EPR REGISTRATION FOR USED OIL

INTRODUCTION

An Overview of EPR Registration for Waste Oil

Extended Producer Responsibility (EPR) for Waste Oil has been introduced by the Ministry of Environment, Forest and Climate Change (MoEFCC) through an amendment to the Hazardous Waste Management Rules, effective from April 1, 2024. The framework aims to regulate the collection, recycling, and disposal of waste oil in an environmentally responsible manner.

Waste oil generated from industrial and commercial activities poses serious environmental risks if handled improperly. Under the EPR system, producers, importers, and recyclers are required to register with the CPCB, meet recycling targets, and ensure waste oil is processed only through authorised recyclers.

This initiative strengthens India’s waste management framework and supports the transition towards a circular economy by promoting accountability, compliance, and sustainable recycling practices.

Role of EPR Compliance for Used Oil

The introduction of EPR for Used Oil marks the fifth Extended Producer Responsibility policy in India, following E-Waste, Plastic Waste, Tyre Waste, and Battery Waste regulations. This policy focuses on improving the management of used oil by promoting sustainable practices and supporting the development of a circular economy. Under the EPR framework, producers, importers, recyclers, and collection agents are required to follow prescribed guidelines for the collection, recycling, and disposal of used oil.

The framework helps reduce environmental risks such as soil and water contamination caused by improper disposal of waste oil. It also encourages the use of re-refined oil, which contributes to lowering greenhouse gas emissions. By establishing a structured system for waste oil management, EPR compliance supports resource conservation, reduces dependence on crude oil, and promotes sustainable industrial practices.

Entities Required for EPR Registration for Waste Oil

Producers: Entities engaged in selling base oil or lubricating oil within India.

Recyclers: Entities engaged in the recycling and re-refining of used oil.

Collection Agents: Entities responsible for collecting waste oil and supplying it to registered recyclers.

Used Oil Importers: Entities engaged in importing used oil for re-refining purposes.

Benefits of EPR Authorization for Used Oil

1
Environmental Protection

Reduces environmental contamination by preventing toxic chemicals in used oil from polluting soil and water bodies.

2
Reduction in GHG Emissions

Helps lower greenhouse gas emissions by reducing the demand for fresh oil through increased recycling and re-refining.

3
Climate Change Mitigation

Contributes to slowing climate change by reducing the carbon footprint associated with crude oil extraction and disposal.

4
Conservation of Resources

Supports conservation of petroleum resources by promoting the use of re-refined oil and reducing dependence on crude oil.

5
Promotion of Circular Economy

Facilitates a circular economy by ensuring used oil is collected, processed, and reintroduced into the supply chain.

6
Sustainable Development

Aligns with sustainable development goals by encouraging environmentally responsible industrial practices.

7
Economic Benefits

Reduces energy consumption, as re-refining used oil requires significantly less energy than refining crude oil, leading to cost savings.

8
Regulated Waste Management

Ensures systematic and regulated management of used oil through authorised collection and recycling channels.

9
Compliance and Accountability

Establishes a clear compliance framework, making producers, recyclers, and other stakeholders accountable.

10
Public Health Safety

Protects public health by minimizing risks associated with improper handling and disposal of hazardous waste oil.

By implementing EPR authorization for used oil, industries can make a meaningful contribution to environmental sustainability, economic efficiency, and public health protection while ensuring regulatory compliance.

EPR REGISTRATION FEE FOR USED OIL

S. No.Sale of Base Oil / Lubrication Oil (MTPA)Registration Fee Amount (INR)
1More than 1,00,000 MT₹10,00,000
2More than 50,000 MT – 1,00,000 MT₹5,00,000
3More than 10,000 MT – 50,000 MT₹2,00,000
45,000 MT – 10,000 MT₹50,000
5Less than 5,000 MT₹25,000

Responsibilities of Stakeholders Under EPR for Waste Oil

Stakeholders must fulfill specific responsibilities to comply with EPR regulations:

Producers: Must register for EPR through the CPCB portal, establish collection mechanisms, and submit periodic returns as prescribed.

Collection Agents: Are responsible for collecting used oil from generators and supplying it to authorized recyclers or producers.

Recyclers: Must carry out recycling operations in accordance with CPCB-approved guidelines and environmental norms.

Importers: Must ensure that imported used oil is utilized strictly for re-refining purposes and complies with all applicable regulatory requirements.

The amended Hazardous Waste Management Rules clearly define these responsibilities to ensure proper handling, recycling, and regulation of used oil across the entire value chain.

Producers

EPR Registration: Producers must obtain EPR registration for used oil through the CPCB (Central Pollution Control Board) portal.

EPR Targets: Producers are required to meet EPR targets based on the quantity of base oil or lubricating oil sold in the market.

Collection and Storage: Producers must arrange proper collection, transportation, and storage of used oil in accordance with CPCB guidelines.

Contact Information: Producers must provide valid contact details on their website or through other communication channels to facilitate used oil collection.

Awareness Programs: Producers are required to promote awareness regarding used oil collection and recycling through appropriate outreach activities.

Record Keeping and Reporting: Producers must file quarterly and annual returns online, including detailed records of used oil generation and recycling.

Collection Agents

Registration: Collection agents must register on the CPCB portal.

Collection and Supply: Collection agents are responsible for collecting used oil from generators and supplying it to registered recyclers or producers.

Collection and Storage: Collection agents must ensure the safe collection, transportation, and temporary storage of used oil as per CPCB guidelines.

Compliance: Collection agents must comply with all applicable regulatory requirements and accurately report their activities.

Record Keeping and Reporting: Collection agents must file quarterly and annual returns online, providing detailed information on used oil collection and supply.

Recyclers

Registration: Must register on the CPCB portal and cannot engage with non-registered entities.

Recycling Processes: Should follow CPCB-approved guidelines for recycling used oil.

Certification: Must issue EPR certificates to producers after recycling, detailing the quantity of used oil processed and compliance status.

Reporting: Must submit annual and quarterly reports on recycling activities to the CPCB.

Record Keeping: Maintain detailed records of used oil collection and recycling, and file quarterly and annual returns online.

Importers

EPR Registration: Must register imported used oil on the CPCB portal.

EPR Targets: Must ensure 100% recycling of used oil imported in the previous year.

Usage Restriction: Imported used oil must only be xused for re-refining. Non-compliance may lead to cancellation of registration and legal action.

By fulfilling these responsibilities, stakeholders play a crucial role in effective used oil management, contributing to environmental sustainability and efficient resource utilization.

Documents Required for Used Oil EPR Compliance

CategoryDocument / RequirementDescription
Registration DocumentsID and Address ProofID and address proof of individuals responsible for compliance.
Business Registration DocumentsCertificate of Incorporation (CIN), MOA, Partnership Deed, MSME registration, etc.
PAN and GST DetailsPAN and GST registration details of the business.
Import Export Code (IEC)Required for importers of used oil.
Operational DocumentsDetails of ManufacturingInformation about manufacturing process, machinery used, and production capacity.
EPR PlanPlan detailing how the business intends to meet its EPR targets for used oil.
Annual ReturnsPrevious annual returns indicating the quantity of used oil generated and managed.
Data on Used Oil GenerationRecords showing quantity and sources of used oil generated.
Compliance DocumentsEPR Registration CertificateIssued by the CPCB.
Collection and Transportation RecordsShowing arrangements for collection, transport, and storage of used oil.
Recycling AgreementsContracts with registered recyclers for supplying used oil for recycling.
EPR CertificatesIssued by recyclers confirming the quantity of used oil recycled.
Reporting & AuditAnnual and Quarterly ReportsSubmitted online to the CPCB detailing used oil management activities.
Environmental Audit ReportsReports from CPCB or authorized third parties verifying EPR compliance.
Additional DocumentsAwareness Campaign RecordsRecords of programs informing stakeholders about used oil collection and recycling.
Contact InformationProvided via the business website or other communication channels to facilitate collection.
Environmental Compensation RecordsRecords of environmental compensation paid for non-compliance with EPR obligations.

Maintaining these documents ensures compliance with EPR regulations, facilitates smooth used oil management, and supports environmental sustainability and resource efficiency.

Process of EPR Compliance for Used Oil

01
Registration of Parties

Producers, importers, collection agents, and recyclers must register on the CPCB portal. Separate registration is required for multiple roles. PAN and GST details must be provided, and annual maintenance fees paid as specified by CPCB.

02
EPR Targets for Producers and Importers

Targets are set based on the quantity of base oil or lubricating oil sold or imported in the previous financial year. They start at 10% and gradually increase up to 60%. CPCB may adjust for operational losses.

03
Collection and Transportation of Used Oil

Proper collection, transport, and storage must be arranged. Partnership with registered collection agents is necessary to gather used oil from various sources.

04
Recycling Process

Used oil must be supplied to CPCB-registered recyclers. Recycling must be performed following CPCB guidelines to ensure environmental safety.

05
EPR Certificates

Producers and importers purchase EPR certificates from recyclers to demonstrate compliance. Certificates must document the quantity of used oil recycled.

06
Reporting and Record-Keeping

Annual and quarterly returns must be submitted online to CPCB detailing used oil management activities. Environmental audit reports verify compliance.

07
Audit and Verification

CPCB or authorized third parties may conduct audits to verify compliance. In case of discrepancies, the lower figure prevails.

08
Environmental Compensation

Failure to meet EPR obligations requires payment of environmental compensation, held in a separate escrow account managed by CPCB.

09
Renewal and Updates

CPCB renews EPR targets annually based on performance and sales data. Stakeholders are expected to continuously improve compliance efficiency.

Following these steps ensures environmental protection, sustainable used oil management, and supports the transition to a circular economy.

Environmental Compensation Under EPR for Used Oil

Environmental compensation under EPR for used oil is a financial penalty imposed on entities failing to meet their EPR obligations. This includes non-registration, providing false information, or not recycling the mandated amount of used oil. The compensation is deposited into an escrow account managed by the Central Pollution Control Board (CPCB), which uses these funds to collect, recycle, and dispose of uncollected and unrecycled used oil. Despite paying the compensation, entities must still fulfill their EPR targets. Successful compliance within a specified time can result in partial refunds of the compensation paid.

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