.

What registration actually involves

A Form 10 registration ties a named business, at a named premises, to a defined scope — for HCFC-22 today, that scope is sale for servicing of refrigeration and air-conditioning equipment, because supplying HCFCs for new-equipment manufacturing ended on 31 December 2024. The registration carries a number and date that any buyer can ask to see. Ours, for the record: ODS/CS/17/6(12)/2024-OC, dated 12.11.2024 — published on our compliance page precisely so procurement teams can verify before they call.

Why the obligation exists

India's Montreal Protocol commitments are quota arithmetic: a national consumption ceiling stepping down against the 1,608.20 ODP-tonne baseline. Quotas only work if the state can see where controlled substances go — hence registered sellers, recorded sales, buyer declarations under Rule 7, and consolidated returns. Registration is the traceability layer that lets legitimate servicing supply continue while the ceiling falls; the ecosystem of buyer-side duties is covered in our Rule 7 guide.

What buyers should take from this

The practical test is simple: a dealer who cannot show you an ODS seller registration is not a lawful R-22 source. Unregistered supply correlates strongly with the counterfeit and contaminated product documented across the industry — the certificate is your first filter, the four-step verification is the rest. For HFCs (R-32, R-410A, R-134a, R-404A) no ODS registration applies, since they are not ozone-depleting; their controls arrive separately under the Kigali framework from 2028.

What the register looks like from the buyer's side

Verification is deliberately low-friction, and it works in minutes. First, ask the dealer for the registration number and date — a genuine holder quotes both without hesitation, because the certificate hangs on the office wall; evasion or 'it is under process' is itself the answer. Second, read the scope line: a Form 10 seller registration issued after the 2024 transition names HCFC-22 for servicing of refrigeration and air-conditioning equipment — a certificate silent on scope, or one claiming manufacturing supply after 31 December 2024, does not fit the current framework. Third, sanity-check the premises: registration ties to a named business at a named address; a certificate photocopied from another firm or another city is a classic dodge. Fourth, look for the behavioural tells of a genuine registrant — they ask for your Rule 7 declaration on regulated purchases, their invoices name the product precisely, and they can produce the manufacturer SDS on the spot, because record-keeping is a condition of their registration, not a courtesy. The pattern generalises: sellers who carry the compliance burden visibly are the ones with something to lose, which is precisely the counterparty you want for a controlled substance. The full four-step procedure, with what to do when a check fails, is in our verification guide.

Related: Verify a licensed R-22 seller · Our licensing & compliance · R-22 servicing supply